Graham Media Group Privacy Policy

Last Updated: December 29, 2022

We take user privacy seriously and are committed to protecting it as described in this Privacy Policy (“Privacy Policy”). This Privacy Policy applies to Graham Media Group’s seven local media hubs:

  • KPRC (Houston, TX)
  • KSAT (San Antonio, TX)
  • WDIV (Detroit, MI)
  • WKMG (Orlando, FL)
  • WJXT/WCWJ (Jacksonville, FL)
  • WSLS (Roanoke, VA)

Each of these local media hubs receives services and support, including digital media and technology development, from Graham Media Group and its business units, subsidiaries, and affiliates (collectively referred to herein as “GMG”). You can learn more about Graham Media Group by visiting https://www.grahammedia.com/.

A summary of our approach to privacy follows:

  • We collect information about you to provide you with the best experience using our media platforms.
  • We do not make money by selling your information to third parties.
  • We only give third-parties access to your information when it is necessary to provide you with the services we make available or because you have asked us to do so.
  • You have choices with how we use the information we collect and maintain about you and can ask us to update or remove that information at any time.

We encourage you to read this Privacy Policy in its entirety, but you can navigate to specific areas using the links below:

General

The privacy practices described below apply to information collected by all the local media hubs that are part of GMG. This includes information collected by our local media hubs on or through any websites, mobile applications, widgets, tools, features, and content (including videos and images) that we may offer or employ on any platform (collectively, the “Services”) that is owned or managed by GMG. This policy does not apply to information collected by third parties, including through any platform or content that may link to or be accessible from any of our websites.

This Privacy Policy is incorporated into and made part of the Terms of Use which govern your use of the Services we provide.

Information We Collect

While legal definitions of personal information or personal data can vary in different jurisdictions, we consider “personal information” to be any information that identifies you as an individual or is directly linkable to you as an identifiable individual. Not all information we collect is personal information under this definition. For example, information that has been de-identified or aggregated in a way that no longer allows identification of a particular person would not meet this definition. Similarly, information we gather about you from publicly available sources, such as government databases, may not be considered personal information in your jurisdiction. Where permitted, we may combine personal information that you have given us with publicly available information about you to create a profile about you, your interests, and your preferences that help us personalize your experience of the Services.

We may collect, store, and process personal information from various categories. These may include identifiers (such as name, email address, and telephone number); demographic information (such as gender and age); payment card information; commercial information; Internet browsing or other electronic network activity information; geolocation data; audio, visual or similar information; and inferences drawn from any additional information we gather about you. Our listing of these categories does not mean that all categories or examples listed in each category are collected about everyone who uses the Services. We are providing a complete list in the spirit of transparency.

We collect this information:

  • Directly from you when you provide it to us, for example, by signing up for an Insider account, submitting an inquiry or comment to us online or via email, or providing us with your contact information to receive news and weather alerts.
  • We may supplement the information you provide directly with information received or otherwise obtained from third parties. This information may be received or obtained from our partners in sponsored content sections of the Services or from other third parties who provide us with user group and audience data they have compiled based on factors such as age, gender, geography, interests, and online activity. For example, we may receive information about you from a social media site if you connect to the Services through that site.
  • Automatically when you visit or use our Services or interact with us in other ways through cookies (small text files containing a string of characters sent to your computer) and similar tracking technologies (such as web beacons or pixels) that tell us which pages were visited and by how many users, the order in which pages were visited, and which hyperlinks were “clicked.” Not all of this information is personal information, as we define it above. Information collected by these technologies can be necessary for site navigation and performance or, in some instances, used by our business partners or us for targeted advertising purposes. We employ a tool from data-privacy software provider Osano that allows you to customize your cookie preferences. You can access the tool to change your preferences anytime by clicking the cookie icon in the bottom left-hand corner of any of our web pages. The tool will record when you have acknowledged our use of cookies and will periodically prompt you to consider your choices to ensure you stay up to date with changes to our privacy practices. The tool controls the marketing and analytical cookies set by using the Services. Essential cookies cannot be disabled from the cookies tool. You may have additional options to control how and whether cookies and similar technologies will be accepted through settings available from your chosen web browser. For more information on how to change these settings, please refer to your browser help menu. Be aware that if you choose to disable cookies at the web browser level, some features of the Services may not function properly or be accessible to you.

