PRIVACY POLICY - COMMITMENT TO YOUR PRIVACY

The Effective Date of this Privacy Policy is June 5, 2023.  This version replaces and supersedes any prior privacy policies applicable to this website. 

SUMMARY AND CONTACT INFORMATION

We at UNITED RADIO INCORPORATED dba BLUESTAR (referred to as “Company,” “we,” “our,” or “us”) recognize the importance of protecting the privacy of personally identifiable information (“PII”) collected about our customers, prospective customers, and end users (referred to as “Customers,” “Users,” “you” or “your”). We are committed to ensuring that your privacy is protected. It is our intention to give you as much control as possible over your privacy in regard to your PII and the use we make of it in the course of your use of our website, located at http://www.bluestarinc.com/us-en/home.html, its subdomains, and all other internet properties owned or operated by us (collectively referred to as “Website” or our “Site”), and the Company products and services offered through our Site. This Privacy Policy describes how we handle information we learn about you from our Site and in connection with our services. Unless otherwise expressly agreed to in writing, your PII will be processed according to the terms of this Policy. By using our Site, you accept the terms of this Privacy Policy. If you have questions about this Privacy Policy or wish to contact us, we can be reached via any of the following:

Legal Department

3345 Point Pleasant Road

Hebron KY 41048, USA

Phone: (800) 354-9776 ext. 3395

Email: legal(at)bluestarinc.com

COLLECTION AND USE OF INFORMATION

Company is the sole owner of the information collected on our Site.  The information we collect depends on what you do when you visit or utilize the Site.

Information We Collect

Personal Information (PII)

We collect PII from Users in a number of different ways including, but not limited to, when Users visit our site, register on the site, fill out a form, and in connection with other activities, services, features or resources we make available on our Site. PII means any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. PII does not include publicly available information from government records, deidentified or aggregate information, or information excluded from the scope of relevant privacy laws. The PII we collect depends on what you do when you visit or utilize the Site or how you choose to communicate with us.   

In the preceding twelve (12) months, we have collected, used, stored or transferred different categories of PII about consumers, which we have grouped together as follows:

·      Identifiers includes first name, maiden name, last name, profile picture, username or similar identifier, IP address, postal address, and email address.

·      PII Listed in the CA Consumer Customer Records Law includes name, address, phone number, employment, credit or debit card number, or other financial information.

·      Characteristics of Protected Classifications under CA or Federal Law includes age, gender, and marital status.

·      Commercial Information includes products or services purchased or obtained from us, and other purchasing and consuming histories and tendencies.

·      Internet or Other Electronic Network Activity Information includes browsing history, search history, and information regarding your interaction with our Site and advertisements.

·      Geolocation Data includes IP addresses, geolocation, beacon based location, and GPS location. You may disable our use of certain location data through your device or browser settings, for example, by disabling “Location Services” for any applicable application in iOS privacy settings.

·      User-Generated Content includes comments or messages provided in free text boxes.

·      Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

Please note that we do not collect PII about you unless you choose to provide such PII to us or our resellers by creating an account, purchasing or using our services, and/or contacting us regarding the Site or our products and services.  If at any time you or our resellers do provide us with such PII, we will collect it. However, note that we do not collect Sensitive PII about you, as that term is defined by relevant data privacy laws.

Analytical Information and Anonymized Data

For each User, we may also automatically gather certain information and store it in log files.  This information includes the following: web beacons, embedded web links, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

We may collect and store this information on an individual basis and in aggregate, or combined, form.  We may also collect both User-specific and aggregate information on what pages Users access or visit.  We use this information to analyze trends, to administer the Site, to track Users’ movements around the Site, and to gather demographic information about our user base as a whole.  We also use this information to improve the content of our web pages, and to customize the content and layout of our pages.  All of this is done with the intention of making our Site more useful to Users.

