Radio Spirits App
Privacy Policy

Effective as of February 20, 2019

RSPT, LLC operates a free and subscription based streaming and downloadable audio service that features classic radio programs and other audio content through its Radio Spirits App on mobile devices and tablets (the "RSPT, LLC Service" or "Service"). As used in this policy, "RSPT, LLC" refers to RSPT, LLC and its subsidiaries. This policy applies to all RSPT, LLC-authorized operations of the Service. We may refer to RSPT, LLC as "we", "us", or "our". We may refer to you as "listener", "you", or "your". The purpose of this policy is to tell you the information we collect, how we use and share this information, and the ways you can control how we use and share this information. By submitting your information through our Service, you agree to the terms of this policy and you expressly consent to the collection, use, and disclosure of your information in accordance with this policy.

1. Information We Receive or Collect from You

Registration Data
When you register, we may ask you to provide certain information including your email address, name and physical mailing address (the "Registration Data"), and a password for your account.

Payment Information
If you choose to subscribe to fee-based portions of the Service, purchase a subscription to the Service as a gift, you will also be asked to provide (at a minimum) your name and credit card information ("Payment Information").

Information You Choose to Provide to RSPT, LLC
You have the ability to provide a variety of information during your interactions with us and the RSPT, LLC Service, such as emails you may send us. RSPT, LLC or third parties acting on our behalf receive data from you whenever you provide us with any of this type of information.

Listening Activity
When you use the Service, we keep track of your listening and browsing activity, which may include the number and title of programs you have listened to, the programs you skip and download and how long you listen to a program.

Technical Information
As is true of many internet-enabled services, RSPT, LLC may collect certain non-personally identifiable technical information through the use of log files and servers. Web and application servers create log files automatically as part of their setup and configuration. Information in a log file may include your IP address, browser type, Internet service provider, date/time stamps, MAC address, files requested, and other usage information.

Device Information
If you access and use the Service from a mobile phone, tablet, or other electronic device, we may collect information about those devices. For example, we may collect and store information such as device type, operating system version and type, unique identifiers (such as Android Advertising ID, Facebook ID, MAC address, and IDFA), carrier, and other related information for that device.

Location Information
As part of registration for the Radio Spirits App, you agree to provide us with, and allow us to use, your zip or postal code. Additionally, we may collect and use approximated or realtime location information, such as GPS location, from devices you use to access the Service. We will provide you with notice and an opportunity to consent before we access and collect your realtime location information, and depending on your device manufacturer, you may have the ability to revoke this consent at any time.

2. Information We Receive or Collect from Third Parties
We may receive or collect information about you from third parties, and combine and store it on our servers with other information we may have already received or collected from you. These third parties include:
• Service partners that provide or make available advertising, features and functionality, and content on or through the Service.
• Advertising partners that collect and maintain information on their customers. These partners may provide RSPT, LLC with certain information about those customers for the purposes of serving advertisements and/or marketing offers to their customers on the RSPT, LLC Service.
• Marketing companies and data providers that create, maintain, and distribute professional marketing lists or segments, or maintain and distribute other marketing, or similar data.
• Governmental or quasi- or pseudo-governmental agencies or organizations that provide or make available, to the public, census and demographic data.
• Third-party social media websites, applications, or services that you use, when we allow those websites, applications, or services to interact through the Service to provide personalized services to you. In some cases, those websites, applications, or services may automatically provide us with information about you to facilitate personalization unless you use the controls available on those websites, applications, or services to opt-out of such sharing.

RSPT, LLC is not responsible for, and will assume no liability, if a business partner or other entity collects, uses, or shares any information about you in violation of its own privacy policy or any applicable laws, rules, or regulations.

3. Information Collection Technologies
Our use of cookies:
RSPT, LLC uses a technology that is commonly known as "cookies." A cookie is a file our server writes to your hard drive that contains a unique alphanumeric identifier. We use the identifier in a cookie to help us manage and report on your interaction with the Service. Through cookies, we are able to collect information that we use to improve the Service, keep track of return visits to our website or our advertisers' or partners' websites, collect and report on aggregate statistical information, authenticate your login credentials, and/or manage multiple instances of the Service in a single browser. We may also collect other data such as the app, page or site that referred you to the Service, the date and time you visited the Service, and your current IP address. The cookies we place on your hard drive are known as "first-party cookies."
We use both session cookies and persistent cookies. A session cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You may be able to remove persistent cookies by following directions provided in your mobile devices settings. If you do not accept first-party cookies you may still use our Service, but some features of the Service may not work properly and you may have difficulty staying logged in to the Service.