The Services may contain links to other websites, including the websites of our sponsors and partners. These third-party websites may collect information directly from you or set cookies or other tracking tools on your device. We are not responsible for the privacy practices these third parties employ when you visit their websites. If you have any questions about an advertisement or other targeted content received from a third party, you should contact the responsible provider directly.

How We Use the Information Collected

Your local media hub will generally be the primary user of information collected from you. This includes using that information on Services that might be on different platforms than the platform the information was initially provided. Other members of GMG may access your information where they perform services on behalf of your local media hub and, unless prohibited under applicable law, for use on their behalf for the purposes described in this privacy policy. Consistent with applicable law and the choices and controls that may be available to you, we may use information collected from you or from devices associated with you as follows:

  • To Provide and Manage the Products and Services You Request. This includes, for example, creating and maintaining your Insider account, processing your subscription, sending you confirmation notices regarding services you have requested, delivering localized weather and news alerts consistent with your choices, and notifying contest or sweepstakes winners.
  • To Contact You. We may periodically contact you with information about upcoming events and programs or other content that might interest you. You may opt out of receiving commercial email messages from us by following the instructions contained in those email messages.
  • To Better Understand Our Users and Improve Our Services. We may collect information on our users’ demographics, interests, and behavior and analyze that data. We do this to better understand and serve our users and to improve our products and services.
  • To Deliver Targeted Advertising. We may use your information, including your location information, to facilitate the delivery of targeted ads, promotions, and offers to you, on behalf of ourselves and advertisers, on and off the Services.
  • To Protect the Services and the Rights of Users and Others. We may use your personal information as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, and safety of property displayed on the Services, our employees or agents, or other users, and comply with applicable law.
  • In Limited Circumstances With Your Consent. Where we collect and use sensitive information, as that term is defined under applicable law, we will obtain your consent at or before the point of collection and disclose the specific purposes for which we intend to use that information.
  • To Comply with Legal Obligations, Resolve Disputes and Enforce Agreements. For example, to notify you regarding any concerns with the Services, including, as required by law, if personal information you provided to us is exposed to unauthorized third parties.

When we sponsor promotions or sweepstakes, or third parties’ sponsor promotions or sweepstakes in conjunction with us, either the third party or we will post any additional relevant privacy information in the official rules and/or registration area for the promotion or sweepstakes. To the extent it conflicts with this Privacy Policy, that privacy information will govern that promotion or sweepstakes.

How We Share Your Information

The categories of personal information that we may have shared for a business or commercial purpose include any of the categories of personal information shown in the Information We Collect section of this Privacy Policy.

We process certain categories of personal information for purposes of targeted advertising. Those include identifiers, demographic information, Internet browsing or other electronic network activity information, geolocation data, and inferences drawn from the above. We share these categories of personal information with our affiliates, business partners, certain service providers, and social media companies. You may opt out of this type of sharing by using the form here: Do Not Sell My Info.

The parties with whom we may share personal information are:

  • Affiliates. We may share information within GMG.
  • Business Partners. We may also share information with business partners to provide you with the Services you request. For example, if you choose to enter a contest or sweepstakes that we are hosting with third parties, we may provide your information to those third parties. We are not responsible for the privacy practices of these entities.
  • Service Providers. We may share information with and receive information from companies providing services on our behalf, such as advertising service providers, website or database hosting companies, address list hosting companies, email service providers, analytics companies, distribution companies, fulfillment companies, payment processing companies, and other similar vendors and services providers. We will not authorize these third parties to use your personal information except as necessary to provide services to us or for purposes authorized by us. Hearken is a third-party service provider.
  • Social Media Sites and Other Similar Platforms. When you direct us to share your personal information with or link the Services to third-party sites or platforms, such as social media sites, we will comply with that request. Please note that once we share your personal information with another company in this circumstance, the information received by the other company is controlled by that company and becomes subject to their privacy practices.
  • Information Posted to Public Forums. The Services may make chat rooms, forums, message boards, news groups, and/or other similar features available to users. Please remember that any information disclosed in these areas becomes public information. You should exercise caution when disclosing personal information about you or anyone else in such a forum. The Services do not accept responsibility for ensuring the privacy of any information you choose to disclose in these areas. Any content or information you provide to these areas of the Services is done at your own risk.
  • Other Parties When Required or Permitted by Law, or As Necessary to Protect Our Users and Services. We may use and share your personal information as we believe necessary or appropriate to protect the legal rights, privacy, safety, or property of the Services, our employees, or users, to detect, suppress or prevent fraud, or where otherwise required or permitted by law or legal process, including responding to requests from public authorities.
  • Other Parties in Connection With a Corporate Transaction. We reserve the right to transfer any information we have about you if we sell or transfer all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition, or in connection with a bankruptcy reorganization.