We may use one or more third-party tracking services to track anonymized and/or non-personally identifiable information in the aggregate about Users.  These third-party services may use JavaScript, pixels, transparent GIF files, and other means to enable us to learn which advertisements bring Users to our Site.  Any information we track in this manner is anonymous, limited to usage and volume statistics, and is used to provide insight into the effectiveness of our online marketing initiatives and strategies.  We also reserve the right to provide anonymized data to third parties for the purpose of evaluating the performance of the Company products or services, or as part of a sales transaction. We will take reasonable measures to ensure that anonymized and/or non-personally identifiable information we collect is not personally identifiable and may not later be easily used to identify you as required by applicable law.

Except as described in this Privacy Policy, we do not divulge any information about an individual User to a third party unless it is in connection with Company products or services.

How We Collect Information

Directly From You: We collect most of this PII directly from you when you voluntarily submit it to us while completing forms on our Site and in connection with other activities, services, features, or resources we make available on our Site. The PII we collect depends on what you do when you visit or utilize our Site or how you choose to communicate with us.

Through Your Use of the Site/Cookies: We collect PII and other information that your browser automatically transmits when you visit our Site. We also use automated tracking technologies, such as cookies and web beacons, to collect information about how you access and interact with our Site.

A cookie is a small text file that is stored on a User’s computer for record-keeping purposes.  We use both session cookies and persistent cookies on the Site.  We may link the information we store in cookies to your PII in order to provide a faster and more pleasant online experience.  You can refuse cookies by turning them off in your browser. You do not need to have cookies turned on to use the Site.  If you reject cookies, you may still visit our Site, but your ability to use some areas of the Site will be limited.

We use session cookies to make it easier for you to navigate the Site.  In particular, we use session cookies to record session information, such as which web pages a User has visited, and to track User activity on the Site.  We also use session cookies to store any passwords used on the Site (such as a password associated with a User account), so you do not have to enter it more than once per session.  Session cookies expire when you close your browser.

We use persistent cookies to track and target the interests of our Users to enhance the experience on our Site.  Persistent cookies remain on your device for an extended period of time.  You can remove persistent cookies by following directions provided in your browser’s “help” file.

From Third Parties: We collect PII and other information through third parties who provide us services, partner with us, or otherwise act or collect information on our behalf. These parties include, for example, payment processing partners, data analytics providers, internet service providers, advertising networks, and resellers of our products.

Use of PII by Company 

We collect, use, and share PII for our business purposes: (i) as necessary for the performance of our contract with Users, (ii) for our legitimate interests, so long as they are not overridden by Users’ own rights and interests, or (iii) as required by law. These purposes include:

Delivery of our Services: Generally, we use your PII in connection with the purpose for which you provided it (e.g., to contact you with a response to a request for information, to provide products or services, and/or to contribute to customer surveys).  We will communicate with you by email, telephone, or social media, in accordance with your wishes.

Advertising & Marketing: We may also use your PII to provide advertising and marketing services to you, including targeted advertising. We may send you information on products, services, and special offers and promotions in which you might have an interest. From time to time, we may also use your information to contact you for market research purposes. The means by which Company will use to contact you with this information will depend on the type of PII you have provided.  For example, if you provide us with your email address, you may receive periodic promotional emails from us. If you do not wish to receive special offers and other promotional information from us, you may opt out of receiving such communications at any time, as discussed below.

Short-Term, Transient Purposes: We may make short-term, transient use of your PII or other information, such as non-personalized advertising shown as part of your then-current interaction with us.

User Experience Personalization: We may use your PII in the aggregate to analyze Users’ browsing and usage activities and patterns in order to understand Users’ interests and preferences with respect to the Site and our services. This may include using your PII or information for auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with relevant data privacy standards.

Business Optimization & Analysis: We may use your PII to improve the content on our web pages, to customize the content and layout of our web pages, and in managing our everyday business needs. We may also use your feedback to conduct business analysis, such as analytics, projections, or identifying areas for operational improvement in order to improve the Site and our services. All of this is done with the intention of making the Site more useful for you.

Safety and Security: We may use your PII to promote the safety and security of the Site, our users, and other parties. For example, we may use the information to authenticate Users, facilitate secure payments, protect against fraud and abuse, respond to a legal request or claim, conduct audits, comply with our legal and regulatory obligations, and enforce our terms and policies.

We will not collect additional categories of PII or use PII we collected for materially different, unrelated, or incompatible purposes without providing you notice and, when required, gathering your consent.

