Privacy Policy

Protecting your private information is our priority. This Privacy Policy applies to Castletown Media, LLC (“Company” or “we” or “our”) and governs collection, usage, and disclosure of your information via the Company’s website at http://www.castletownmedia.com (“Website”).

By accessing and using the Website, you consent to the data practices described in this Privacy Policy.

Why We Collect Your Data

We collect data from you so that we can provide you with information about our services. In furtherance of these purposes, we may use and disclose your information to our contractors who will use the data to assist Company’s provision of services.

Data that We Collect

Company collects personal information when you register for, and use, the Website. Depending on how you use the Website, we collect different kinds of information about you. This information may include:

Personal Data

Among the types of personal data (“Personal Data”) that the Website may collect from you there are: geographic position, general activity data, movement activity, cookies, usage data, first name, last name, email address, and phone number that you provide to Company and its contractors through the Website.

Personal Data may be freely provided by you or collected automatically, including but not limited to usage data, device information, and location information. Failure to provide the requested Personal Data may make it impossible for Company to provide its Website to you.

Whenever you use the Website, Company receives and records certain Personal Data about you on our server logs, including your IP address, Company’s cookie information and the pages you request, and relates it to the personal information you provide. Any use of cookies – or of other tracking tools – serves the purpose of providing, customizing or improving the Website.

Users are responsible for any third-party Personal Data obtained, published or shared through the Website and confirm that they have the third party’s consent to provide the Data to Company.

Non-Personally Identifiable Information

Non-personally identifiable information includes information that does not personally identify you, but it may be linkable to you. If non-personally identifiable information is directly linked to personally identifiable information, it will be considered Personal Data while it is linked. Aggregate and de-identified information is not considered Personal Data or PHI.

Collection and Combination of Information from Other Sources

We also may collect information about you that we may receive from other sources or from our offline interactions with you to, among other things, enable us to verify or update information contained in our records and to better customize the Website for you. We may combine information gathered from multiple parts of the Website into a single record.

If you do not want us to collect this information, do not access and use the Website.

How Long We Keep Your Data

We will retain your information for as long as needed for us to provide the Website and develop, enhance, modify, and improve our products and services. We will also retain and use your information as necessary to comply with our legal obligations and enforce our agreements.

Third-Party Information Collection

When you use the Website, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include analytics companies, your mobile device manufacturer, your mobile service provider, and Company’s contracted service providers.

These third parties may use tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Protect Your Data

We have contracted with a vendor who stores your data in a secure environment in accordance with commercially reasonable standards. While we take commercially reasonable precautions to prevent your data from being unlawfully accessed, we cannot guarantee that your communications with the Website will never be unlawfully intercepted or that your data will never be unlawfully accessed by third parties. Any transmission of information is at your own risk.

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Disclosure of Your Data

We may disclose aggregated information about our users, and information that does not identify any individual without restriction.

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In addition, we may disclose personal information of that we collect or you provide in the following manner:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business and develop, enhance, improve, and modify our products and services.
To third parties for the purposes of research.
To our contracted third party clients who have engaged us
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Application’s users is among the assets transferred.
For any other purpose disclosed by us when you provide the information.
With your consent.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request, or as otherwise required by law.
As necessary where we believe an individual’s rights, safety, or security is at risk.
If we find that your actions violate any of our legal rights.
To enforce our rights arising from any contracts entered into between you and us.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company our customers or others.

Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the Website and visiting your account profile page.

If you stop using the Website, any Personal Data that you provided to Company and its contractors via the Website will continue to be maintained, used, and disclosed by the Company is accordance with this Privacy Policy.

California residents may have additional personal information rights and choices as set forth below in the California Consumer Privacy Act Addendum.

Minors' Privacy

The Website are not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13 please contact us at contact@castletownmedia.com.

International Transfer

If you are located in a country other than the United States, please note that information that we collect will be processed and stored in the United States, a jurisdiction in which the data protection and privacy laws may not offer the same level of protection as those in the country where you reside or are a citizen. Subject to applicable law, by using our Website, you consent to the transfer to and processing of information in the United States and other jurisdictions.

Changes to our Privacy Policy

We reserve the right to change our Privacy Policy as business needs require. If we decide to change our Privacy Policy, we will post those changes on our Website prior to the time they take effect. If we make material changes to the way we use Personal Data, we will notify affected users through the Website.

Questions and Support

It is important to us that you fully understand how our commitment to keeping the users of the Website safe includes protecting your privacy, and what that means for you and your data. If you have a question related to this Privacy Policy, please contact at us at contact@castletownmedia.com.

California Consumer Privacy Act Addendum

This California Consumer Privacy Act Addendum supplements the information contained in the Castletown Media, LLC (“Company,” or “we” or “us”) Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this Addendum to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Addendum.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA's scope, including health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA).

In particular, we have collected the following categories of personal information from its consumers within the last twelve (12) months:

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

A. IAudio, electronic, visual, thermal, olfactory, or similar information.dentifiers.

I. Professional or employment-related information.

Current or past job history or performance evaluations.

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

A. IdentifierEducation records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. s.

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collecting, Using, and Sharing Personal Information

Please see our Privacy Policy above for details about how we collect, use, and share and use your personal information.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

We have disclosed your personal information for a business purpose to services providers.

Sales of Personal Information

‍In the preceding twelve (12) months, Company has not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see section below titled “Exercising Access, Data Portability, and Deletion Rights”), we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
Sales, identifying the personal information categories that each category of recipient purchased; and
Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide these access and data portability rights for business-to-business personal information.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see section below titled “Exercising Access, Data Portability, and Deletion Rights”), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We do not provide these deletion rights for business-to-business personal information.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 917-277-5406.
Emailing us at contact@castletownmedia.com.
Visiting www.castletownmedia.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

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Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website 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 contact@castletownmedia.com or write us at: Castletown Media, P.O. Box 55451, Seattle, WA 98155.

Changes to this Addendum

We reserve the right to amend this Addendum at our discretion and at any time. When we make changes to this Addendum, we will post the updated Addendum on the Website and update the Addendum's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Addendum, the ways in which Company collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 917-277-5406

Website: www.castletownmedia.com

Email: contact@castletownmedia.com

Postal Address:

Castletown Media

P.O. Box 55451

Seattle, WA 98155

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Castletown Media, LLC

Privacy Policy

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Examples

Collected

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