Privacy Policy

SummitMedia, LLC, along with its subsidiaries and affiliates (collectively, "Company," "us," "we," or "our"), is committed to protecting the privacy of Personal Data (i.e., information that identifies, relates to, describes, or is reasonably capable of being associated with or linked to a particular individual or household). This Privacy Notice outlines how we handle Personal Data collected through our websites, social media accounts, mobile applications, SMS messages, and other online interactions and communications, such as email (collectively referred to as our “Digital Properties”); in-person events and purchases; and other online and offline interactions.

This Privacy Notice concerns information collected about individual consumers, including general website visitors (“Individuals”), as well as data gathered about the personnel of our business partners, such as vendors and business clients, during business-to-business interactions (“Business Contacts”). However, this Privacy Notice does not apply to information concerning our current or former employees, applicants, and other individuals who engage with us for employment-related purposes.

Additionally, this Privacy Notice does not cover data we manage on behalf of, and under the guidance of, our business customers. When you interact with us on behalf of another individual or entity, such as when you refer a friend, you must obtain their consent (or possess the legal authority to share their Personal Data without permission).

1. Sources of Personal Data

We collect Personal Data about you from the following sources:

• Directly from you. We may collect Personal Data that you provide to us, such as when you contact us through our Digital Properties, register for an event, interact with us in person, sign up for offers, communicate with us, place orders, enter sweepstakes, complete surveys, or create an account and access other services.
• Automatically and through tracking technologies. We may automatically gather information or inferences about you, such as through cookies and other tracking technologies, when you interact with our Digital Properties as described in Section 5 (Cookies and Other Tracking Technologies).
• From third parties. We may collect Personal Data from third parties, including service and content providers, affiliated companies and subsidiaries, business partners, data brokers, social media companies, and other entities that interact with us.
• From publicly available sources. We may gather Personal Data about you from publicly accessible sources, including public profiles and websites.

We may merge information obtained from the various sources outlined in this Privacy Notice, including third-party sources, and use or disclose the merged information for the purposes identified below.

2. Types of Personal Data We Collect

We may collect the following types of Personal Data. Unless otherwise specified, we may gather this Personal Data from both Individuals and Business Contacts.

• Identifiers, such as your name; email address; postal address; telephone number; other contact information; account details; and device identifiers (including cookie IDs and IP address).
• Records related to you, such as user-generated content (e.g., forum posts); preference information, such as marketing preferences; account settings; the content, timing, and method of communications with us, including calls and emails; and signatures.
• Demographic information, such as age (including birthdate) and gender.
• Commercial information, such as details about your transactions, products or services you purchased, obtained, or considered, subscription details, and other buying or consumption histories and trends.
• Information regarding your activity on the internet or other electronic networks, such as your browsing history, search history, and other details about your interactions with and use of the Digital Properties. For more information about cookies and other device data, please refer to Section 5 (Cookies and Other Tracking Technologies).
• Imprecise geolocation data, such as your approximate location based on your IP address.
• Audio, electronic, visual, or other sensory information, such as photographs (including those taken at events or uploaded to our Digital Properties), call recordings, recorded messaging, and video recordings.
• Professional or employment-related information (for Business Contacts only), such as job title, organization, professional licenses, credentials, and affiliations.
• Education information (if you choose to provide it).
• Inferences drawn from the information we collect about your preferences or behavior, such as assessing your interest in our products and services based on visit frequency and contact and determining your preferred frequency for receiving offers.
• Sensitive Personal Data, including the following:
• Account login credentials (such as a username or email address in combination with a password).
• Precise geolocation (collected only with your permission).
• Government-issued identifiers, such as Social Security number or driver’s license number, collected from contest and sweepstakes winners for prize fulfillment, identity verification, and tax reporting.