Disclosing and Sharing Your PII

We may share any collected information, including PII, to a third party for our business purposes as described below. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the PII confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed PII for a business purpose to the categories of third parties indicated in the respective chart below.

We may also share or sell certain collected information, including PII, with certain third parties to make our Site function properly and to deliver relevant personalized ads to you on and off our Site. Some of these disclosures may constitute the “sharing” or sale of PII under certain U.S. state privacy laws, as indicated in the respective chart below, and subject to certain opt-out rights. We do not knowingly “share” or sell the PII from children under the age of 16 for targeted advertising purposes.

In the preceding twelve (12) months, we may have disclosed, “shared,” or sold PII to the following parties, subject to the charts below:

Our Affiliates and Partners including companies within the United Radio Incorporated group. We may jointly offer, together with our business partners, certain promotional materials available upon request. If you request such materials from us, we may share or sell the contact information you provide when accessing those materials to our trusted business partners so that they may contact you with promotional information about services related to the requested materials that we believe may be of interest to you.

Our Service Providers and Contractors that help us deliver our services and products to you, such as payment service providers, upstream vendor and manufacturer partners, and delivery companies in connection with sales reporting and related purposes.

Internet Cookie Data Recipients such as Google Analytics that analyze information regarding visits to our Site. To learn more about Google’s privacy practices, click here. To access and use the Google Analytics Opt-out Browser Add-on, click here.

Advertising Publishers and Data Analytics Providers that place advertisements on our behalf or provide statistical and analytic information regarding the effectiveness of our marketing, such as Google, LinkedIn, Meta, Twitter, and Hubspot. If you have not opted-out, we allow these third-party companies to use device identifiers or cookies to collect certain information when you visit our Site which is then used to serve ads for our products or services when you visit our Site or other websites. These parties use non-identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, hardware/software information, cookie and session ID) and limited PII (e.g., static IP address) during your visits to our Site in order to provide advertisements about our goods and services likely to be of greater interest to you.

Other Third Parties we use to help us run our business, such as website hosts and marketing agencies, or sponsors or partners that you have specifically requested to received additional information from through our Site.

For Law Enforcement, Safety, and Legal Processes we may also disclose any collected information, including PII, if: (1) the disclosure is necessary or useful to our provision of services; (2) we believe in good faith that disclosure is necessary to protect our rights, interests, or property; (3) we are acting in good faith to protect your safety or the safety of others, to investigate fraud, or to respond to a government request; (4) we believe in good faith the disclosure is required by law, such as to comply with a subpoena, search warrant, court order, or similar legal or administrative process; and (5) a third party purchases or otherwise acquires us or the Site, in which case your information will likely be among the assets transferred.

Categories of PII Disclosed for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of PII to third parties for a lawful business purpose:

Categories of PII Sold or “Shared”

In the preceding twelve (12) months, we may have sold or “shared” the following categories of PII to third parties for the purpose of providing personalized advertisements or other requested promotional materials to you:

INFORMATION ACCESS

Upon request we provide Site Users with access to their own contact PII (e.g., name, address, e-mail address, phone number) that we maintain about them.  You can access this PII by sending your request to: Manager, Customer Relations and Ombudsman 3345 Point Pleasant Road, Hebron KY 41048, USA or by emailing legal(at)bluestarinc.com. To help us process your request, please provide sufficient information to allow us to identify you in our records. 

We reserve the right to ask for information verifying your identity prior to disclosing any information to you.  Should we ask for verification, the information you provide to verify your identify will be used only for that purpose, and all copies of this information in our possession will be destroyed when the process is complete.

We also offer Users the opportunity to have inaccuracies corrected in all information we maintain about them.  To begin the process, send your request to Legal Department, 3345 Point Pleasant Road, Hebron KY 41048, USA or legal(at)bluestarinc.com.  Please provide sufficient information to allow us to identify you in our records and help us process your request.

YOUR ABILITY TO CONTROL YOUR PII

If you do not wish to receive promotional emails from us, please let us know by using the opt-out response device that can be found at the bottom of every email we deliver or by emailing us at legal(at)bluestarinc.com. To help us process your request, please include sufficient information for us to identify you in our records (your email address will suffice).  Please allow a reasonable time for us to process your request.