We may use information, including personal information, we have collected about you to create de-identified and/or aggregated data sets, such as de-identified demographic information, aggregated trends, reports, or statistics about how users interact with the Services. De-identified and aggregated information is used for various functions, including measuring visitors’ interest in and use of various portions or features of the Services we offer. Such de-identified and aggregated information does not identify you individually and is, therefore, not personal information for purposes of this Privacy Policy. We may disclose such de-identified or aggregated information in several ways, including to improve the Services, for our internal business purposes, and any other legally permissible purpose.

How Do We Protect Your Information?

We take the security of your personal information seriously. We implement commercially reasonable technical, physical, and administrative security measures to protect against the loss, misuse and unauthorized access, disclosure, alteration, and destruction of personal information collected through the Services.

Unfortunately, the transmission of information via the Internet is not completely secure. We cannot and do not guarantee that your personal information will never be accessed by an unauthorized party or otherwise breached during transmission through the Internet. Additionally, any contact with us by email or through the Services might not be secure. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on our websites.

If we believe the information you provided to us has been exposed to unauthorized third parties, we will notify you as required by law or upon our own choice. In the event of such unauthorized exposure, we expressly reserve the right to provide notice to you electronically via any email address you have provided if permitted by law. If you have reason to believe that your personal information, including any password you created for access to the Services, is no longer secure, please notify us immediately by contacting us via one of the methods listed below.

Consumer Rights Regarding Personal Information

Depending on where you live, you may have certain privacy rights created by law. While these laws vary depending on where you live, we strive to provide everyone the same basic level of privacy rights. Thus, the rights described here are available to anyone with whom we interact or about whom we collect personal information.

  • Right to Access. You have the right to confirm whether we are processing your personal information and to access your personal information if so.
  • Right to Correct Inaccuracies. You have the right to correct inaccuracies in the personal information we have collected, considering the nature of the personal information and the purposes of the processing. For example, in most circumstances, we cannot comply with requests to “change” or “correct” information submitted via public forums such as comment and chat features made available through the Services. Please take care with what you post.
  • Right to Delete. You have the right to request that we delete personal information provided by or obtained about you insofar as this is reasonably practicable. Please note that certain information may be excluded from your deletion request. For example, we may keep your information provided as part of a contest or sweepstakes where necessary for reporting purposes.
  • Right to Portability. You have the right to obtain a portable copy of the personal information that you have provided to us.

To exercise the rights to access, correct, or delete your personal information or to obtain a portable copy, as described above, please visit: DSAR Form.

Before completing your request, we may need to verify your identity. We will send you a link to verify your email address and may request additional documentation or information to verify your identity.

We do not charge a fee to process or respond to your consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

If you have any questions about your rights described above or want to appeal any decision regarding a request related to these rights, you may email us here or contact us as provided below.

Right to Opt Out of Targeted Advertising

As discussed above, we may use your personal information to facilitate the delivery of targeted ads, promotions, and offers to you, on behalf of ourselves and advertisers, on and off the Services. To tell us you want to opt out of the use of your personal information for targeted advertising, please visit: Do Not Sell My Info

Additional Privacy Choices

In addition to the rights discussed above, there are various other ways to access, update, or limit the personal information you provide to us.

