Effective Date: January 22, 2024
LAST UPDATED January 22, 2024
Guide to Contents:
Townsquare Media Inc., together with its subsidiaries and affiliates (collectively, "Company" "us," "we," or "our") is committed to protecting the privacy of Personal Data (i.e., information reasonably related to a specific individual). This Privacy Notice describes how we process Personal Data collected through our websites, social media accounts, mobile applications, and other online interactions and communications such as email (collectively, our “Digital Properties”); in-person events and purchases; and other online and offline interactions.
This Privacy Notice applies to information we collect about individual consumers, such as general website visitors (“Individuals”) as well as information we collect about the personnel of our business partners, including vendors and business customers, in business-to-business interactions (“Business Contacts”). However, this Privacy Notice does not apply to information about our current/former employees, applicants, and other individuals who interact with us for employment-related purposes. This Privacy Notice also does not apply to data that we handle on behalf of and under the instructions of our business customers. Whenever you interact with us on behalf of another individual or entity, such as if you refer a friend to us, you must obtain their consent (or have the legal authority without consent) to share their Personal Data with us.
Changes: We may update this Privacy Notice from time to time. Any updated Privacy Notice will be effective when posted. Please check this Privacy Notice periodically for updates.
1. Sources of Personal Data
We collect Personal Data about you from the following sources:
Directly from you. We may collect Personal Data you provide to us directly, such as when you contact us through our Digital Properties; register for an event; interact with us in person; sign up for offers or newsletters; communicate with us; place orders; enter sweepstakes; complete surveys; apply for a job; or sign up for an account or other services.
Data collected automatically and through tracking technologies. We may automatically collect 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, such as service and content providers, our affiliated companies and subsidiaries, business partners, data brokers, social media companies, or other parties who interact with us.
From publicly available sources. We may collect Personal Data about you from publicly available sources, such as public profiles and websites.
We may combine information that we receive from the various sources described in this Privacy Notice, including third party sources, and use or disclose the combined information for the purposes identified below.
2. Types of Personal Data We Collect
We may collect the following types of Personal Data. Except as otherwise specified, we may collect this Personal Data from both Individuals and Business Contacts.
Identifiers, such as your name; email address; physical address; telephone number; contact information; account information; and device identifiers (including cookie IDs and IP address).
Records about you, such as user-generated content (including posts on forums); preference information (including marketing preferences); account settings; the content, timing and method of communications you have with us (including calls and emails); and signatures.
Demographic information, such as age (including birthdates) and gender.
Commercial information, such as information related to your transactions; products or services purchased, obtained, or considered; subscription information; or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information, such as your browsing history; search history; and other information regarding your interactions with and use of the Digital Properties. For more information about cookies and other device data, please see Section 5 (Cookies and Other Tracking Technologies).
Non-precise geolocation data, such as your approximate location based on your IP address.
Audio, electronic, visual, or other sensory information, such as photographs (including ones taken at events or uploaded to our Digital Properties); call recordings; 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 any of the information we collect about your preferences or behavior, including to assess the level of interest in our products and services based on frequency of visits and contact and determine your preferred frequency for receiving offers.
- Sensitive Personal Data, including the following:
- Account log-in information.
- Precise geolocation.
3. How We Use Personal Data
We may use Personal Data for the following purposes:
To provide you or your company products and services, such as making our Digital Properties and other products and services available to you; providing customer service; processing or fulfilling orders and transactions (including processing payments); verifying customer information and eligibility for certain programs or benefits; communicating with you (including soliciting feedback or responding to requests, complaints, and inquiries); and providing similar services or otherwise facilitating your relationship with us.
For our internal business purposes, such as day-to-day operation of our business; maintaining internal business records; enforcing our policies and rules; management reporting; auditing; and IT security and administration.
For our internal research and product improvement purposes, such as verifying or maintaining the quality or safety of our products or services; improving our products or services, including the Digital Properties; designing new products and services; evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against us, our personnel, and our customers; for the establishment, exercise or defense of legal claims; protecting our, your, our customers', and other third parties' safety, property or rights; detecting, preventing, and responding to security incidents and health and safety issues (including managing spread of communicable diseases); and protecting against malicious, deceptive, fraudulent, or illegal activity.
In connection with a corporate transaction, such as if we acquire assets of another entity, or sell or transfer all or a portion of our business or assets, including through a sale in connection with bankruptcy and other forms of corporate change.
For marketing and targeted advertising, such as marketing our products or services or those of our affiliates, business partners, or other third parties. For example, we may use Personal Data we collect to personalize advertising (including by developing product, brand, or services audiences and identifying you across devices/sites); to analyze interactions with us, including our Digital Properties; to hold sweepstakes, giveaways, and contests; and to send you newsletters, surveys, questionnaires, promotions, or information about events.
We may use anonymized, de-identified, or aggregated information for any purpose 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 and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.
Service providers that work on our behalf to provide the products and services you request or support our relationship with you, such as IT providers, internet service providers, web hosting providers, data analytics providers, and companies that provide business support services, financial administration, or event organization.
Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.
