1. INTRODUCTION

1.1. PURPOSE OF POLICY. Inner Radio LLC (“us,” “we,” or “Company”) is committed to respecting the privacy rights of its customers, visitors, and other users of the Company Website and services (together, the “Site”). We created this Privacy Policy (this “Policy”) to give you information about our collection, use, and disclosure of information about you, as well as your rights regarding that information. This Policy is only applicable to the Site and any offline location where we make this Policy available to you, and not to any other websites that you may be able to access from the Site, each of which may have data collection and use practices and policies that differ materially from this Policy.

1.2. NOTICE CONCERNING CHILDREN

PLEASE NOTE: We are a general audience site, and do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a Site user is under age 13, we will promptly delete any personal information in that user’s account.

2. INFORMATION COLLECTION PRACTICES

2.1. WHAT INFORMATION DOES THE COMPANY COLLECT?

(a) INFORMATION YOU PROVIDE. In operating the Site, Company may include registration, online surveys, and other online forms that ask users to provide their names, e-mail addresses, and other contact information. If you communicate with us by e-mail, post messages to any of our chat groups, bulletin boards, or forums, or otherwise complete online forms, surveys, or contest entries, any information provided in those communications will be collected from you.

(b) AUTOMATIC COLLECTION. When you visit the Site, our servers automatically recognize (1) visitors’ domain names; (2) IP addresses (the number assigned to computers on the Internet); (3) device information; and (4) location data. This “traffic data” may be used for marketing purposes or for improving the services we offer, as explained in more detail below.

(c) TRACKING TECHNOLOGIES. We use “cookies” and other tracking technologies that allow us to store a small piece of data on your computer about your visit to the Site. Cookies help us learn which areas of the Site are useful and which areas need improvement. You can choose whether to accept cookies by changing the settings on your browser. However, if you choose to disable this function, your experience at the Site may be diminished and some features may not work as they were intended.

3. USE AND SHARING OF INFORMATION

3.1. WHAT DOES COMPANY DO WITH COLLECTED INFORMATION?

(a) OPERATING OUR SITE AND PERFORMING SERVICES. We use your personal information to verify your identity, to check your qualifications, or to follow up with transactions initiated on the Site. We may also use your contact information to inform you of any changes to the Site, or to send you additional information about Company.

(b) TRAFFIC DATA. We use traffic data to analyze our Site traffic, but we do not examine this information for individually identifying information. In addition, we may use IP addresses to help diagnose problems with our server, to administer the Site, or to display the content according to your preferences. Traffic and transaction information may also be shared with business partners and advertisers on an aggregate basis.

(c) USE OF COOKIES. We may use cookies and other tracking technologies to deliver content specific to your interests, to save your password so you don’t have to re-enter it each time you visit our Site, or for other purposes. Promotions or advertisements displayed on our Site may contain cookies. We do not have access to or control over information collected by outside advertisers on our site.

(d) DISCLOSURE OF PERSONAL INFORMATION. We may disclose personal information that you provide via the Site to the following third parties:

   Joint venture or marketing partners who may want to send you information about their products or services, unless you have specifically requested that we not share your information for this purpose; and

   Contractors, vendors, and service providers we use to support our business and the Site. These support partners have all agreed to uphold the same standards of security and confidentiality that we provide to you under this Policy, and they have agreed to only use your information to carry out their specific business obligations to Company.

We may also disclose personal information that you provide via the Site in the event of a merger, acquisition, or any form of sale of some or all of our assets, in which case personal information we collect via the Site will be among the assets transferred to the buyer. Further, we may disclose your personal information to third parties to

   Comply with any court order or other legal obligation;

   Enforce or apply our terms of use and other agreements; and

   Protect the rights, property, or safety of our business, our clients, customers, employees, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, information security, and other related matters.

4. USER CHOICES REGARDING COLLECTION, USE, AND DISTRIBUTION OF INFORMATION.

4.1 ACCOUNT SETTINGS. We maintain a procedure to help you confirm that your Personal Information remains correct and up-to-date. At any time, you may visit your personal profile at www.innerradio.com. Through your personal profile you may: (a) review and update your Personal Information that we have already collected; (b) choose whether you wish us to send you information about our company or promotional material from some of our partners; and (c) choose whether you wish for us to share your Personal Information with third parties.