  • Account Preferences. If you have an account on the Services, you can access and/or edit certain information you have provided to us by logging in. You may also edit your email notification practices here.
  • Additional Choices With Respect to Targeted Advertising. As described above, we may allow third parties to compile information or aggregate statistics from our use of tracking pixels, cookies, and other tracking technologies to help them assess the effectiveness of online marketing and enable our advertisers and us to deliver targeted advertising. This allows users to see advertising more likely to be of interest to them and advertisers to send their messages to people who are most likely to be receptive, improving both the viewer’s experience and the effectiveness of the ads. You can learn more about specific types of targeted advertising by visiting the Digital Advertising Alliance or our Ad Choices page. In addition to disabling cookies and other tracking technologies described above, you may opt out of receiving targeted advertising from participating ad networks, audience segment providers, ad-serving vendors, and other service providers by visiting websites operated by the Network Advertising Initiative and Digital Advertising Alliance.
  • Global Privacy Control. Some browsers feature a universal global privacy control (GPC) setting. You may choose to enable GPC where available. We will process a readable GPC signal as an opt-out request for targeted advertising.
  • Google® Analytics. Among other technologies, the services use Google Analytics, a service provided by Google, Inc. Google Analytics uses cookies to analyze how visitors interact with the Services. Google Analytics’s policy describes how it collects and processes data. You can opt out of Google Analytics collection and use of data generated using the Services by going to http://tools.google.com/dlpage/gaoptout.
  • Nielsen TV Ratings. Our properties may feature Nielsen proprietary measurement software, allowing you to contribute to market research, such as Nielsen TV Ratings. To learn more about the information that Nielsen software may collect and your choices, please see the Nielsen Digital Measurement Privacy Policy.
  • Unsubscribe from Emails. If you have registered to receive email updates or newsletters from us, you may opt out of receiving those communications by following the “unsubscribe” instructions included in the message.
  • Mobile Application Users. Due to differences between using apps and websites on mobile devices, you may need to take additional steps to disable tracking technologies in mobile apps. Many mobile devices allow you to opt out of targeted advertising for mobile apps using the settings within the mobile app or your mobile device. For more information, please check your mobile settings. You also may uninstall our apps using the standard uninstall process available on your mobile device or app marketplace.
  • Do-Not-Track Signals and Similar Mechanisms. Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, the Services currently do not act in response to these signals.

Other Important Information

  • No Use of Site by Children Under 13. The Services are not directed at or intended for use by children under 13 years old. If you are under the age of 13, you should not be visiting our websites or using the Services. We do not knowingly collect or retain personal information from children under 13. If you are under the age of 13 and are visiting or otherwise using the Services, please exit immediately and do not disclose or provide any personally identifiable information to us. If you are a parent or guardian who thinks your child has disclosed information to us, please contact us so that we can remove that information from our systems.
  • Parent or Guardian Permission for Certain Minors; Acceptance of Responsibility. If you are at least 13 years old but less than 18 years old and would like to use the Services, please ask your parent or legal guardian to review and agree to this Privacy Policy and the Terms of Use before you use any part of the Services. If you wish to use the Services, you must ask your parent or legal guardian for permission. Continued use of the Services indicates that you have obtained such consent; if you have not received such permission and continue to use the Services, you do so in violation of this Privacy Policy and the Terms of Use. If you are a parent or guardian who has granted your minor permission to use the Services, you agree and understand that you are responsible for monitoring and supervising your child’s usage.
  • Users Outside the United States. The Services are not directed at or intended for users outside the U.S. Please be advised that if you are located in the European Union or another region with laws related to data collection and use that may differ from U.S. law, your personal information submitted through the Services and transferred to the U.S. may not have the same legal data protection as in your jurisdiction.
  • Retention of Personal Information. We will retain your personal information collected through the Services for as long as we deem reasonably necessary or desirable unless any applicable law, rule, or regulation requires a different retention period. We reserve the right to delete or destroy any information collected, including personal information, at any time.
  • Links to Third Party Websites. Our Services contain links to other websites. Please be aware that we are not responsible for other websites’ privacy practices or content. We encourage our users to be aware when they leave our Services and to read the privacy policies of other websites and online services.
  • Non-Discrimination. We will not discriminate against you for exercising any of the rights listed in this privacy policy.

Changes to This Privacy Policy

We may update or change our privacy practices and this Privacy Policy from time to time. If we update the Privacy Policy, we will publish the revised policy on this page or as otherwise required by law. The date at the top of this page reflects the date of the most recent update. Your continued use of the Services after we make changes is deemed, to the extent allowed by law, to be acceptance of those changes, so please check the policy periodically for updates.

How to Contact Us

If you have questions about this privacy policy or the rights described above, email us at websitepolicy@grahammedia.com.