Vendors necessary to complete 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 law or legal requirements; to enforce or apply our terms, agreements or policies; and to protect our, your, our customers', or other third parties' safety, property, or rights.
Other entities in connection with a corporate transaction, such as if we acquire assets of another entity, or sell or transfer all or a portion of our business or assets, including through a sale in connection with bankruptcy and other forms of corporate change.
- Business partners that 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 own marketing purposes; and
- Partners who work with us on promotional or sponsorship opportunities, including sweepstakes and co-branded products and services.
Where recipients use your Personal Data for their own purposes independently from us, we are not responsible for their privacy practices or personal data processing policies. You should consult the privacy notices of those third-party services for details on their practices.
The public, such as when you have an opportunity to make comments regarding us or our products or services that we may share with the public, including comments on our blog posts and posts on our forums. Any Personal Data in comments, reviews, or other content that you share in public areas of our Digital Properties may be read, collected, or used by other users or the public.
- Entities to which you have consented to the disclosure.
We may disclose anonymized, de-identified, or aggregated information for any purpose permitted by law.
5. Cookies and Other Tracking Technologies
- 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, which are a type of technology that install a small amount of information on a user's computer or other device when they visit a website. Some cookies exist only during a single session and some are persistent over multiple sessions over time.
- Pixels, web beacons, and tags, which are types of code or transparent graphics. In addition to the uses described below, these technologies provide analytical information about the user experience and help us customize our marketing activities. In contrast to cookies, which are stored on a user's computer hard drive, pixels, web beacons, and tags are embedded invisibly on web pages.
- Session replay tools, which record your interactions with our Digital Properties, such as how you move throughout our Digital Properties and engage with our webforms. In addition to the uses described below, this information helps us improve our Digital Properties and identify and fix technical issues visitors may be having with our Digital Properties.
- 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, such as remembering language preferences and pages and products you have viewed in order to enhance and personalize your experience when you visit our Digital Properties;
- Improvement, such as maintaining and improving the performance of our Digital Properties and improving the user experience;
- Advertising, such as conducting advertising and content personalization on our Digital Properties and those of third parties; tracking activity over time and across properties to develop a profile of your interests and advertise to you based on those interests (“interest-based advertising”); providing you with offers and online content that may be of interest to you; optimizing advertising campaigns; and measuring the effectiveness of advertising campaigns and our communications with you, including identifying how and when you engage with one of our emails; and
- Security, such as preventing fraud and malicious behavior.
- Information Collected
These tracking technologies collect data about you and your device, such as your IP address, name of your Internet service provider, device type, location (both approximate and precise), cookie ID, device ID, ad ID, operating system, browser used, referring domain, browsing history, search history, and information about how you interact with our Digital Properties (such as pages on our Digital Properties that you have viewed).
- Disclosures of your information
We may disclose information to third parties or allow third parties to directly collect information using these technologies on our Digital Properties, such as social media companies, advertising networks, companies that provide analytics including ad tracking and reporting, security providers, and others that help us operate our business and Digital Properties.
6. Your choices
- Marketing emails
You can unsubscribe to our email marketing via the link in the email or by managing your preferences here: https://www.townsquaremedia.com/privacy-preferences. You may continue to receive service-related, legal, and other important communications from us even after you have unsubscribed from email marketing.
- Text messages
When you have provided authorization, we may deliver SMS text messages, push notifications, and voice message notifications, including promotional messages. You are not required to receive such messages as a condition of purchasing any goods or services from us, and you may choose not to receive text messages from us by not providing us your cell phone number. Please note that standard message rates and data charges from your cellular service provider apply to sending and/or receiving text messages. You are solely responsible for such message rates and data charges.
- Cookies and tracking technologies
Some of the third parties we work with participate with the Digital Advertising Alliance ("DAA") and Network Advertising Initiative ("NAI"). The DAA and NAI provide mechanisms for you to opt out of interest-based advertising performed by participating members at https://www.aboutads.info/choices/ and https://optout.networkadvertising.org/. We adhere to the DAA's Self-Regulatory Principles for Online Behavioral Advertising. You may also click on the AboutAds icon on a Company advertisement and follow the instructions on how to opt out.
You can also refuse or delete cookies using your browser settings. If you refuse or delete cookies, some of our Digital Properties' functionality may be impaired. Please refer to your browser's Help instructions to learn more about how to manage cookies and the use of other tracking technologies. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from participating parties.
Some browsers have incorporated Do Not Track (“DNT”) preferences. At this time, we do not honor Do Not Track signals.
7. Data Security and Data Retention
Although we maintain reasonable security safeguards, no security measures or communications over the Internet can be 100% secure, and we cannot guarantee the security of your information.
Your Personal Data will be retained as long as necessary to fulfill the purposes we have outlined 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 and interact with you; complete your transaction; maintain our business relationship with you; improve our business over time; ensure the ongoing legality, safety and security of our services and relationships; or otherwise in accordance with our internal retention procedures. Once you have terminated your relationship with us, we may retain your Personal Data in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as to enable easier future onboarding, demonstrate our business practices and contractual obligations, or provide you with information about our products and services in case of interest.
