Privacy Policy
Last modified: February 28, 2021
Introduction
Association for Independents in Radio, Inc. (“AIR,” “Company”, “our,” “we,” “us”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy is part of our Terms of Use available here.
In this Privacy Policy we describe the types of information we may collect from you or that you may provide when you use this website or other Company services, such as mobile versions of this website or mobile applications released by the Company (collectively the “Platform”), and our practices for collecting, using, protecting, and disclosing that information.
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it, as you agree to this Privacy Policy by using the Platform. If you do not agree with our policies and practices, do not use the Platform.
Usage by and Information about Children
The Platform is not intended for children under 18 years of age and you are not allowed to use the Platform or provide information on it if you are under 18 years of age. Further, if we learn we have received personal information from or about a child under 13 without verification of parental consent, we will delete that information immediately. If you believe we might have any information from or about a child under 13, please contact us immediately at soundpath@airmedia.org.
If you are based in the European Economic Area (“EEA”) you may only use the Platform if you are over the age at which you can provide consent to data processing under the laws of your country or if verifiable parental consent for your use of the Platform has been provided to us.
Information We Collect About You
Like most websites, we collect several types of information from and about users of the Platform, and such information may be personal information, including:
- Information required to sign up for a Platform account, such as full name and email address;
- Information that allows us to charge you for services or products requested through the Platform, such as credit card information and billing address when you sign up for a course or purchase services or products through the Platform;
- Information that you post without any prompts from the Company, such as comments and questions on the Platform discussion boards, chat function, and other features that can be viewed by other users;
- Other information that you provide about yourself voluntarily, such as birthday, city of residence, and professional experience, when you to respond to survey questions, course preparation materials, and other requests for such information within the Platform;
- Information that you voluntarily enter or provide to us when asking us for assistance or support, such as telephone number or information about your Platform usage;
- Information that you provide to the Platform for a specific reason or purpose that is explained before you provide it; and
- Information about your internet connection, the equipment you use to access the Platform, and Platform usage details.
How We Collect Information From You
We collect information from you in two ways:
- First, directly from you when you provide it to us, such as entering your information into a questionnaire provided to you on the Platform, commenting on a message board, or purchasing a course.
- Second, automatically as you navigate through the Platform, such as usage details, IP addresses, web browser preferences, and information collected through cookies and other tracking technologies. Although we do not correlate tracking information to individuals, some information collected, such as IP addresses, will be unique.
In some countries, including countries in the EEA, the information referenced in this Privacy Policy may be considered personal information under applicable data protection laws. If you do not want us to collect this information, do not use the Platform.
Do Not Track Settings
We use LearnWorlds to host the Platform and, to the best of our knowledge, LearnWorlds does not currently support recognition of Do Not Track protocol. LearnWorlds has released that it collects and uses aggregated, non-individualized, information collected from users of LearnWorlds websites to analyze trends, administer websites, track users’ movements around websites, and gather demographic information about their userbase. While the Company does not track its customers over time and across third party websites to provide targeted advertising, users should be aware of LearnWorlds’s potential tracking when they use the Platform.
For more information about LearnWorlds’ use of cookies and tracking technologies, view LearnWorlds’ privacy policy here.
For more information about LearnWorlds’ use of cookies and tracking technologies, view LearnWorlds’ privacy policy here.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To develop, provide, and improve the Platform and its services to you.
- To provide you with information, products, or services that you request from us or that you wish to provide to others through the Platform.
- To allow other users to review the information you contribute to the Platform.
- To connect Platform users.
- To post and facilitate courses on the Platform.
- To provide you with notices about your account and/or any boards, messages, chats, or other discussions you may be engaged in on the Platform.
- To collect payment for services you request on the Platform.
- To carry out our obligations and enforce our rights to the Platform and its services.
- To notify you about changes to the Platform or any products or services we offer or provide though it.
- In any other way we may describe when you provide the information.
Sharing and Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide:
We may disclose personal information that we collect or you provide:
- To contractors, service providers, and other third parties we use to support our business, such as Stripe and LearnWorlds.
- To our subsidiaries and affiliates.
- To other users of the Platform to the extent that you include it in a comment, message board post, chat, course, or other area of the Platform that is available to third parties.
- To other users to the extent that information about you is shared by someone else on the Platform.
- To a buyer or other successor if the Company or its assets are sold and user information is part of the Company assets transferred.
- To fulfill the purpose for which you provide it, such as if you include personal information on your user profile so other users can search for you, we will post that information in the manner you entered it.