Advertisers' and other third parties' use of cookies
Advertisers and third-party advertising partners that deliver ads to you on the Service may place or recognize a unique cookie on your mobil device. These types of non-RSPT, LLC cookies are known as "third-party cookies." Advertisers and third-party advertising partners may use third-party cookies in order to collect information about you, which may include how many times you have seen their ads or whether you have interacted with an ad. They may also use third-party cookies to provide you with interest-based advertising. Most major web browsers provide users with the option to accept or reject third-party cookies. The use of third-party cookies is not covered by this privacy policy. We do not have access to or control over cookies placed by advertisers and other third parties. If you would like to review and modify your interest-based advertising settings, visit Your Advertising Choices on RSPT, LLC.

Beacons and Tracking Pixels
RSPT, LLC, its third-party advertising partners, and tracking-utility partners use a technology known as "beacons" or "tracking pixels" (each, a "Beacon"). A Beacon is a one-pixel-by-one-pixel clear image that is embedded in HTML content, and is about the size of a period at the end of a sentence. When HTML content containing a Beacon is rendered, the Beacon transmits anonymous information to a server, such as a numeric count, unique identifier, or IP address. RSPT, LLC and its partners use Beacons to help us better manage content on our Service. For example, we may place a Beacon in HTML-based emails to let us know which emails recipients have opened, or on a webpage to count the number of unique visitors to that page.

HTML5 and Flash Local Storage
RSPT, LLC and its advertising and technology partners may, in some instances, use HTML5 and/or Flash Local Storage (collectively, "Local Storage") to enhance your listening and advertising experiences on the Service. Each browser implements HTML5 Local Storage differently and provides tools for managing content stored within local storage. Review your browser's privacy settings to manage the content stored within HTML5 Local Storage. Similarly, for more information on how to manage content stored with Flash Local Storage, please review this document provided by Adobe.

4. How We Use Information We Receive or Collect

In general, RSPT, LLC may use your Registration Data and/or other information or data we receive or collect, as well as data we derive or infer from combinations of the foregoing, for a variety of reasons, such as:
• To create and secure your account on the Radio Spirits App.
• To customize and personalize the advertising and other content we deliver to you both on the Service and on other services offered by our publishing partners. We use this information to provide you with relevant and interesting advertising and other content.
• To measure and analyze Service usage and improve the user experience on our Service. We use tracking information to determine how well each page and app function performs overall, based on aggregate visitor and listener statistics and traffic patterns to those pages.
• To fulfill your requests for certain products and services, such as distributing electronic newsletters and enabling you to participate in and renew paid services.
• To assist with technical inquiries that you have made.
• To send you information that you agreed to receive.
• To alert you to the latest developments and features of our Service and to notify you of administrative information, such as security or support and maintenance advisories.
• To pay rightsholders for programs you listen to or download, by reporting listening information to appropriate licensing parties.
Email Address

We do not sell or give your email address to other companies for their own marketing purposes without your permission. However, we may use your email address or other Registration Data to provide you with technical support, send you notices about the Service or other promotional offers you have elected to receive, and to serve you with ads that are more relevant to your interests. We may also work with data partners and advertising platforms to help increase the relevancy of ads we provide to our listeners. In doing so, we may use information representing an encrypted or hashed value derived from information we have received, such as your email address, in connection with these partners and platforms.

Contact Information
We do not sell or give your Contact Information to companies for their own marketing purposes without your permission. We do use Contact Information, however, to contact you, and to provide you with special offers and other information

5. How We Share Information We Receive or Collect with Others
RSPT, LLC may share information we receive or collect in a variety of ways, such as:
• When you give RSPT, LLC permission through an affirmative election (for example, clicking "yes" in response to a message such as "share my email with this advertiser").
• If we contract or partner with third parties to provide specialized services on our behalf, such as credit card processors, customer support, ad servers or other providers of advertising services, bulk email processors who send out emails on our behalf, or parties who assist us with sweepstakes management and prize fulfillment. These companies are authorized to use your personal information only as necessary to provide these services to RSPT, LLC. They are not authorized to use your personal information for their own, unrelated purposes.
• If you have given permission to a third party for us to share data about you with them.