3. How We Use Personal Data

We may use Personal Data for the following purposes:

• To provide you or your company products and services, including making our Digital Properties and other products and services accessible to you; offering customer service; processing or fulfilling orders and transactions (which includes handling payments); verifying customer information and eligibility for specific programs or benefits; communicating with you (such as soliciting feedback or responding to requests, complaints, and inquiries); and delivering similar services or otherwise facilitating your relationship with us.
• For our internal business purposes, including day-to-day operations, maintaining internal records, enforcing our policies and rules, generating management reports, conducting audits, and ensuring IT security and administration.
• For our internal research and product improvement purposes, such as verifying or maintaining the quality and safety of our products and services; enhancing our products and services, including Digital Properties; designing new products and services; assessing the effectiveness of our advertising and marketing efforts; and debugging and repairing errors in our systems, networks, and equipment.
• For legal, safety, or security reasons, including compliance with legal and reporting requirements; investigating and addressing claims against us, our personnel, and our customers; establishing, exercising, or defending legal claims; safeguarding the safety, property, or rights of ourselves, you, our customers, and other third parties; detecting, preventing, and responding to security incidents and health and safety issues (including managing the spread of communicable diseases); and protecting against malicious, deceptive, fraudulent, or illegal activities.
• In connection with a corporate transaction, whether we acquire assets from another entity or sell or transfer all or part of our business or assets, including through a sale related to bankruptcy or other forms of corporate change.
• For marketing and targeted advertising, such as promoting our products or services, or those of our affiliates, business partners, or other third parties. For instance, we may utilize the Personal Data we collect to personalize advertising (including developing audiences for products, brands, or services and identifying you across devices and sites); to analyze interactions with us, including our Digital Properties; to conduct sweepstakes, giveaways, and contests; and to send you newsletters, surveys, questionnaires, promotions, or information about events.

We may use and disclose de-identified or aggregated information for any purpose permitted by law. When we maintain de-identified information, we will maintain and use it in de-identified form and will not attempt to re-identify it, except as permitted by law.

4. How We Disclose Personal Data

We may disclose Personal Data to third parties, including the categories of recipients described below:

• Affiliates, subsidiaries, parent entities, corporate affiliates, business units, and other companies sharing common ownership.
• Service providers that work on our behalf to deliver the products and services you request, or to support our relationship with you, such as IT providers, internet service providers, web hosting providers, data analytics providers, and companies offering business support services, financial administration, or event organization.
• Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.
• Vendors necessary to complete the transactions you request, such as shipping companies, payment processors, and logistics providers.
• Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when we share information to comply with laws or legal requirements; to enforce or apply our terms, agreements, or policies; and to protect the safety, property, or rights of ourselves, our customers, and other third parties.
• Other entities involved in a corporate transaction, such as if we acquire assets from another entity, or sell or transfer all or part of our business or assets, including through a sale related to bankruptcy and other corporate changes.
• Business partners who may use Personal Data for their own purposes, such as:
• Advertisers, ad platforms and networks, and social media platforms.
• Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Other Tracking Technologies).
• Commercial data partners to whom we make information available for their marketing purposes.
• Partners collaborating with us on promotional or sponsorship opportunities, such as sweepstakes and co-branded products and services.

If recipients utilize your Personal Data for their own purposes independent of us, we are not responsible for their privacy practices or Personal Data processing practices. We encourage you to review the privacy notices of those third-party services for information on their practices.

• The public, when you choose to post comments, reviews, or other content in public areas of our Digital Properties, such as our blogs and forums. Any Personal Data you share in these areas may be read, collected, or used by other users or the public.

• Entities to which you have consented to the disclosure.

5. Cookies and Other Tracking Technologies

The Company and our authorized third parties use cookies and other tracking technologies to collect information about you, your device, and how you interact with our Digital Properties. This section contains additional information about:

• The types of tracking technologies we use and the purposes for which we use them
• The types of information we collect using these technologies
• How we disclose or make information available to others
• Choices you may have regarding these technologies

• Types of cookies and tracking technologies we use

We and the third parties that we authorize may use the following tracking technologies:

• Cookies are a type of technology that places a small amount of information on your computer or other device when you visit a website. Some cookies exist only during a single session, while others persist across multiple sessions.
• Pixels, web beacons, and tags are types of code or transparent graphics. In addition to the uses described below, these technologies provide analytical insights into user experiences and assist us in customizing our marketing efforts. Unlike cookies, which are stored on your device, pixels, web beacons, and tags are embedded invisibly in web pages and emails.
• Session replay tools capture your interactions with our Digital Properties, including how you navigate and engage with our web forms. Besides the uses described below, this information helps us enhance our Digital Properties and identify and resolve any technical issues visitors may encounter.
• Embedded scripts and SDKs, which allow us to build and integrate custom apps and experiences on our Digital Properties.

• Purposes for using these technologies

We and authorized third parties use these technologies for purposes including:

• Personalization may include remembering your language preferences and the pages and products you have viewed to enhance and tailor your experience when visiting our Digital Properties.
• Enhancement includes maintaining and improving the performance of our Digital Properties while enhancing the user experience.
• Analytics involves examining how our websites are used and generating insights. For example, we use Google Analytics to improve the user experience. Google Analytics may use cookies and other tracking technologies to provide its services. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners' sites or apps” at https://policies.google.com/technologies/partner-sites.
• Advertising includes activities like running promotions and personalizing content on our Digital Properties and those of third parties; monitoring user behavior over time and across properties to create a profile of interests for interest-based advertising; presenting you with offers and online content that may be of interest; optimizing ad campaigns; and assessing the effectiveness of our advertising efforts and communications with you, including identifying when and how you engage with our emails.
• Security, including preventing fraud and malicious behavior.

• Information Collected

These tracking technologies gather data about you and your device, including your IP address, your Internet service provider’s name, device type, location (approximate and, with your permission, precise), cookie ID, device ID, ad ID, operating system, browser used, referring domain, browsing history, search history, and details about how you interact with our Digital Properties (such as the pages on our Digital Properties that you have viewed).

• Disclosures of your information

We might disclose information to third parties or permit them to collect information directly through these technologies on our Digital Properties. This includes social media companies, advertising networks, analytics providers for ad tracking and reporting, security services, and others who assist us in operating our business and Digital Properties.

6. Your Choices

• Cookies and tracking technologies

Some of the third parties we collaborate with are members of the Digital Advertising Alliance ("DAA") and the Network Advertising Initiative ("NAI"). The DAA and NAI provide options for opting out of interest-based advertising from participating members at https://optout.aboutads.info/ and https://optout.networkadvertising.org/. We comply with the DAA's Self-Regulatory Principles for Online Behavioral Advertising. Additionally, you can click the AboutAds icon on a company’s advertisement and follow the prompts to opt out. For mobile apps, you can use the DAA’s AppChoices app or your device’s advertising settings.

You can refuse or delete cookies through your browser settings. Some functionality of our Digital Properties may be affected if you choose to refuse or delete cookies. Please refer to your browser's Help section to learn more about managing cookies and other tracking technologies. If you switch computers, devices, or browsers, use multiple devices, or delete your cookies, you may need to repeat this process for each one. Opting out of interest-based advertising does not mean you will stop receiving all advertising; it only affects the interest-based advertising from participating parties.

Some browsers offer a Do Not Track (“DNT”) setting. Because there is no common industry standard for interpreting DNT signals, we do not respond to them. However, we recognize the Global Privacy Control (“GPC”) signal. When we detect a GPC signal, we treat it as a request to opt out of the sale or sharing of Personal Data and of targeted advertising for that browser or device and, if you are logged in, for your account. You may also opt out by clicking the “Your Privacy Choices” link in the footer of our websites.

Marketing emails. You can unsubscribe from our marketing emails at any time by clicking the unsubscribe link in any email. We may still send you transactional or account-related messages.

7. Data Security and Data Retention

While we implement reasonable security safeguards, no security measures or communications over the Internet can be completely secure, and we cannot guarantee the protection of your information.

Your Personal Data will be retained as necessary to fulfill the purposes mentioned above, unless we are required to do otherwise by applicable law. This includes retaining your Personal Data to provide you with the products or services you have requested, to engage with you, to complete your transaction, to maintain our business relationship, to enhance our business over time, to ensure the ongoing legality, safety, and security of our services and relationships, or as required by our internal retention procedures. After you terminate your relationship with us, we may keep your Personal Data in our systems and records to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as facilitating future onboarding, demonstrating our business practices and contractual obligations, or providing you with information about our products and services if you express interest. When setting retention periods, we consider the amount, nature, and sensitivity of the data, the purposes for which we process it, and our legal obligations. When Personal Data is no longer needed, we delete or de-identify it.

8. Children's Privacy

Our Digital Properties are intended for individuals 18 years of age and older. They are not directed to, marketed to, or intended for children under 18. We do not knowingly collect any information, including Personal Data, from individuals under 18.

If you think we have inadvertently collected Personal Data from a child under 18, please contact us using the information in Section 15 (Contact Information), and we will promptly delete that information.

9. External Links

Our Digital Properties may include links to external websites or other online services that we do not control, including those found in third-party advertisements or sponsorship information. We do not assume responsibility for the privacy practices or data collection policies of these third-party services. We encourage you to review the privacy notices of those services for details about their practices.

10. Mobile Applications and Voice Collection

When you use our mobile applications, we may collect specific data to support functionality, personalize your experience, and improve performance. This may include:

• Device Information (e.g., type, OS, identifiers)
• Location Data (approximate or precise, if permission is granted)
• Voice Data (only when you enable voice features)
• Usage Activity (app interactions, preferences, and diagnostics)
• Push Notification Preferences

You can manage app permissions at any time through your device settings. We do not access your microphone, location, or other sensitive data unless you’ve explicitly granted permission.

Voice Data: When you enable voice features in our applications or services, we may collect, use, and store your voice data, including audio recordings and transcriptions of your voice input when you engage with features such as voice search, commands, interactions, or advertisements.

What We Collect

• Your voice input when you activate voice features (e.g., by pressing a button or responding to a prompt)
• Any metadata related to the voice interaction (e.g., timestamps, interaction context)
• Transcripts generated from your voice input

How We Use Your Voice Data

• To fulfill your voice commands or requests
• To personalize your experience and improve service functionality
• To verify voice-based engagement for promotions or contests
• By sending a voice message, you are consenting to your voice being broadcast on-air, in a podcast, or as part of a public stream (e.g., during voice-based messages or contest entries).

Important

• We do not record or listen to your voice without your active participation. Recording begins only when you engage a voice feature (e.g., pressing a record button or accepting a voice prompt).
• You can disable voice permissions at any time by adjusting your device or app settings.
• We do not use your voice data to create voiceprints or other biometric identifiers, and we do not sell your voice data.

Consent: By activating or using voice features, you consent to collecting and using your voice data as described in this Privacy Notice. If you do not wish to have your voice recorded or used, you should not enable or interact with voice-enabled features.

Push Notifications: If you use our apps, we may occasionally send you push notifications. If you prefer not to receive them, you can disable them in your device settings.

Location Information: We may determine your approximate location when you use the apps and, if you grant permission, your precise location. You can stop the collection of this information at any time by adjusting your preferences in your device settings. Please note that if you do this, certain features of our apps may not function as intended. Additionally, you can uninstall or remove our apps from your device.

11. SMS Messaging Policy

This section describes how SummitMedia, LLC collects, uses, and shares Personal Data in connection with our SMS messaging services (e.g., contest alerts, promotional texts, sweepstakes updates).

How We Collect Information

We collect Personal Data in the following circumstances:

• Direct Collection: information you provide by responding to SMS messages.
• SummitMedia, LLC Sources: contact information we import from other SummitMedia, LLC systems and sources, such as Audience, Text Grove, and InterTech Media. We apply appropriate safeguards to protect this information.
• Automated Collection: information our messaging platform collects automatically as you engage with the service.

What Type of Information We Collect

Direct Collection

We directly collect the following Personal Data:

• Opt-out preferences
• Content of your SMS messages to us
• The name attach to the mobile number, unless blocked

Collection from SummitMedia, LLC Sources

We import Personal Data from SummitMedia, LLC systems and sources. The information can include:

• First and last name
• Phone number

Automated Collection

We automatically collect the following Personal Data:

• Device status indicating whether a device is available for messaging
• Carrier (e.g., Verizon, AT&T, T-Mobile)
• Country linked to the phone (we do not send international SMS messages)
• Delivery status
• Error codes that explain why a message was not delivered (e.g., the number is a landline or the device is unreachable)

How This Information Is Used

We use the Personal Data we collect to communicate with you about SummitMedia, LLC operations and services, including:

• Contests and Sweepstakes: to send entry confirmations, reminders, and winner notifications for station contests and sweepstakes.
• Automated response to information requests: to inform you of important dates or events specific to the requested information.
• Promotional Activities: to share opportunities that may interest you, events, discounts, and offerings through various SummitMedia, LLC services.

With Whom This Information Is Shared

We do not sell, rent, or share your mobile phone number or SMS opt-in data and consent with third parties or affiliates for their marketing or promotional purposes. We share this information only with service providers that help us operate our SMS program, such as Text Groove Communications, Inc., which provides the messaging platform that SummitMedia, LLC and its subsidiaries use for SMS messaging services.

We require our service providers to protect the security of your Personal Data and prohibit them from using or sharing it for any purpose other than delivering services on our behalf.

We may also share your Personal Data when required by law or when we believe that doing so will help protect the safety, property, or rights of SummitMedia, LLC and its subsidiaries.

What Choices You Can Make About Your Information

To stop receiving SMS messages from a campaign or contest, reply with any of the following words: “stop,” “quit,” “end,” “cancel,” “unsubscribe,” “revoke,” or “opt out.” You may also opt out by any other reasonable means, such as by contacting us using the information in Section 15. We will honor your request within 10 business days. For help, reply “help.”

If you would like to re-subscribe, please respond with the specific keyword when prompted.

Please be aware that unsubscribing from SMS messages from one campaign will not automatically unsubscribe you from others. Additionally, unsubscribing will not erase your information from SummitMedia, LLC systems.

Please let us know if your mobile number changes so we can deliver messages accurately.

How SMS Information Is Secured

SummitMedia, LLC recognizes the importance of safeguarding the information it collects and maintains. We are dedicated to protecting this information from unauthorized access and damage, and we strive to implement reasonable security measures, including physical, administrative, and technical safeguards, to secure your Personal Data.

Please note that standard message rates and data charges from your cellular service provider may apply when sending or receiving text messages. Message frequency varies by program. You are responsible for any associated message rates and data charges.

12. Consent Mechanisms

We collect and process specific categories of Personal Data based on your affirmative consent, including but not limited to:

• The use of voice recognition features (e.g., microphone access, voice commands)
• Collection of precise geolocation data
• Participation in marketing communications via SMS or push notifications
• Where required by law, the use of tracking technologies for interest-based advertising

You will be asked to opt in before we enable these features. Your consent will be requested at the appropriate point of interaction — such as through a pop-up, checkbox, or device settings prompt — and we will provide a clear explanation of what data is collected, how it will be used, and with whom it may be shared.

You may withdraw your consent at any time using the tools provided in your device settings, privacy preferences center, or by contacting us directly at the contact information in Section 15.

Please note that withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

13. Your State Privacy Rights

Depending on where you live, you may have some or all of the following rights regarding your Personal Data, subject to exceptions under applicable law. These rights apply to residents of California and the other states that have enacted comprehensive consumer privacy laws.