4.2. LOST OR STOLEN INFORMATION. You must promptly notify us if your user name or password is lost, stolen, or used without permission. In such an event, we will remove that user name and/or password from your account and update our records accordingly.

4.3 COMMUNICATIONS.

   If you do not wish to receive information and promotional material from us or from some of our partners, you may select the appropriate “opt-out” option each time we ask you for information.

   You can opt-out of e-mails from us by clicking on the unsubscribe link in each message, or e-mailing us with UNSUBSCRIBE in the subject field of the e-mail.

5. FOR RESIDENTS OF CALIFORNIA

5.1 SHINE THE LIGHT.

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, once each calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately preceding calendar year.

To obtain this information, please send an e-mail message to jen@helloinnerradio.com with “Request for California Privacy Information” in the subject line and in the body of your message. We will provide in response the requested information to you at your e-mail address.

Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only required information will be included in our response.

5.2 The California Consumer Privacy Act (“CCPA”) provides additional rights to residents of California regarding our information collection and use practices.

5.2.1 CATEGORIES OF PERSONAL INFORMATION COLLECTED

We identify below the categories of personal information that we have collected about our users in the last 12 months, using the categories provided in the CCPA.

   Identifiers

   Customer Records Information

   Characteristics of protected classifications under California or federal law

   Commercial Information

   Internet or Other Electronic Network Activity Information

   Geolocation Data

   Audio, Visual, Electronic, Thermal, Olfactory, or Similar Information

   Professional or Employment-related Information

   Educational Information

   Inferences

For more detail on the information we collect, including the sources we receive information from, please refer to our Information Collection Practices above. We collect and use these categories of personal information for the business purposes described in the Information Collection Practices section above.

5.2.2 CATEGORIES OF PERSONAL INFORMATION SOLD.  The Company does not sell personal information as defined under the CCPA. 

5.2.3 RIGHTS OF CALIFORNIA RESIDENTS

A. Right to Know

You have the right to know certain details about our data practices in the past 12 months. In particular, you may request the following from us:

   The categories of personal information we have collected about you;

   The categories of sources from which the personal information was collected;

   The categories of personal information about you we disclosed for a business purpose or sold;

   The categories of third parties to whom the personal information was disclosed for a business purpose or sold;

   The business or commercial purpose for collecting or selling the personal information; and

   The specific pieces of personal information we have collected about you.

To exercise the Right to Know, please submit a request through our Online Form or email us at jen@helloinnerradio.com.  In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know.

B. Right to Delete

You have the right to request that we delete the personal information we have collected from you in the last 12 months. To exercise the Right to Delete, please submit a request, please email us as jen@helloinnerradio.com. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request to delete. If we deny your request, we will explain the reason why in our response.

C. Right to Non-discrimination

You have the right not to receive discriminatory treatment by us for exercising any of your rights.

D. Authorized Agent

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

6. SECURITY

The Site has security measures in place to prevent the loss, misuse, and alteration of the information that we obtain from you, but we make no assurances about our ability to prevent any such loss, misuse, to you or to any third party arising out of any such loss, misuse, or alteration.

7. PUBLIC WEBSITE AREAS AND ACCESS TO OTHER WEBSITES

7.1. PUBLIC FORUMS

The Site may include interactive forums such as message boards and chat rooms. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information.

7.2. OTHER WEBSITES

The Site may contain links to other websites. If you choose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their policies.

8. CONTACT INFORMATION AND POLICY UPDATES

8.1. CONTACTING US

If you have any questions about this Policy, our practices related to this Site, or if you would like to have us remove your information from our database, please feel contact us at the following jen@helloinnerradio.com.

8.2. UPDATES AND CHANGES

We reserve the right, at any time, to add to, change, update, or modify this Policy, simply by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Site. It is your responsibility to review this Policy from time to time to ensure that you continue to agree with all of its terms.