• To measure and analyze Service usage. For example, we may use third-party providers such as Nielsen to measure how long and how frequently you are using the Service. Our advertising partners may use these providers to measure the effectiveness of their campaigns. When we use these providers, we provide them with non-personally identifiable information about you, such as your device identifier. Sharing of Personally Identifiable Information

We do not share personally identifiable information with third parties other than as described in this policy. However, we may share your information, including personally identifiable information, in order to (i) protect or defend the legal rights or property of RSPT, LLC, or the legal rights of our business partners, employees, agents, and contractors (including enforcement of our agreements); (ii) protect the safety and security of RSPT, LLC users or members of the public including acting in urgent circumstances; (iii) protect against fraud or to conduct risk management; or (iv) comply with the law, legal process, or legal requests. Additionally, we may share your data, including any personally identifiable information, with our successor in interest in the event of a corporate reorganization, merger, or sale of all or substantially all of our assets.

Sharing of Device Data
RSPT, LLC may share information from devices you use to access the Service with its third-party vendors or service providers, manufacturing or distribution partners, or advertising partners. We may share this information for a variety of purposes such as advertising frequency capping, tracking advertising conversion events, estimating the number of unique users, security and fraud detection, debugging issues with the RSPT, LLC Service, and for providing you with more relevant advertisements.

Sharing of Anonymized, Non-Personally Identifiable or Aggregated Data
RSPT, LLC may share with third parties, advertisers, and/or business partners anonymized, non-personally identifiable, or aggregated data we receive or collect, such as demographic information, location information, information about the computer or device from which you access the Service, or information about the programs you listen to or download. We share such information for a variety of reasons, such as to analyze Service usage, improve the Radio Spirits App and your listener experience, improve the serving of advertisements, or for other similar purposes. The use and disclosure of such anonymized, non-personally identifiable, or aggregated information is not subject to any restrictions under this agreement.

6. Advertising & Measurement Settings
Opting Out of Behavioral Advertising on the Web
In our effort to provide you with advertisements that may interest you, RSPT, LLC and its third-party advertising partners use data in the manner disclosed in this policy to provide you with relevant ads. To learn about how the online advertising industry uses information it collects to provide you with relevant ads, and to control whether you want to receive those relevant ads from third-party advertisers, please review the information at the following links:
• Your Advertising Choices on RSPT, LLC
• AdChoices
• Understanding Online Advertising

Because we do not control the privacy practices of third-party advertising companies, you should read and understand their privacy policies. You acknowledge and agree that you are solely responsible for reviewing the privacy policies of such third-party advertising companies and the methods available, if any, for changing privacy settings and the like.

Opting Out of Behavioral Advertising on Mobile and Tablet Devices:
If you are using an iOS-based device and do not want to receive tailored in-application advertisements that relate to your interests, you may be able to limit these advertisements by enabling "Limit Ad Tracking" on your iOS Device following these instructions from Apple.

If you are using an Android-based device and you do not wish to receive tailored in-application advertisements, you can visit Google's Ads Settings page from a browser on your Android-based device and make your choices there.

RSPT, LLC does not control the applicable operating system supplied ad settings, which may be updated or removed in accordance with each operating system provider’s respective policies. You should contact your operating system provider if these options are no longer available.

Opting Out of Third Party Service Measurement and Analytics
As disclosed in this policy, we use third-party providers to aid us in measuring and analyzing service usage. To opt-out of participation on mobile and tablet devices, please follow the instructions listed above.

7. Managing Your Information
Modification of Your Registration Data
We provide you with the ability to modify your Registration Data, which you may do through the Settings section of our App or by contacting Customer Support. For detailed instructions on how to modify your Registration Data or to otherwise access this information, visit our support site at http://help.RSPT, We generally respond to email requests within 48 hours of receiving a request, but it may take up to 30 days depending on the volume of requests we receive.

Retention of Your Registration Data and other Information
We will retain and use your Registration Data and the other information we collect about you for as long as your account is active or as needed to provide you Services. We will retain and use this information for the purposes for which it was collected (as specified in this policy or as RSPT, LLC discloses to its listeners outside of this policy), including, to provide the Service to you, comply with our legal obligations, resolve disputes, and enforce our agreements.

If you would like to delete your Registration Data, or if you would like more information on cancelling or deactivating your account, see the section below on Cancellation or Deactivation of Accounts.

Your Email Preferences
When you register for the Service, you may elect to receive promotional, marketing, or other similar emails tailored to your interests. You have the option to change this election in the Settings section of our Service. For information on how to opt in or out of receiving promotional, marketing, or other similar emails from us, visit our FAQ page.

Additionally, you may also follow the unsubscribe instructions contained in the promotional, marketing, or other similar emails you may receive from us. However, we will always send you transaction confirmation emails and other Service-related announcements when it is necessary to do so. You may not opt-out of transaction or service related communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account and stop use of the Service.

Cancellation or Deactivation of Accounts
If you would like to request the cancellation or deactivation of your account, you should contact our Customer Support team for assistance.

8. Security and Content from Other Websites
Protection of Data from Loss
We have implemented numerous security measures designed to protect the data we collect or receive from you. However, despite our efforts, no security measures are perfect or impenetrable. If you have any questions about security on our Service, you can contact Customer Support.

Data Integrity
We will use personally identifiable information, if any, that we collect and receive from you in ways that are relevant and compatible with the purpose for which that information was collected or provided to us as more fully disclosed in this policy. We will take steps to ensure that all personally identifiable information collected, processed, and/or stored is protected from use in a manner inconsistent with the purpose for which we received it.

Links to Other Websites
Our Service and certain advertisements on our Service include links to other websites whose privacy practices may differ from those of RSPT, LLC. If you submit personal information to any of those websites, the privacy statements and practices of those websites govern their use of your information. We encourage you to carefully read the privacy statement of any website you visit.

Use of Framing Techniques
Some of our third-party partners may utilize framing techniques to serve content to and from webpages accessible through our Service while preserving the look and feel of our website. Please be aware that if a third-party partner utilizes framing techniques, you are providing your personal information to this third-party partner and not to RSPT, LLC.

9. Our Policies Concerning Children
RSPT, LLC prohibits registration by, and does not knowingly collect personal information from, anyone under 13 years of age. In the event we obtain actual knowledge that we have collected information from children under the age of 13, we will take measures to remove such information from our servers and other records if applicable.

10. Your California Privacy Rights and "Do Not Track"
Pursuant to California Civil Code Section 1798.83, this policy sets forth that we only share personal information (as defined in California Civil Code Section 1798.83) with third parties for direct marketing purposes if you either specifically opt-in, or are offered the opportunity to opt-out and elect not to opt-out of such sharing at the time you provide personal information or when you choose to participate in a feature on the Service. If you do not opt-in or if you opt-out at that time, we will not share your personal information with that identified third party for direct marketing purposes.
California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how we respond to "Do Not Track" browser settings. Like many other websites and online services, we do not currently alter our practices when we receive Do Not Track signals as there is no consensus among industry participants as to what "Do Not Track" means in this context. To find out more about "Do Not Track," you may wish to visit

11. Transfer of Information of International Listeners
Please note that the information you submit to us may be transferred to the U.S. and other countries to be processed by us or our service providers in order to provide the Service to you or for such other purposes as set forth in this policy. If you are not a resident of the U.S., you hereby consent and agree that we may collect, process, use, and store your information, as discussed in this policy, outside your resident jurisdiction, including in the U.S. Please be aware that U.S. law and the laws of other countries where we may store and process your information may offer different levels of protection for information than may be available in your country.

12. Changes to our Privacy Policy
We may make changes to this policy occasionally. Please check this page periodically for updates. If we make any material changes to this policy, we will post the updated terms of the policy on the Service, and provide you notice of such chances, which may include notice by email through a message sent to the email address you use to access the Service, or posting a message on the Service.
Any material changes to this policy will be effective upon the earlier of 30 calendar days following our dispatch of an email notice to you or 30 calendar days following our posting of notice of the changes on the Service. These changes will be effective immediately for new users of the Service. Please note that at all times you are responsible for updating your information to provide us with your most current email address. In the event that the last email address you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the email containing such notice will constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your information, you must notify us prior to the effective date of the changes that you wish to deactivate your account. Continued use of the Service following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

13. Governance
RSPT, LLC will conduct compliance audits of our relevant privacy practices to verify adherence to this policy. and will self-certify with the U.S. Department of Commerce for the purposes of EU Safe Harbor compliance. Further, we will conduct follow up investigations to verify that attestations and assertions regarding our privacy practices are accurate. You may inquire about an inaccuracy or make a complaint about a potential violation to us via the contact information provided below. We do engage in training to support implementation and compliance of our privacy practices; any employee that we determine is in violation of this policy may be subject to disciplinary action.

Dispute Resolution
Questions regarding our use or disclosure of information may be directed to our Customer Support team. RSPT, LLC will investigate and attempt to resolve complaints and disputes regarding use and disclosure of information in accordance with the principles contained in this policy. For complaints that cannot be resolved between RSPT, LLC and the complainant, RSPT, LLC agrees to cooperate with the respective data protection authorities located in the applicable country (or their authorized representatives) and participate in any dispute resolution procedures established by such authorities.

14. Contact Us
If you have any questions about this privacy policy, or the privacy practices of RSPT, LLC, contact our Customer Service team for more information, or write to us at: Attn: Radio Spirits App, RSPT, LLC, PO Box 1315, Little Falls, NJ 07424.