107.1 The Drive WCKC Privacy Policy

107.1 The Drive WCKC Privacy Policy

Updated: October 24, 2016 107.1 The Drive, an Up North Radio LLC radio station, is committed to protecting your privacy. This Privacy Policy describes, among other things, the types of information collected about you when you visit 107.1 The Drive’s Web Site, located at http://www.1071TheDrive.com; how your information may be used and when it may be disclosed; how you can control the use and disclosure of your information; and how your information is protected. 1. Scope of Privacy Policy This Privacy Policy applies to information, including contact information, collected about you by the 107.1The Drive Web Site and Up North Radio LLC. This Privacy Policy does not cover any information collected through any other web site. Please note that 107.1 The Drive’s Web Site may contain links to non-Up North Radio LLC Web Sites. We are not responsible for the privacy practices of those sites, and we recommend that you visit the privacy policies of each web site that you visit. 2. Information Collected Information you provide directly to the 107.1 The Drive Web Site You are not required to provide information about yourself when you visit 107.1 The Drive’s Web Site. 107.1 The Drive’s Web Site may ask you for some or all of the following types of information when you register for certain services, access various content or features, or directly contact the Web Site:

• Contact information, such as name, email address, postal address, phone number, facsimile number, and mobile number;
• User name, password, and password reminder questions and answers;
• Age and date of birth;
• Other demographic information, such as gender, job information, and zip code;
• Information for a public profile, such as your interests and the address of your web site;
• Communications preferences, such as which newsletters you would like to receive;
• Search queries;
• In limited circumstances, payment and identity verification information, such as credit card number, social security number or comparable national identifiers, and driver’s license number where needed for payment or to access a particular service (e.g., contests);
• Contact information about others when you provide information about others or refer a friend to a particular site or service (note: such information is used solely to facilitate the communications requested);
• Information posted in community discussions and other interactive online features;
• Correspondence you send to us; and
• Information collected about you offline (including via facsimile, mail, or in person for sweepstakes entrance forms).

Information we collect automatically on 107.1 The Drive’s Web Site. 107.1 The Drive’s Web Site may collect certain information automatically, including:

• Your browser type and operating system;
• Your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;
• Sites you visited before and after visiting 107.1 The Drive’s Web Site;
• Web pages and advertisements you view and links you click on within 107.1 The Drive’s Web Site;
• Unique identifiers, including mobile device identification numbers, that can identify the physical location of such devices in accordance with applicable law;
• Information collected through cookies, web beacons, and other technologies;
• Information about your interactions with video content, such as the type of content viewed, and information about your interactions with email messages, such as the links clicked on and whether the messages were opened or forwarded;
• Upon request, your bandwidth speed and information about the software programs installed on your computer; and
• Standard server log information.

Information we obtain from other sources. We may collect information about you from other sources, including through interactive applications (such as mobile devices, third-party services, and embedded video players), from co-branded partners, and from commercially available sources (such as data aggregators and public databases). The following are examples of information we may collect from other sources:

• Name, postal address, and telephone number;
• Demographic data, such as age, gender, and income level;
• If you access third-party services (such as Facebook Connect) through 107.1 The Drive’s Web Site, your username and password for those services and other information available about you on those services;
• Your interests and purchase behavior;
• Publicly-observed data, such as activities on blogs, videos, and other online postings; and
• Other navigation data, such as web sites visited and advertisements viewed or clicked on.

Please note that all of the information we collect about you may be combined, including to help us tailor our communications to you and to develop rich online content and services across 107.1 The Drive’s Web Site. 3. Use of Information We only use payment and identity verification information, such as credit card numbers, driver’s license numbers, social security numbers, or comparable national identifiers as necessary for completing a particular transaction or fulfilling a service (e.g., paid subscriptions or awarding prizes to contest winners) or as otherwise required by law. We generally use other information we collect about you to:

• Fulfill your requests for products, services, and information, including to send you electronic newsletters, authorize a purchase, and complete a transaction that you have requested;
• Enable you to participate in features such as surveys, polls, sweepstakes, and message boards;
• Provide you with special offers and promotional materials on behalf of 107.1 The Drive’s Web Site, companies within Up North Radio LLC, and third parties, in accordance with applicable law;
• Analyze the use of 107.1 The Drive’s Web Site and information about visitors to our Web Sites to understand and improve our service offerings;
• Customize the content you see when you visit 107.1 The Drive’s Web Site;
• Develop and provide advertising tailored to your interests, as described in our overview of 107.1 The Drive’s Web Site’s online advertising;
• Prevent potentially prohibited or illegal activities and otherwise in accordance with 107.1 The Drive’s Terms of Use; and
• For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

4. Disclosure of Information 107.1 The Drive is committed to maintaining your trust and we want you to understand when and with whom we may share information collected about you.

• With your consent. You may be asked to consent to have your contact information shared with third-party business partners. For example, 107.1 The Drive’s Web Site sometimes run contests with prizes provided by an advertiser (e.g. a contest with a prize provided by the advertiser).  When entering such a contest you may be asked if the third party may contact you to provide information about their products or serices or to provide you with special promotional opportunities.
• Authorized third-party service providers. We share your information with third-party vendors who help us with specialized services, including customer support, email and text message deployment, business analytics, marketing, and data processing. These third parties are allowed to use your contact information to help us provide our services and not for any other purpose.
• Sweepstakes, contests, or promotions. When you choose to enter a sweepstakes, contest, or other promotion, and in accordance with the terms and conditions of the promotion, your information may be disclosed to sponsors and third parties who help administer the promotion, including in connection with winner selection and prize fulfillment. Your information also may be disclosed as required by law, such as on a winners list. Also, by entering a promotion, you are agreeing to the official rules that govern that promotion, including allowing the sponsors to use your name, voice, and likeness in advertising and marketing associated with the promotion in accordance with applicable law.
• Co-Branded Partners. Co-Branded Partners are third parties with whom a 107.1 The Drive’s Web Site may jointly offer a service or feature. You can tell when you are accessing a service offered by a Co-Branded Partner because the Co-Branded Partner’s name will be featured prominently. You may be asked to provide information about yourself to register for a service offered by a Co-Branded Partner. In doing so, you may be providing your information to both us and the Co-Branded Partner, or we may share your information with the Co-Branded Partner. Please note that the Co-Branded Partner’s privacy policy may apply to its use of your information.
• Business transfers. We may share your information in connection with a substantial corporate transaction, such as the sale of 107.1 The Drive’s Web Site, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
• Legal requirements. We may disclose information about our users, including contact information, to respond to subpoenas, court orders, legal process, and other law enforcement measures, and to comply with other legal obligations, such as FCC requirements.
• Protect our Web Sites and users. We may disclose information to protect and defend the legal rights, interests, and safety of 107.1 The Drive’s Web Site, Up North Radio LLC, and their employees, agents, and contractors (including enforcing our agreements); to protect the safety and security of users of the Web Sites and members of the public; and as otherwise disclosed in our Terms of Use.

Please note that we may share information with advertisers as described in our overview of 107.1 The Drive online advertising. We also may share aggregated or anonymized information with third parties, including to help us develop content and services we hope you will find of interest. This information cannot be used to individually identify you. 5. Your Choices You can choose to enjoy content and features on 107.1 The Drive’s Web Site without directly providing us with any information about you; however, as described above, some information may automatically be collected or may be requested so you can take advantage of certain features and services offered on 107.1 The Drive’s Web Site. You can opt out of receiving commercial email or text messages from 107.1 The Drive’s Web Site or service by following the instructions contained in any such message. Please note that even if you unsubscribe to commercial messages, we still may need to send you communications relating to your use of the 107.1 The Drive’s Web Site, such as service announcements. You have a choice about the display of relevant advertisements by third parties; for more information, visit our overview of third-party online advertising. 6. Access If you choose to share contact information with us, you may have the opportunity to update that information on 107.1 The Drive’s Web Site. You also may update or amend your information by contacting us. If you ask us to shut down your account or delete your information, we will disable your account within a reasonable period of time. Please note that we may need to retain some information about you in order to satisfy our legal and security obligations. For example, some of your information may remain in back-up storage even if you ask us to delete it. In some cases, you may be entitled under local laws to access or object to the processing of information that we hold relating to you. 7. Protection of Information We are committed to protecting your information. We have adopted commercially reasonable technical, administrative, and physical procedures to help protect your information from loss, misuse, and alteration. Please note that no data transmission or storage can be guaranteed to be 100% secure. We want you to feel confident using the 107.1 The Drive’s Web Site but we cannot ensure or warrant the security of any information you transmit to us. Please refer to the U.S. Federal Trade Commission’s web site for information on how to protect yourself from identity theft. 8. Visiting from Outside the United States 107.1 The Drive is headquartered in the United States. Please be aware that information you provide to us or we obtain as a result of your use of 107.1 The Drive’s Web Site may be processed and transferred to the United States and be subject to United States law. The privacy and data protection laws in the United States may not be equivalent to such laws in your country of residence. By using and participating in 107.1 The Drive’s Web Site or providing us with your information, you consent to the collection, transfer, storage, and processing of information to and in the United States. 9. California Visitors Residents of the State of California may request a list of all third parties to which 107.1 The Drive’s Web Site has disclosed certain information during the preceding year for the third parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us.  For all requests, you must put the statement “Your California Privacy Rights” in the subject field of your email and include your name, street address, city, state, and zip code. Please note that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information. 10. Privacy Protections for Children 107.1 The Drive’s Web Site is intended for a general audience and do not knowingly collect or store contact information about children under the age of 13. 107.1 The Drive’s Web Site may ask for a birth date to ensure that it is not collecting information from children under 13 or to identify when additional steps may need to be taken in connection with information collected from children under 18. In those instances where 107.1 The Drive’s Web Site has actual knowledge that it collects information from children, or offers a service directed toward children, it will comply with applicable laws, including the U.S. Children’s Online Privacy Protection Act. To read about our privacy policy for children under the age of 13, please see the Children’s Privacy Policy. 11. User-Generated Content 107.1 The Drive’s Web Site sometimes enables users to submit their own content for contests, blogs, videos, message boards, and other functions. Please remember that any information you disclose becomes public information and exercise caution when deciding to disclose your contact, financial, and other information in a submission. We cannot prevent such information from being used in a manner that may violate this Privacy Policy, the law, or your personal privacy and safety. 12. Changes to This Privacy Policy We may update this Privacy Policy to reflect changes in our practices and service offerings. If we modify our Privacy Policy, we will update the “Updated” Date and such changes will be effective upon posting. If we make any material changes in the way we use your information, we will notify you by sending an email message to the email address you most recently provided to us or by prominently posting a notice of the changes on 107.1 The Drive’s Web Site. 13. Questions If you have questions regarding this Privacy Policy, please contact us and we will endeavor to respond to your request within a reasonable period of time. You may also submit questions or comments using the postal address listed below: Up North Radio LLC 8082 E. M115 Suite B Cadillac, MI 49601 Attn: Legal Department We are committed to working with you to obtain a fair resolution of any privacy concern. Cookies, Web Beacons and Other Technologies Cookies Cookies are small amounts of data that are stored in separate files within your computer’s Internet browser. Cookies are accessed and recorded by the web sites you visit, and by the companies that show advertisements on web sites, so they can recognize the same browser navigating online. 107.1 The Drive’s Web Site uses cookies for the following general purposes:

• To help us recognize your browser as a previous visitor and save and remember any preferences that may have been set while your browser was visiting one of our Web Sites. For example, if you register on 107.1 The Drive’s Web Site, the Web Site may save your password so you do not have to re-enter it each time you visit.

• To help us customize the content and advertisements you are shown while visiting 107.1 The Drive’s Web Site and potentially other web sites online. Please read about our online advertising to learn more about our efforts to show you relevant advertising.
• To help measure and research the effectiveness of our interactive online content, features, advertisements, and other communications.

107.1 The Drive’s Web Site may also allow third parties to place their own cookies within your browser in order to serve you with relevant advertising online. Please note that we do not share contact information with these third parties and 107.1 The Drive can only access cookies that we set on your browser, not the cookies sent to you by other companies. For more information about the use of cookies by third parties for advertising purposes, please read about third-party online advertising on Up North Radio LLC Web Sites. You have the choice to set your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. (Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.) It is up to you whether to allow us or third parties to send you cookies, but if you block cookies, you may not be able to view or access some or all of 107.1 The Drive’s Web Site. Web Beacons and Other Technologies We may use standard Internet technology, such as web beacons and similar technologies, to track your use of 107.1 The Drive’s Web Site. Web beacons (sometimes called transparent GIFs, clear GIFs, or web bugs) are small strings of code that provide a way for us to deliver a small graphic image (usually invisible) on a web page or in an email. Web beacons can recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed. We use web beacons to improve your experience on our Web Sites, including to provide you with content customized to your interests and to understand whether users read email messages and click on links contained within those messages so that we can deliver relevant content and offers. Our web beacons may collect some contact information (for example, the email address associated with an email message that contains a web beacon). 107.1 The Drive’s Web Site also may include third-party web beacons so that these third parties may receive auditing, research, and reporting information about advertisements viewed on 107.1 The Drive’s Web Site. Third parties do not have access to your contact information in connection with their use of web beacons. Mobile Devices Certain mobile devices contain unique identifiers that can be used, for example, to identify the physical location of such devices. Mobile devices also typically transmit caller ID data when used to transmit a telephone call or text message. 107.1 The Drive’s Web Site may collect, use, transmit, process, and maintain unique identifiers, caller ID data, location-based data, and similar information when you rely on mobile devices, including to provide the services you request, tell you about offers we think you will value, and improve your experience on 107.1 The Drive’s Web Site. 107.1 The Drive’s Web Site also may require collection of your mobile phone number in order for you to participate in certain services or features and that number may be associated with such information. 107.1 The Drive Online Advertising In order to customize your experience on 107.1 The Drive’s Web Site, we may use cookies, web beacons, and other technologies to collect information about the content and advertisements you view on our Web Sites. Based on this information, and other information we may collect about you, we try to infer your interests and show content and advertising that is more relevant to you. For example, if you access an article about computers on 107.1 The Drive’s Web Site, we may show you a computer-related advertisement on another Up North Radio LLC Web Site based on your apparent interests. We also may receive information from third parties about you and your activities on other sites for the purpose of serving relevant advertisements to you on 107.1 The Drive’s Web Site. For example, if you access an article on a third-party site about computers, we may use that information to serve you with a computer-related advertisement on 107.1 The Drive’s Web Site. Please note that we may share information about our users with advertisers so that they can measure the effectiveness of advertisements viewed on 107.1 The Drive’s Web Site. For example, we may tell advertisers the number of users who clicked on a particular advertisement. These online-advertising efforts across 107.1 The Drive’s Web Site do not result in you seeing more advertisements, just more relevant advertising, and they allow us to provide you with free content and services on our Web Sites. We hope you value our efforts to show you content and advertising that more closely reflects your interests. Some of the advertisements you see on 107.1 The Drive’s Web Site are delivered by third parties. To learn more, please read about third-party online advertising. Third-Party Online Advertising Some of the advertisements you see on 107.1 The Drive’s Web Site are delivered by third parties who also collect information through cookies, web beacons, and other technologies about your online activities, either on our Web Sites or across the Internet, in an effort to understand your interests and deliver you advertisements that are tailored to your interests. These third parties include advertisers, advertising agencies, and ad networks that may collect information when you view or interact with one of their advertisements. Please note that 107.1 The Drive does not have access to the information these third parties may collect about your interests to deliver relevant advertising to you, and the information practices of these third parties are not covered by this Privacy Policy. Third parties that currently serve ads on our Web Sites, and thereby may collect information about your online activities on such Web Sites to deliver tailored ads, include, but are not limited to, Atlas, DoubleClick, Eyeblaster, EyeWonder, and Pointroll. These companies may offer you a way to choose not to have your information used for advertising purposes. You can find more information by clicking on the company names above and following the links to each company’s web site. In addition, some of these companies are members of the Network Advertising Initiative (“NAI”), which offers a single location to opt out of receiving tailored ads from member companies. To opt out of information collection by NAI member companies, or to obtain information about the technologies they use or their own privacy policies, please visit: http://www.networkadvertising.org/optout_nonppii.asp. Please note that if you choose to opt out of having your information used to deliver advertisements tailored to your interests, you will continue to see advertisements on our Web Sites, but these advertisements may not be as relevant to you. For more information about relevant advertisements delivered by 107.1 The Drive, please read about 107.1 The Drive online advertising.   107.1 The Drive and FCC Requirements If you send a written communication (including an email) regarding the programming or operation of an Up North Radio LLC radio station, your communication may be placed in the public inspection file of that station or made available via electronic file access at the station. In either case, your communication may be subject to review by members of the general public, as required by Federal Communications Commission (“FCC”) regulations. Be advised that we are not responsible for information that may be disclosed if your communication is made available for review by members of the general public in compliance with FCC regulations. Children’s Privacy Policy We recognize the need to provide additional privacy protections when children visit the sites on which this Children’s Privacy Policy is posted. The following guidelines supplement our general Privacy Policy and follow the rules set by the U.S. Children’s Online Privacy Protection Act and other applicable laws. “Child” means an individual under 13 years of age or an individual under 18 where the collection, use or disclosure of personal information about such an individual is restricted by applicable law. When we use the term “parent” below, we mean to include legal guardians. Information We Collect Children can enjoy content and features on 107.1 The Drive’s Web Site without directly providing contact information. However, children who wish to participate in sweepstakes, contests, and certain other special activities may need to provide information such as first name, user name, password, email address, date of birth, city and state of residence, and gender. In the course of participating in interactive features such as chat rooms and message boards, a child may provide us with additional information about himself or herself, such as the contents of his or her postings. Some information, including information collected through cookies, web beacons, and other technologies, may be collected automatically. For more information, see the “information we collect automatically” section of our general Privacy Policy. If we collect, use, or disclose contact information collected from a child, we will provide notice and obtain parental consent in accordance with applicable law. We do not condition a child’s participation in an online activity on the child’s providing more contact information than is reasonably necessary to participate in that activity. Use of Information We use the information we collect consistent with the services requested by the child. For example, we may use information provided by the child to:

• Send a newsletter, electronic card, and other communication requested by the child;
• Enable a child’s participation in certain interactive features such as games, contests, message boards, chat rooms, song requests, and online scrolling tickers; and
• Respond to correspondence sent by the child.

In addition, we may use a parent’s contact information to communicate with the parent regarding the child’s activities on 107.1 The Drive’s Web Site. For example, if a child wins a sweepstakes or contest, we may use the parent’s contact information to conduct prize fulfillment. Disclosure of Information Information collected from children will be disclosed in the same ways described in the “Disclosure of Information” section of our general Privacy Policy. Third parties who receive contact information collected by 107.1 The Drive have agreed to maintain the confidentiality, security, and integrity of that information. Parents have the option not to consent to the disclosure of their child’s contact information to third parties. Parents may consent to 107.1 The Drive’s collection and use of their child’s contact information while refusing to permit the disclosure of that information to third parties. Parents’ Choices and Access to Children’s Information Parents may review the contact information we have collected from their child, refuse to permit us to collect further contact information from their child, and request that any contact information we have collected be deleted from our records. Parents may also correct factual inaccuracies. To review, update, or delete your child’s contact information, please contact us.  You may also send your request to the postal address listed below. To protect your child’s safety, we ask for proof of your identification. We may deny access if we believe there is a question about your identity. Certain information cannot be deleted because of other legal obligations, such as FCC requirements. Changes to the Children’s Privacy Policy We may amend our Children’s Privacy Policy at any time. We will provide parents with notice of any material changes in the way we intend to collect, use, and share children’s contact information. Please note that, at all times, parents should update their contact information to provide us with current email addresses. We will apply material changes in our Children’s Privacy Policy only in conformance with applicable law. Contact Us If you need further assistance, please contact us.  If you would prefer to submit your questions or comments by mail, please send a letter to the address below: Up North Radio LLC 8082 E. M115 Suite B Cadillac, MI 49601 Attn: General Counsel.