• Access. Confirm whether we process your Personal Data and obtain a copy of it, including, for California residents, the categories of Personal Data we collected, the sources, the purposes, and the categories of third parties to whom we disclosed it.
• Correction. Correct inaccurate Personal Data.
• Deletion. Request that we delete Personal Data we collected from or about you.
• Portability. Obtain your Personal Data in a portable and, where feasible, readily usable format.
• Opt out of sales, sharing, and targeted advertising. Opt out of the “sale” of your Personal Data, the “sharing” of your Personal Data for cross-context behavioral advertising, and targeted advertising.
• Opt out of profiling. Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.
• Sensitive Personal Data. Withdraw consent to, or (in California) limit, our use of Sensitive Personal Data. We use Sensitive Personal Data only for purposes permitted by law and do not use it to infer characteristics about you.
• List of third parties. Residents of certain states, such as Oregon and Minnesota, may request a list of the specific third parties to which we have disclosed Personal Data.
• Nondiscrimination. We will not discriminate against you for exercising any of these rights.

Sales, Sharing, and Targeted Advertising

We do not sell Personal Data for money. However, as described in Sections 4 and 5, we disclose Personal Data to advertising partners, ad networks, social media platforms, and commercial data partners, and we allow them to collect data through tracking technologies on our Digital Properties. Under some state laws, these activities may be considered a “sale,” “sharing,” or “targeted advertising.” In the past 12 months, we may have sold or shared the following categories of Personal Data: identifiers, commercial information, internet or other electronic network activity, imprecise geolocation, and inferences.

To opt out, click the “Your Privacy Choices” link in the footer of our websites, enable the Global Privacy Control in your browser, or contact us using the information in Section 15. We do not knowingly sell or share the Personal Data of individuals under 18, and we do not sell Sensitive Personal Data.

How to Exercise Your Rights

You may submit a request by (1) completing our online request form at [URL]; (2) emailing [privacy email address]; or (3) calling us toll-free at [1-8XX-XXX-XXXX].

We will verify your identity before responding, typically by matching information you provide with information in our records. You may use an authorized agent to submit a request on your behalf; we may require the agent to provide proof of authorization and may ask you to verify your identity directly with us. We will respond within 45 days of receipt, or within any longer period permitted by law, and will tell you if we need an extension.

Appeals

If we decline to act on your request, you may appeal by emailing [privacy email address] with the subject line “Privacy Request Appeal.” We will respond to your appeal within the period required by your state’s law. If you disagree with our decision, you may contact your state Attorney General.

Additional Information for California Residents

Notice at collection. The categories of Personal Data we collect, the sources, the purposes of use, and the categories of recipients are described in Sections 1 through 5. We retain each category of Personal Data as described in Section 7.

Financial incentives. Contests, sweepstakes, loyalty programs, and similar promotions may require you to provide Personal Data and may be considered a “financial incentive” under California law. The material terms appear in the official rules or program terms presented when you enter or enroll. Participation is voluntary, and you may withdraw at any time by [method]. We reasonably estimate the value of your Personal Data to be equal to [the value of the prize, discount, or benefit offered], calculated based on [method].

Shine the Light. California residents may request information about our disclosure of personal information to third parties for their direct marketing purposes under California Civil Code § 1798.83 by contacting us using the information in Section 15.

Nevada residents. Nevada residents may submit a request to opt out of the sale of covered information by contacting us using the information in Section 15.

14. International Users and Data Transfers

If you access our Digital Properties from outside the United States, please be aware that your information may be transferred to, processed, and stored in the United States, where data protection laws may differ from those in your jurisdiction.

We implement appropriate safeguards to protect your Personal Data in accordance with applicable laws.

15. Contact Information

If you have questions regarding this Privacy Notice, please get in touch with us at:

Email: summitdigital@summitmediacorp.com

Mail:
SummitMedia, LLC
ATTN: Privacy
800 Shades Creek Parkway, Suite 725
Birmingham, AL 35242

16. Changes to This Privacy Notice

We may update this Privacy Notice from time to time and will review it at least once every 12 months. The date of the most recent update appears at the top of this notice. If we make material changes, we will notify you by posting the updated notice on our Digital Properties and, where required by law, by other means.