- For any other purpose disclosed by us when you provide the information.
- To third party contractors in order to analyze Platform performance and user behavior and/or to improve the Platform.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, other Platform users, or others.
User Contributions
The Platform includes areas where users can post, submit, publish, display, sync, upload or transmit to other users (hereinafter, “post”) content, courses, and other materials (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk and, to the extent that you share personal information in these User Contributions, our obligations under this Privacy Policy do not apply to these disclosures. Additionally, we cannot control the actions of other users of the Platform with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Data Retention
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a course you have purchased or to comply with applicable legal, tax, or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
- Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to soundpath@airmedia.org. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a registration, product service experience or other transactions.
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.
Accessing and Correcting Your Information
You can review and change your personal information by logging into the Platform and visiting your account profile page. You may also send us an email at soundpath@airmedia.org to request access to, correct, or delete any personal or other information that you have provided to us or uploaded to the Platform. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect, but otherwise we will do everything we can to provide you with complete control over information you put on the Platform.
If you delete your User Contributions from the Platform, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Platform users.
Transferring Your Information
The Company is a worldwide service. By using the Platform, you authorize us to transfer and store your information outside your home country, including in the United States, for the purposes described in this Privacy Policy. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country. We take additional measures when information is transferred from the EEA. This includes having standard clauses approved by the European Commission in our contracts with parties that receive information outside the EEA. We also rely on European Commission adequacy decisions about certain countries, as applicable, for data transfers to countries outside the EEA.
Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access. For example, access by a user to his or her personal information is available through a password and unique customer ID selected by the user. This information is encrypted through the Platform with Secure Socket Layer technology (SSL) and is also encrypted when it is stored by us to prevent unauthorized parties from viewing such information. Also, we perform regular malware scanning of the Platform and all servers and computers used by us to support the Platform. All Company employees are required to adhere to our security and confidentiality procedures and undergo training related to maintaining the security of user personal information.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of the Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to soundpath@airmedia.org.
EEA Users
You have options under the law in relation to the information and data that we have about you. To exercise any of the options discussed below, please contact us at soundpath@airmedia.org. In particular, you may:
- Access the information we have about you. We’ll will make an effort to share this information with you within a reasonable time.
- Have your information corrected or deleted.
- Object to us processing your information. You can ask us to stop using your information, including when we use your information to send you marketing emails or push notifications. We only send you marketing material if you've agreed to it, but if you'd rather we don't, you can easily unsubscribe at any time by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you, or by emailing us at the email address above.
- Withdraw your consent for us to collect and process your personal information at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- Have the information you provided to us sent to another organization, where we hold this information with your consent or for the performance of a contract with you, where it's technically feasible.
- Report us to a regulator. If you're based in the EEA and think that we haven't complied with data protection laws, you have a right to lodge a complaint with the Data Protection Commission in Ireland or with your local supervisory authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Legal Basis for Processing Personal Information
Our legal basis for collecting and using the personal information described in this Privacy Policy will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you (such as your agreement to our Terms of Use and requests to use our Platform); (ii) where the processing is in our legitimate interests and not overridden by your rights (such as, generally, our business interests in operating the Platform); or (iii) where we have your consent to do so (which we have when you voluntarily enter information into our Platform and agree to our Terms of Use and Privacy Policy).
In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Changes to Our Privacy Policy
We will post any changes we make to our privacy policy on this page and you will be notified of any material changes on the Platform home page.
Organization and Contact Information
The Platform is property of Association for Independents in Radio, Inc.. For general information about the Platform, this Privacy Policy, or anything else, you can contact us at:
Representative: Hannah Eaves, soundpath@airmedia.org
US Data Protection Officer: Ken Ikeda, soundpath@airmedia.org
General Data Protection Regulation (GDPR) - European Representative: Pursuant to Article 27 of the General Data Protection Regulation (GDPR), the Company has appointed the European Data Protection Office (“EDPO”) as its GDPR representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by:
Representative: Hannah Eaves, soundpath@airmedia.org
US Data Protection Officer: Ken Ikeda, soundpath@airmedia.org
General Data Protection Regulation (GDPR) - European Representative: Pursuant to Article 27 of the General Data Protection Regulation (GDPR), the Company has appointed the European Data Protection Office (“EDPO”) as its GDPR representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by:
- Sending an email to privacy@edpo.brussels
- Using EDPO’s online request form at https://www.edpo.brussels/contact
- Writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium