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Privacy Policy (Updated: 12/14/18)

Townsquare Media, Inc. and its subsidiaries and affiliates (individually or collectively, “TSM” or “we/our/us”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the type of information we may collect from you and or that you may provide us when you interact with our websites, mobile applications, email, and online services, participate in our loyalty program, or register for one of our events (our “Services”). “You/your/user(s)” means you as a user of our Services. We offer the Services, including all information, tools and features available from the Services, to you conditioned upon your acceptance of all the terms, conditions, policies and notices stated here, which you accept by continuing to utilize the Services.

Guide to Contents:

1. Scope

1.1 We value our users and respect your privacy. This Privacy Policy describes the information we collect about you online, why we collect it, how we use it, and when we share it with third parties. This Privacy Policy also describes the choices you can make about how we collect and use certain of that information.

1.2 By accessing the Services, you acknowledge this Privacy Policy and agree to be bound by the terms hereof and the Terms of Service set forth on each of the Services that you visit or utilize. If you have any questions about the content of this Policy, please contact us at our privacy preferences page: http://www.brooklynvegan.com/privacy/preferences.

1.3 This Policy applies to our Services as described above as well as the information we collect when you interact with us through social media or other websites and online services. It does not apply to non-TSM Websites and mobile applications that may link to the Services or be linked to or from the Services; please review the privacy policies on those Services and applications directly to understand their privacy practices.

1.4 We reserve the right to change or update this Privacy Policy by posting such changes or updates to the Services. Amendments to this Privacy Policy will be posted at this URL and will be effective when posted. You can tell if the policy has changed by checking the last modified date that appears at the end of this Privacy Policy. Your continued use of the Services following the posting of any amendment, modification or change shall constitute your acceptance thereof.

2. Information Collected

2.1 We collect information that you provide directly to us. You may provide different types of information to us when you engage in certain activities through the Services, such as creating an account, ordering a product or service, submitting, posting or accessing various content or features, subscribing to mobile push notifications, responding to and submitting a form, participating in our blogs or forums, entering a sweepstakes, contest, promotion or other special initiative, signing up for a special offer, completing a survey, sending feedback, requesting or submitting information, applying for a job, or directly contacting us. The information we request includes, but is not limited to, your name, email address, mailing address, telephone number, age, and demographic information. It is optional for you to engage in such activity; however, if you choose to do so, we may not be able to permit you to participate in the activity unless certain pieces of information are provided.

2.2 When you interact with the Services, certain information about your use of the Services is automatically collected, regardless of whether you create an account on the Services. This information includes, but is not limited to, your browser type; mobile phone, tablet or other device type; computer or mobile operating system; the domain of the website that referred you to us; name of your Internet service provider; web pages you visit on the Services; IP address; geo-location information; and standard server log information. We also collect information about your interactions with our email messages, such as whether the messages were opened and the links clicked in those emails. Much of this information is collected through cookies, web beacons and other tracking technologies. Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Services may not be available, work, or work as designed.

2.3 The cookies described in Section 2.2 may be first or third party. We may also allow our affiliates, service providers, data management providers and advertisers to serve cookies or employ other tracking technologies from the Services. These cookies allow us, in conjunction with our partners, to analyze how the Services are accessed, used, or performing, and allow us to serve you with content, including advertising, tailored to your preferences or interests, as well as measure the effectiveness of that advertising.

2.4 Among the third party cookies used for purposes of optimizing the Services is Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Services, compile reports on the Services’ activity, and provide other services related to our Services’ activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. The Services do not use Google Analytics to gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here.

2.5 We currently use a third party for payment processing. We do not receive or store your credit card or bank account information, and we do not want you to send us your credit card or bank account information. Please review the terms of use and privacy policies of the third party payment processor prior to providing your information to them.

2.6 When you interact with us or the Services through a social media platform (such as by clicking on a social media icon linked from our Services), we may collect the personal information that you make available to us on that page, including your account ID or username and other information included in your posts. If you choose to log in to your account with or through a social networking service, we and that service may share certain information about you and your activities.

3. Use of Your Information

3.1 We use and share the information we collect for various purposes, including to:

• Communicate with you, including to fulfill your requests, provide information about additional products, services, and promotions that might be of interest to you, and provide notices of a transactional, administrative or relationship nature or as required by law;

• Provide, maintain, personalize, optimize, and improve our products and services including research and analytics regarding use of the Services, or to remember you when you leave and return to the Services;

• Provide you with content that may be of interest with you, including advertising;

• Enable you to participate in features such as surveys, reviews, blogs or forums, or to enter sweepstakes, contests, promotions and other special initiatives and to communicate with you about them

• Provide you with more relevant content in email bulletins to which you may be subscribed;

• Monitor and protect the Services, including research and analytics regarding how the Services are accessed, used, or performing;

• Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal.

3.2 We may combine information from the Services together and with other information we obtain from our business records or from third party sources. We also may use or combine information that we collect from the Services with information provided by third parties, including demographic information and other attributes, and organizational affiliations.

4. Sharing Information With Third Parties

4.1 We may share the information collected via our Services with third parties who work on our behalf to help us further the purposes described above. We may provide additional information that we have collected about you both directly and automatically to these third parties.

4.2 We share information about you with third parties who partner with us to provide advertisements about products and services that may be of interest to you. This may include third parties who assist us in identifying which ads to deliver and third parties who deliver the advertisements. As described above, our third party partners may use persistent identifiers to track your Internet usage across other websites, online services, email and mobile applications in their networks beyond the Services, and may combine information about you from other sources. We may provide additional information that we have collected about you both directly and automatically to our partners.
Our partners may use the information collected to serve you with targeted advertising, both through our Services and other websites, email, online services or mobile applications. We may also contribute to or participate in cooperative databases, which give other companies access to your information. For more information regarding the partners with whom we share data, please see our Partners List.

We adhere to the principles of the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising and Multi-Site Data and the Network Advertising Initiative’s Code of Conduct, as applicable. See the Opt-Out section (below) to learn about choices available to you with respect to this type of advertising.

4.3 We may aggregate your information into a form where individuals can no longer be identified. Given the aggregated, de-identified information, there are no restrictions under this Privacy Policy on how we may use or disclose such information. For example, we may freely share such information with third parties who may use such data for their own marketing, advertising, research, or other business purposes.

4.4 If you choose to enter a sweepstakes, contest or other promotion, your information may be disclosed to third parties who help design, administer and implement the promotion, including in connection with winner selection, prize fulfillment and aggregated data analysis. Your information also may be disclosed as required by law, such as on a winners list.

4.5 We may provide products or services jointly with or through certain third-party businesses, including but not limited to retail businesses. When we provide these products or services, we may give you the opportunity to opt-in to the additional sharing of information with these businesses. Should you choose to do so, information you provide specifically in connection with those products and services may be shared with these businesses and subject to their privacy policies.

4.6 The Services may allow users to post comments and other content to the Services. Any information about yourself that you post to the Services will become public information and will be accessible by other users of the Services. In addition, your user name will be viewable by other users, along with a profile picture if you have chosen to upload one. We have no responsibility to maintain the privacy or security of any such information that you may choose to post to the Services.

4.7 When you use the Services, you may be given the option to subscribe to or to be added to our email list. Your selection will not affect other uses or sharing of your information as described in this this Privacy Policy. Subscriptions to the email list can be cancelled at any time by following the instructions below.

4.8 By providing us with your telephone number, you are authorizing us, our service providers and our and their affiliated companies to deliver or cause to be delivered SMS text messages, texts, push notifications and voice message notifications, including promotional messages, using an automatic telephone dialing system. You are not required to receive such messages as a condition of purchasing any property, goods or services. Registered users may choose not to receive text messages from us by not providing us their cell phone number. You can also cancel the SMS service at any time by replying ‘STOP’ via text. Please note that standard message rates and data charges from your cellular service provider apply to sending and/or receiving text messages. You are solely responsible for such message rates and data charges.

4.9 We may disclose information about you if required to do so by law or on the good-faith believe that such sharing is necessary to (a) conform to applicable law or comply with legal process served on us or our Services; (b) protect and defend our rights or property, the Services, or our users; or (c) act to protect the personal safety of our employees and agents, other users of the Services, or members of the public.

4.10 If we go through a business transition, such as a merger, acquisition by another company or a financing, investment, support or funding, sharing or sale of all or a portion of our assets, your information may be among the assets shared or transferred. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Privacy Policy.

5. Your Security

5.1 We strive to keep your information private and safe. We take commercially reasonable physical, electronic and administrative steps to maintain the security of the information collected. Unfortunately, despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. Please note that e-mail is not encrypted and is not considered to be a secure means of transmitting credit card information, so please do not send us your credit card number by email. Any payment transactions will be encrypted.

6. Your Options

6.1 You may choose not to subscribe to email communications other than service-related communications such as payment confirmation. If you do choose to receive email communications such as email newsletters and promotional emails, you may later opt out by following the instructions provided at the bottom of each email, clicking the “unsubscribe” button at the bottom of emails we sent you, or by managing your preferences here: http://www.brooklynvegan.com/privacy/preferences. Please allow up to ten (10) business days for changes to your email preferences to take effect.

6.2 You can learn more about ad serving companies and the options available to limit their collection and use of your information by visiting the Services for the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Advertising Digital Alliance (EDAA). Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device. For more information about how to change these settings go to:

Apple: http://support.apple.com/kb/HT4228

Android: http://www.google.com/policies/technologies/ads/

Windows: http://choice.microsoft.com/en-US/opt-out

The DAA’s AppChoices App provides options regarding the collection of cross-app data for your device.

Additional resources or tools may exist that streamline the process of submitting opt-out requests--for example, TRUSTe’s Ad Preference Manager. We do not review or warrant the representations made by these tools and cannot guarantee the effectiveness.

6.3 To opt out of Google Analytics Advertising Features, visit Google’s Ad Settings page. Website users can also access the Google Analytics Opt Out Browser Add-on https://support.google.com/analytics/answer/181881?hl=en.

6.4 Please note that opting-out of advertising networks services does not mean that you will not receive advertising while using our Services or on other Services, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. If you delete your cookies, you may also delete your opt-out preferences. If you use multiple browsers or devices you may need to execute this opt out on each browser or device.

6.5 Your browser or device may include “Do Not Track” functionality. At this time, we do not respond to browser “Do Not Track” signals.

6.6 Registered users who have provided their cell phone number to us may remove it from within their personal profile settings. If you prefer not to receive text or wireless promotional communications on your mobile device, you can opt out by replying STOP.

6.7 You may update or delete information from your profile at any time, or request that we do so; however, because we archive past transactions, you cannot delete this information. You may also request that we delete your account entirely by contacting us. Terminating your registration will not necessarily remove previous public comments or other user content on public display on the Services. If you wish to cancel your account on the Services or delete your information previously provided to us, you may send your request here: http://www.brooklynvegan.com/privacy/preferences.

6.8 If you do not receive a response from us to any emails you send to us within ten (10) business days, please send us another email, as your original email may not have been received.

7. Children

We do not permit children under 13 years of age to use the Services, and we do not knowingly collect, use or disclose information from anyone under 13 years of age except as part of specific outreach programs with parental permission. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian's consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13, we will make reasonable efforts to delete such information from our records. If you believe that we have mistakenly or unintentionally collected personal information of a minor without appropriate consent, please notify us at our privacy preferences page: http://www.brooklynvegan.com/privacy/preferences. You may also contact by mail at the following address: Townsquare Media, Inc., ATTN: Privacy, 240 Greenwich Ave., Greenwich, CT 06830.

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8. Your California Privacy Rights

8.1 Under California Civil Code sections 1798.83-1798.84, California residents are entitled to request information from us regarding what categories of personal information we share with third parties who may use the data for direct marketing purposes and all third parties with whom we have shared that data in the past year. If you are a California resident and would like to submit a request, please write to the following address: Townsquare Media, Inc., ATTN: Privacy, 240 Greenwich Ave., Greenwich, CT 06830. You must put the statement “Your California Privacy Rights” in the body of the request and state the name of our website with respect to which you are requesting the information as well as your name, street address, city, state, and zip code.

9. International User Notice

For international users, please note that it may be necessary to transfer your information internationally and, in particular, your information may be transferred to and processed in the United States. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law. If applicable, you may have a right to claim compensation for damages caused by a breach of relevant data protection laws. By using the Services, you agree to have your information used and transferred to the United States as set forth in this policy.

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10. Users in the European Union (EEA) and Switzerland

If you are a resident of the EEA or Switzerland, the following information applies.

Purposes of processing and legal basis for processing: As explained above, we process personal data in various ways depending upon your use of our Services. We process personal data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services; and (3) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedom related to data privacy

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Right to lodge a complaint: Users that reside in the EEA or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.

Transfers: Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. Upon the start of enforcement of the General Data Protection Regulation (GDPR), we will ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR.

Individual Rights: If you are a resident of the EEA or Switzerland, you are entitled to the following rights once the GDPR becomes effective. Please note: In order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing information about you.

• The right to request data erasure. You have the right to have your data erased from our Services if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.

• The right to restrict or object to our processing. You have the right to restrict or object to our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.

11. Contact

If you have any questions about your privacy or security at the Services, or wish to update your information, please contact us at our privacy preferences page: http://www.brooklynvegan.com/privacy/preferences. You may also write to us at: Townsquare Media, Inc., ATTN: Privacy, 240 Greenwich Ave., Greenwich, CT 06830, Fax: 1 (800) 301-6408, and include your name, mailing address and email address in the message. You may call us at 1 (203) 861-0900.

DATE LAST MODIFIED: December 14, 2018