8. Children's Privacy
Our Digital Properties are intended for individuals 18 years of age and older. The Digital Properties are not directed at, marketed to, nor intended for, children under 18 years of age. As a general rule, we do not knowingly collect any information, including Personal Data, from children under 18 years of age. If you believe that we have inadvertently collected Personal Data from a child under the age of 18, please contact us at the address in Section 10 (Contact Information) below, and we will take prompt steps to delete the information.
9. External Links
Our Digital Properties may contain links to external sites or other online services that we do not control, including those embedded in third party advertisements or sponsor information. We are not responsible for the privacy practices or data collection policies of such third-party services. You should consult the privacy notices of those third-party services for details on their practices
10. Contact Information
If you have questions regarding this Privacy Notice, please contact us at:
Townsquare Media, Inc.
1 Manhattanville Rd, Suite 202,
Purchase, NY 10577
Phone: (203) 861-0900
11. Supplemental Information for Residents of California, Colorado, and Other U.S. States Data Subject Rights
- Data Subject Rights
Depending on our relationship with you (i.e., whether you are an Individual or a Business Contact), and in which state you reside within the United States, you may have certain rights regarding Personal Data:
- Right to Know. You may have the right to request information about the categories of Personal Data we have collected about you, the categories of sources from which we collected the Personal Data, the purposes for collecting, selling, or sharing the Personal Data, and to whom we have disclosed your Personal Data and why. You may also request the specific pieces of Personal Data we have collected about you.
- Right to Delete. You may have the right to request that we delete Personal Data that we have collected from you.
- Right to Correct. You may have the right to request that we correct inaccurate Personal Data that we maintain about you.
- Right to Opt Out of Sales and Sharing for Targeted Advertising. You may have the right to opt out of the sale or sharing of your Personal Data for targeted advertising.
You may exercise the Right to Know, Right to Delete, or Right to Correct via our webform or by calling us at 1-833-643-0467.
You may exercise the Right to Opt Out of Sales and Sharing for Targeted Advertising via the Consent Management Platform ("CMP") (click here). When you disable Sales and Sharing for Targeted Advertising, the CMP will place a token signaling that you have opted out of such online activities. Please Note:
- You may need to disable “Sale/Sharing” in the CMP from each browser you use.
- If you delete the token, you will need to disable “Sale/Sharing” in the CMP from that browser again.
- If you have blocked such technologies, we will be unable to fully comply with your request.
We will not discriminate against you for exercising your privacy rights.
Verification: In order to process rights requests, we may need to obtain information to locate you in our records or verify your identity depending on the nature of the request. In most cases we will collect some or all of the following data elements: first and last name, email address, and telephone number. In some cases, we may request different or additional information, including a signed declaration that you are who you say you are. We will inform you if we need such information.
Authorized Agents: Authorized agents may exercise rights on behalf of you by submitting a request by visiting our webform and indicating that they are submitting the request as an agent. We may require the agent to demonstrate authority to act on behalf of you by providing signed permission from you. We may also require you to verify your own identity directly with us or to directly confirm with us that you provided the authorized agent permission to submit the request.
Appeal: If we deny your rights request, you may have the right to appeal. To submit an appeal, contact us at firstname.lastname@example.org. We will inform you in writing our response to your appeal.
Additional California Rights: If you are a California resident, you may opt out of the sharing of your Personal Data subject to California Civil Code §1798.83 (the “Shine the Light law”) with third parties for those third parties' direct marketing purposes by contacting us at email@example.com.
Nevada residents: You may contact us at firstname.lastname@example.org to inquire about your right to opt out of the sale of your Personal Data.
- Additional Data Processing Disclosures for California Residents
Although we have not “sold” Personal Data for money in the past 12 months, we engage in routine practices with our Digital Properties involving third parties that could be considered a “sale” or “sharing” (i.e., for targeted advertising). We do not knowingly sell or share any Personal Data of minors under the age of 16.
We only use and disclose Sensitive Personal Data for the following purposes:
- performing services or providing goods reasonably expected by an average person;
- detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions;
- ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising;
- performing or providing internal business services;
- verifying or maintaining the quality or safety of a service or device; or
- for purposes that do not infer characteristics about you.
Below please find a chart detailing the categories of Personal Data we collected and with whom it was sold, shared, or disclosed for a business purpose in the past 12 months.
|Categories of Personal Data We Collect
|Categories of Third Parties With Whom We Disclose Personal Data for a Business Purpose
|Categories of Third Parties to Whom Personal Data is Sold/Shared for Targeted Advertising
|Identifiers (Section 2.A)
Records about you (Section 2.B)
Demographic information (Section 2.C)
Commercial information (Section 2.D)
Internet or other electronic network activity (Section 2.E)
Geolocation data (Section 2.F)
Audio, electronic, visual, or other sensory information (Section 2.G)
Professional or employment-related information (Section 2.H)
Education information (Section 2.I)
Inferences (Section 2.J)
Sensitive personal information (Section 2.K)