If you do not wish for us to share your PII with any third parties working on our behalf to serve our Customers, please let us know by sending your request to legal(at)bluestarinc.com. To help us process your request, please provide sufficient information to allow us to identify you in our records.  Please allow a reasonable time for us to process your request. Please note that exercising these opt-out rights may limit your ability to receive the full range of Company’s products and services.

Please note that, although you can opt not to receive promotional messages, we reserve the right to send you informational email messages about any administrative notices regarding the Site, as permitted under the CAN-SPAM Act (15 U.S.C. §7701 et seq.). 

You can also set your browser to refuse all or some browser cookies, or to alert you when cookies or device identifiers are being sent. If you disable or refuse cookies or device identifiers, please note that some parts of this site may then be inaccessible or not function properly. To learn more about opting-out of Google’s use of cookies or device identifiers, you can visit your Google Ad Settings here. You can also adjust your preferences using your device’s settings.

We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

If you are a resident of certain jurisdictions, you may also have the right to opt-out of any current or future “sharing” of your PII for personalized advertising purposes. To exercise this right, please use the Verified Consumer Request method described below. 

SECURITY

The security of your PII is important to us.  We follow generally accepted industry standards and have put in place suitable physical, electronic, and administrative procedures to protect the PII submitted to us, both during transmission and once we receive it, and to guard that PII against loss, misuse or alteration.  When you enter sensitive information and/or PII on our registration or order forms, we encrypt that PII using secure socket layer technology (SSL).

Please note, however, that no method of transmission over the internet, or method of electronic storage, is 100% secure.  Therefore, while we use commercially-reasonable means to protect your PII, we cannot guarantee its absolute security.

CHILDREN

Company does not offer its services or promote its Site to, nor does it intentionally collect or retain PII from, children who are younger than 18 years of age.  Site Users are cautioned, however, that the collection of PII submitted in an e-mail or through the Site will be treated as though it was submitted by an adult, and may, unless exempted from access by Federal or State law, be subject to public access.  If you believe your child may have submitted PII to Company without indicating their actual age and would like it removed, please contact us at legal(at)bluestarinc.com and we will delete it immediately. 

RETENTION

We will retain Users’ PII while they maintain an account with us or to the extent necessary to provide the services through the Site. Thereafter, we will keep PII for as long as reasonably necessary: (i) to respond to any queries from Users; (ii) to demonstrate we treated Users fairly; (iii) for ordinary business continuity procedures; or (iv) to comply with any applicable laws. We delete PII within a reasonable period after we no longer need the information for the purposes set out in this Privacy Policy.

CALIFORNIA PRIVACY RIGHTS

California Residents

If you are a California resident, the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), grants you certain data privacy rights. Your rights include the:

• Right to Access: You have the right to request a copy of the specific pieces of PII that we have collected about you in the previous twelve (12) months. The information will be delivered by mail or electronically. Upon receipt of a Verifiable Consumer Request, we will disclose:
• The categories of PII we have collected about you;
• The categories of sources from which PII is collected;
• Our business purpose for collecting PII;
• The categories of third parties with whom we share PII, if any; and
• The specific pieces of PII we have collected about you.

• Right to Data Portability: You have the right to receive your PII in a portable, readily usable format that allows you to transmit your information to another entity without hindrance.

• Right to Correct Inaccurate Information: You have the right to request that we correct inaccurate information about you that we maintain.

·      Right to Deletion: You have the right request that we delete your PII. To exercise this right via email, simply type the words “Personal Data Deletion” in the subject line of your email.

• Right to Be Free from Discrimination: You have the right to not be discriminated against by us for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:
• Deny goods or services to you;
• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Provide a different level or quality of goods or services to you; or
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

• Right to Opt-Out: If you are age 16 or older, you have the right to opt-out of the sale or sharing of your PII to third parties for purposes of personalized advertising at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing us at legal(at)bluestarinc.com with the subject line “Opt Out of the Sale of Personal Information” or by visiting the following link:

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sale or sharing. However, you may change your mind and opt back in at any time.

