PRIVACY POLICY EFFECTIVE JULY 25, 2022
PRIVACY POLICY
Effective date: July 25, 2022
This Privacy Policy (Policy) is applicable to all websites and mobile applications, including the podcasts or other media services offered thereby (collectively referred to as the Site) owned and operated by American Public Media Group (APMG) or one of its affiliates and related companies, including Minnesota Public Radio (MPR), American Public Media (APM), Southern California Public Radio (SCPR), American Public Media Foundation, LAist, and the Glen Nelson Center (collectively referred to as “APMG,” “we,” “us,” and “our”). “You” means you, the user, who accesses or uses this Site.
APMG has provided this Policy so that you will know what information APMG collects, how APMG uses this information, the types of third parties with whom APMG may share this information, and some of the choices that are available to you. Please read this Policy carefully before using this Site. By using this Site, you agree to the terms of this Policy and any additional Privacy Notices (as described below) and our collection, use, and disclosure of information as described here and in such notices. If you do not agree with the practices described in this Policy and any other applicable Privacy Notice, you may choose not to access or use the Site.
Your use of this Site is also subject to any applicable Terms and Conditions or other agreements we may have with you. You may find the applicable Terms and Conditions here.
ADDITIONAL PRIVACY NOTICES
This Policy may be supplemented or amended from time to time by additional privacy notices (“Privacy Notices”), provided at the time we collect your information or otherwise applicable to particular services we provide. For example, certain pages of this Site may contain Privacy Notices providing more details about the information we collect on those particular pages, why we need that information, and choices you may have about the ways we use that information. In other cases, specific Privacy Notices may be required to comply with the privacy laws of one of the locations in which we do business.
In situations where a Privacy Notice contains information that conflicts with this Privacy Policy, then the Privacy Notice takes priority.
Please carefully read this Privacy Policy and any applicable Privacy Notices before providing information to us.
PERSONAL INFORMATION WE MAY COLLECT
For the purposes of this Policy, “personal information” is any information that identifies you or can be used to contact you. The types of personal information we may collect through this Site can be grouped as follows:
Contact information – Name, pronouns, email address, mailing address, telephone number, (in certain circumstances) company name, and other similar contact information.
Communication, event, and marketing information – Details regarding informational and promotional materials you have requested or received from us, information you may have downloaded from this Site, your event registrations, your subscription to receive informational or promotional communications from us, and information on your marketing or communication preferences.
Transactional information – If you make a donation, purchase products, or become a member of APMG or one of its affiliates through this Site, details regarding the donation made, products purchased, or your membership, including your bank account, information regarding your payment or donation method, and details relating to the transaction.
Inquiry information – Copies of communications, inquiries, or other information you have submitted to us, including user generated content and other information submitted through features available on this Site.
Site usage information – Details regarding how and when you use this Site, including the device used to connect to this Site, your internet protocol (IP) address, the frequency and duration of your visits, and information about your interaction with this Site.
Survey and demographic information - Demographic details, such as age, education status, profession, income level, and gender may be collected if a member participates in our surveys or audience research, or otherwise responds to a request for such information from APMG.
Job applicant information – If you apply for a job through this Site, contact information, information regarding your qualifications and background, educational information, and any other information you provide as part of your application or the application process.
We (or third parties acting on our behalf) collect this information from you when you fill out forms on this Site, subscribe to receive informational or promotional communications or one of our newsletters from us, make a donation via this Site, download information from this Site, apply for a job, register with this Site, comment on a news item or article on the Site, email or communicate with us, order and schedule orders for benefits, rewards, products and services from or through us and our partners, or otherwise interact with this Site.
We also collect this information from third parties who you have provided the information to. You may be able to register with, log on to, or enhance your profile on this Site by choosing to automatically populate the requested data fields with information you previously provided to a third-party social media platform (such as Facebook or Twitter). By doing this, you are asking the third-party platform to send us information, including personal information, from your profile on that platform. We treat that information as we do any other information you give to us when you register, log on, or enhance your profile.
We also collect this information from third-party providers from whom APMG may rent or purchase lists in order to reach prospective members of its charitable organizations or activities.
OTHER INFORMATION WE MAY COLLECT
Like most websites, we use various technologies to automatically collect information about you, including the following:
IP Address or Device Identifier – When you visit this Site, we collect your Internet Protocol (“IP”) address, which identifies the computer, device, or service provider that you use to access our website. We may use these identifiers to collect information about the length of time spent on our website or the specific areas visited.
Cookies - Cookies are small text files that can be used by websites to make a user’s experience more customized. The cookies used in connection with this Site may be deployed by us or one of our third-party vendors or service providers (described in more detail in the section titled, “Third Party Cookies,” below). This Site uses different types of cookies to, among other things, automatically recognize you when you return to this Site, store information regarding your preferences (including preferred payment methods), serve relevant advertising to you, personalize content for you, provide social media functionality, and analyze our website traffic and audience. Cookies may collect, transmit or store information that does not reference any other personal information, such as usage data, or cookies may collect, transmit, or store information that does reference other personal information, such as name and credit card information. You may have the option to set your browser, application, or device to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies. Please note that if cookies are disabled, you may not be able to enjoy certain features of this Site.
Web beacons and other technologies – This Site may use other tracking tools, including web beacons, which are small electronic images embedded in web content and email messages that are not ordinarily visible to users. Web beacons allow us to track pages and content accessed and viewed by users, as well as to monitor email readership. We may also use pixels to track visitors.
GPS and location tracking - We may also collect precise, real-time location information from your mobile device in connection with your use of our mobile applications. We may use that information to deliver notifications to you via our mobile applications. We may also link location information to information that identifies you. Your mobile device may allow you to adjust your settings so that location information is not available to any mobile website or application. If you have questions about the security and privacy settings of your mobile or tablet device, please refer to instructions from your mobile service provider, the Google Play Store or Apple App Store, or the manufacturer of your device.
The information we receive through these types of technologies may depend on your browser or device settings. The information we receive from your web browser and device may not, in and of itself, be personally identifiable. Generally, we use the information described above in the aggregate to help us improve this Site and make it more compatible with the technology used by our visitors. However, we may combine it with other information in an attempt to identify you (in which case it becomes personal information), or we may combine it with personal information. We may also review our server logs for security purposes—for example, to detect intrusions into our network—and we might share our server logs, which contain visitors’ IP addresses, with the appropriate investigative authorities who could use that information to trace and identify you.
In addition to the cookies APMG directly delivers to your device through this Site, certain third parties may deliver cookies to you for a variety of reasons. For example, we allow certain of our third-party vendors and service providers that assist us with our customer relationship management practices or our advertising, marketing, and audience research needs. Such vendors and service providers include Google Analytics, Springboard, Quantcast, and our marketing consultants. Vendors and service providers like these deliver cookies on our behalf or in the course of providing their services to us so we can collect transaction related data, better analyze usage of our Site and better understand how visitors engage with our Site. We may permit other third parties to deliver cookies to your device for the purpose of tracking your online behaviors over time and across nonaffiliated websites and/or delivering targeted advertisements either on this Site or on other websites that are based on various factors such as the content of the pages you visit, your searches, and demographic and geographic data.
APMG also engages third-party vendors and service-providers that use cookie-less means to monitor our Site traffic, such as Comscore. These vendors and service providers may use these other technologies to automatically collect information from you when you visit or use this Site in order to assist us with our website improvement, marketing, and advertising needs.
You may have choices about the collection of information by third parties on our Sites and the advertisements you receive, as discussed in the “Your Choices” section below. Please note that we do not have access to or control over the use of cookies or other tracking technologies on your device by non-affiliated third parties, and this Policy does not apply to such activity. Those parties that use these technologies may offer you a way to opt-out of ad targeting as described below.
HOW WE USE YOUR INFORMATION
We may use the information we collect from or about you:
to provide the information, products and services you request;
to respond to your questions, concerns, and otherwise provide appropriate customer service;
to provide you with a personalized or optimized experience when you use this Site;
to contact you with information and notices related to your use of this Site or information we have received from you;
to contact you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us) and engage in advertising, including interest-based advertising;
to determine your interest in receiving, and provide you with, donor or member materials and communications;
to invite you to participate in surveys and provide Feedback to us (in accordance with any privacy preferences you have expressed to us);
to improving our knowledge and insights regarding our members, the audience for our services, and the individuals use our Site;
to collect, measure, and analyze traffic and usage patterns, conduct market or audience analysis, and improve the quality and effectiveness of our Site, content, and offerings;
to better understand your needs and interests;
to improve our products and services;
to improve our marketing and promotional efforts;
to prevent and detect fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the Site
for any other purpose identified in an applicable Privacy Notice, click-through agreement or other agreement between you and us; and
to perform other functions as otherwise described to you at the time of collection or that you otherwise consent to.
If you have questions regarding our use of your information, feel free to contact us using the information provided at the end of this Policy. For more information about your options relating to your information and your communication preferences, see “Your Choices” below.
HOW WE SHARE YOUR INFORMATION
When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, it is not “Personal Information” and we may use that information for any purpose, including sharing it with third parties, to the extent permitted by applicable law.
In addition, we may share your information with the following entities or under the following circumstances:
Third–Party Vendors, Service Providers, and Volunteers - APMG shares information collected through this Site with third-party vendors, service providers, and volunteers who act for us or on our behalf or are used by us to support our business. For example, we may use third-party vendors, service providers, and volunteers to design and operate this Site; to conduct surveys; to help us with our promotional efforts; to process and deliver our email communication system; to process donations made through this Site; to process purchases made through this Site; to contact Members and other subscribers to our newsletters or promotional materials. These third-party vendors, service providers, and volunteers may need information about you to perform their functions for us.
Other Users of this Site - You may be able to submit comments, content, or information on or through this Site using the tools or features we make available to you whether in the form of User-Generated Content or Feedback (as defined in our Terms of Use) (collectively, “User Submissions”). Any personal information contained in User Submissions can be read, collected, or used by APMG and others, including our vendors and service providers and other users of this Site. In addition, we may use User Submissions you submit for advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the content for such purposes. Therefore, you should have no expectation of privacy with respect to User Submissions you submit on or through this Site and acknowledge that when you submit User Submissions on or through this Site you are authorizing APMG to use it in accordance with this Policy.
Third-Party Social Media Platforms - We may provide functionality on this Site that allows you to automatically post information about the actions you take on this Site to a third-party social media platform (such as Facebook or Twitter). If you choose to take advantage of this functionality, people with access to your profile on the third-party platform may be able to see the actions you have taken—for example, the items you have purchased. Thus, you should have no expectation of privacy in those actions. Further, if you choose to link your profile on this Site with an account on a third-party social media platform, we may share the information in your profile with that third-party platform.
Our Related Companies - APMG may share the information collected through this Site or otherwise provided by you to us with other APMG affiliates and related companies, such as MPR, APM, SCPR. These related companies are permitted to use your information for their own marketing purposes and in a manner otherwise consistent with this Policy.
Other, Carefully Selected Business Partners - From time to time, we may share your information with selected third parties for their own marketing purposes, except as noted in any applicable Privacy Notices. (For example, we do not rent, sell or trade member or contributor information.).
As Part of a Business Transfer - Your information may be transferred to a successor organization if, for example, we transfer the ownership or operation of this Site to another organization or if we merge with another organization, or if we experience any reorganization, restructuring, divestiture, acquisition, dissolution or other sale of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred. If such a transfer occurs, the successor organization’s use of your information will still be subject to this Policy and the privacy preferences you have expressed to us.
To Comply with Laws and Protect Our Rights and the Rights of Others- We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of this Site; to enforce or apply our online Terms and Conditions or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.
We reserve the right to disclose your information as described in any Privacy Notice posted on a page of this Site where you provide that information. By providing your information subject to the applicable Privacy Notice you will be consenting to the disclosure of your information as described in that Privacy Notice. We also reserve the right to disclose your information as described in any click–through agreement to which you have agreed.
HOW WE PROTECT YOUR INFORMATION
APMG takes reasonable precautions to provide a level of security appropriate to the sensitivity of the information we collect. Please be aware that no data transmission over the Internet is 100% secure. Although we use reasonable measures to help protect your information against unauthorized use or disclosure, we cannot ensure or do not make any warranties regarding the security of any information you transmit to us and you do so at your own risk.
CHILDREN’S PRIVACY
THIS SITE IS A GENERAL AUDIENCE SITE, AND IS NOT DIRECTED AT, OR INTENDED FOR USE, BY CHILDREN UNDER THE AGE OF 13 YEARS. WE DO NOT KNOWINGLY COLLECT, USE OR DISCLOSE PERSONAL INFORMATION DIRECTLY FROM VISITORS UNDER 13 YEARS OF AGE. IN SOME INSTANCES, HOWEVER, PARENTS OR LEGAL GUARDIANS MAY SUBMIT INFORMATION REGARDING THEIR CHILDREN TO APMG (E.G., DRAWINGS, QUESTIONS FOR A PODCAST HOST, ETC.). IF YOU BELIEVE WE HAVE COLLECTED OR OBTAINED INFORMATION FROM A CHILD UNDER AGE 13, CONTACT US AT THE “CONTACT US” INFORMATION PROVIDED BELOW.
LINKS TO OTHER WEBSITES
This Site may also contain links to websites that are not operated by APMG or its affiliates. This Policy does not apply to personal information collected through such websites. These links are provided for your reference and convenience only and do not imply any endorsement of the products sold or information provided through these websites, nor any association with their operators. APMG does not control these websites and is not responsible for their data practices. Any information you provide to third parties on their websites is covered under their privacy and data collection policies and is not covered by this Policy. We urge you to review the privacy policy posted on any site you visit before using the site or providing any personal information.
YOUR CHOICES
We respect your right to make choices about the ways we collect, use, and disclose your information.
APMG tries to offer you such choices in a meaningful way and at an appropriate time—for example, at the time and on the page where you provide your information. Some choices you have regarding personal information include the following.
Do Not Track Mechanisms - Please note that APMG does not honor “Do Not Track” signals, and such signals will not impact the operation of this Site.
Previously Expressed Preferences - You may change previously expressed preferences regarding how we use your information. If you have registered with this Site or downloaded one of our mobile applications, you may be able to change certain privacy preferences, such as limiting or opting out of push notifications, through your account settings or via the settings on your device. You can also unsubscribe from our promotional emails at any time, by clicking the “Unsubscribe” link in the email, and you can unsubscribe from promotional text messages at any time by texting STOP in response to a text message we send you. Otherwise, please contact us.
Marketing Emails – As required by applicable laws, you can opt-out of receiving promotional emails from us by clicking the “opt out” link in any such promotional emails and following the instructions provided.
Cookies – Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies. Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same. Please note that if you disable or delete cookies, you may not be able to access or use certain features of the Site.
Tracking Systems – As discussed above, we use the services and tools of third-party vendors and service providers in connection with the Site to assist us with our customer information management, marketing, advertising, and audience research needs. These vendors and service providers may include Google Analytics, Google Adwords, Google Tag Manager, Comscore, Chartbeat, Parse.ly or the like. Google has developed resources to help you manage your choices in this regard. If you would like to refrain from having your data collected by Google Analytics or otherwise indicate to Google your desire to opt-out of certain targeting, Google has developed an opt-out browser that you can use. Users can opt out of Google's use of cookies for advertising, including DoubleClick cookies, by visiting Google's Ads Settings page. Users can opt out of third-party advertising cookies from a wide range of advertising services, including Google, by visiting the Network Advertising Initiative's Opt-Out page. You can find more information on how Google uses information it collects here.
Interest-Based Advertising – To opt-out of personalized or interest-based advertisements, you may be able to adjust the settings on your device. Please go to your device settings and opt-out through the controls provided through Google/Android or iOS, as applicable. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices, has its own instructions on how to prevent the delivery of interest-based advertisements. (We cannot guarantee that these instructions will not change, or that they will continue to be available; they are controlled by each mobile platform, not us.). For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator. Users can opt out of Google's use of cookies for advertising, including DoubleClick cookies, by visiting Google's Ads Settings page. Users can opt out of third-party advertising cookies from a wide range of advertising services, including Google, by visiting the Network Advertising Initiative's Opt-Out page. You can also visit https://optout.aboutads.info for more information about how to opt out of interest-based advertisements.
Declining to Provide Information – If you do not consent to the collection, use, or sharing of your information as described in this Policy, you can choose not to use the Site or provide us with information when prompted. By using the Site or providing us with information, you consent to the collection, use, and sharing of your information as described in this Policy.
In addition to the above, you may contact APMG at the “Contact Us” details below to update your information or confirm your information is accurate. We will respond to your request. and will use reasonable efforts to comply with your request, as required by applicable law.
CHANGES TO THIS POLICY
APMG is continually improving and adding to the features and functionality of this Site and the services we offer through this Site. As a result of these changes (or changes in the law), we may need to update or revise this Policy. Accordingly, we reserve the right to update or modify this Policy at any time, without prior notice, by posting the revised version of this Policy behind the link marked “Privacy Policy” at the bottom of each page of this Site. Your continued use of this Site after we have posted the revised Policy constitutes your agreement to be bound by the revised Policy.
APMG will update the “Last Updated” date at the top of this page. When you visit this Site, be sure you check the “Last Updated” date to see if this Policy has been revised since your last visit.
RETENTION OF PERSONAL INFORMATION
APMG RETAINS THE PERSONAL INFORMATION COLLECTED FROM YOU OR ABOUT YOU AS LONG AS NECESSARY TO PROVIDE THE SERVICES, PRODUCTS AND INFORMATION YOU REQUEST OR AS PERMITTED BY APPLICABLE LAW.
DATA TRANSFERS AND LOCATION
APMG is based in the United States and the servers that support this Site are located in the United States. While it is in our possession, your information will generally be stored in APMG databases or databases maintained by our third-party service providers on servers and data storage devices located in the United States. U.S. data protection laws may not provide as much protection as the data protection laws in force in some other countries, however, we will process your information in accordance with this Policy no matter where our data is stored. If you are located in a country outside the United States, by accessing or using this Site you acknowledge and consent that your information, including personal information, will be transmitted to, processed and stored, in the United States.
VISITORS FROM THE EU, UK, AND SWITZERLAND
As indicated above, APMG is headquartered in the United States. Its Site, products, and services are intended for use or purchase by individuals in the United States. AMPG does not intentionally offer or market its goods or services to individuals outside the United States and does not intentionally seek information relating to such individuals. As such, APMG is subject only to the laws of the United States.
When applicable, the General Data Protection Regulation (GDPR) affords individuals in the EU, UK, and Switzerland (collectively, EU) certain rights regarding their personal information, including the rights to (1) withdraw consent or object the processing of their personal information, (2) correct, access, or request a copy of their personal information, (3) erase their personal information, (4) transfer their personal information to another entity or individual, and (5) the right to restrict the processing of their personal information. To the extent APMG receives a verifiable request seeking to exercise one of these rights, APMG will reasonably endeavor to respond to such requests. But because APMG is not subject to the GDPR, we are under no obligation to do so.
VISITORS FROM CALIFORNIA
California’s “Shine the Light” law allows California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding year. If you are a California resident and wish to make such a request, please send an email with “California Shine the Light” in the subject line to the email and/or regular mail address provided below under “Contact Us.”
When applicable, the California Consumer Privacy Act (CCPA) provides California residents with additional rights relating to their personal information. The rights available under the CCPA including the rights to (1) receive information from a business about the personal information it collects from an individual and how it is used, (2) request the business delete personal information about the individual, (3) request that the business provide copies of personal information about the individual, and (4) opt out of the sale of the individual’s personal information. If a California resident submits a verifiable request seeking to exercise one of these rights, APMG will reasonably endeavor to respond to such request. The CCPA, however, does not apply to non-profit entities like APMG and APMG is under no obligation to respond.
QUESTIONS ABOUT THIS POLICY OR AMERICAN PUBLIC MEDIA GROUP’S DATA PRACTICES
If you have questions or concerns about this Policy, any Privacy Notice, or APMG’s data practices, please contact us at:
American Public Media Group
Attn: Chief Privacy Officer
480 Cedar Street
St. Paul, MN 55101
privacy@americanpublicmedia.org
1-800-228-7123