Please be aware that your rights (including those enumerated elsewhere in this Privacy Policy) are limited to the extent permitted by applicable law. To exercise any other rights set forth in this Section, please submit a Verifiable Consumer Request to us by emailing us at legal(at)bluestarinc.com or by calling us at (800) 354-9776 ext. 3395.

Only you, or someone legally authorized to act on your behalf, may make a Verifiable Consumer Request related to your PII. Making a Verifiable Consumer Request does not require you to create an account with us. You may only make a Verifiable Consumer Request for access to PII twice in a 12-month period.

The Verifiable Consumer Request must:

·      Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and

·      Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We reserve the right to ask for information verifying your identity and residency prior to disclosing any information to you or acting on your request.  Should we ask for verification, the information you provide to verify your identity and residency will be used only for that purpose, and all copies of this information in our possession will be destroyed when the process is complete. We will acknowledge receipt of a Verifiable Consumer Request within ten (10) days. We strive to respond to your request within 45 days of receiving a verifiable consumer request however, we reserve the right to respond within 90 days when reasonably necessary. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to Verifiable Consumer Requests, unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Under California's “Shine the Light” law, California residents who provide PII in obtaining products or services for personal, family or household use are entitled to request and obtain from us, once per calendar year, information about the Customer PII we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of Customer PII and the names and addresses of those businesses with which we shared Customer PII for the immediately prior calendar year (e.g. requests made in 2020 will receive information regarding 2019 sharing activities). To obtain this information from us, please contact us at the following email address: legal(at)bluestarinc.com and write “Request for California Privacy PII” for the subject of your message. We will send you a reply e–mail within 30 days containing the requested information once we confirm your request. Not all information sharing is covered by the “Shine the Light” requirements and only that information which is covered will be included in our response.

Other State Privacy Rights

Residents of certain other states may have additional personal information rights and choices, including the right to opt-out of the sharing of their PII for purposes of targeted advertising.

If you believe you may have such rights and wish to exercise them, please use the Verifiable Consumer Request method described below. Please be aware that your rights are limited to the extent permitted by applicable law.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request using the Verifiable Consumer Request method described below.

DO NOT TRACK DISCLOSURES

Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. Our Site does not currently respond to these “do-not-track” signals.

INTERNATIONAL TRANSFER

Your information, including PII, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note we transfer your information, including PII, to the United States and process it there. Your submission of information to us represents your consent to that transfer. Please note the EU has not adopted an adequacy decision with respect to data transfers to the United States, nor are we a participant in the EU-US Privacy Shield; however, we value your privacy and protect your data using reasonable information security practices.

THIRD PARTY SITES

This Privacy Policy applies only to information collected by Company through internal channels controlled by Company such us our Site.

From time to time, the Site may link you to other sites or applications (“Linked Sites”) that are not owned by Company.  We do not control the collection or use of any information, including PII, which occurs during your visit to the Linked Sites.  Further, we make no representations about the privacy policies or practices of the Linked Sites, and Company is not responsible for the privacy practices of these Linked Sites.

Be careful of disclosing any of your PII when leaving our Site.  We encourage you to be aware when you leave our Site and to read the privacy statements of each and every website that collects PII.

SPAM

We do not participate in bulk email solicitations that you have not consented to receiving (i.e., “Spam”).  We do not sell or disclose customer lists or email address lists to unrelated third parties. Except as otherwise provided herein, we do not share PII with any third party advertisers.

QUESTIONS / CONCERNS

If you believe that our Site is not following our stated information policy, you may contact us at the above address.

CONSENT

By using our Site, or by otherwise communicating with us online, you consent to our collection and use of your information by Company. From time to time, we may use your PII for new, unanticipated uses not previously disclosed in our privacy notice.  If our information practices change materially at some time in the future, we will post the policy changes to our Site.  If we have collected PII from you, we will notify you about the changes prior to making use of your PII in new ways and will provide you with a reasonable opportunity to opt out of the new procedures before they are implemented.  We will also honor opt out requests made following implementation of the new procedures, as discussed above.