WERS Privacy Policy

Last Modified Date: August 31, 2017

This Privacy Policy (the “Privacy Policy”) explains the information we collect from visitors to the WERS web site  (the “Site”) or the various social media sites or RSS feeds that offer our content (each a “Platform,” and collectively together with this Site, “the WERS Platforms” ).  By visiting this Site or accessing any of these Platforms you consent to the terms of this Privacy Policy.

This Privacy Policy describes, among other things, the types of information collected about you when you visit the WERS Platforms, how your information may be used and when it may be disclosed, how you can control the use and disclosure of your information, and how your information is protected.

1.  Scope of this Privacy Policy

Please note that this Privacy Policy applies exclusively to the WERS Platforms.  WERS is owned and operated by Emerson College.

This Privacy Policy does not apply to any other websites operated or managed by Emerson College or to any other information collected by Emerson College in any manner

If you access our content via the WERS mobile app, that app is operated by Triton Digital.  You can access the privacy policy governing your use of the app at https://www.tritondigital.com/privacy-policy-services.  For purposes of this Privacy Policy, the mobile app is not part of the WERS Platform.   However, WERS does receive information about users of the app in aggregated form which we use in the manner described in Section 4H below.

We also recommend reviewing the Terms of Use governing your use of the WERS Platforms.

2.  Information Collected

A.  Information you provide directly to WERS.

You are not required to provide information about yourself when you visit the WERS Platforms, however, we may ask for certain information when you access certain services.  For instance, if you sign up for a contest or our newsletter, we will ask you for your name and contact information.  If you send us an email we may collect your email address.  If you register for certain services, we may also collect other information about you including, in addition to the information requested during the registration process, playlists you create, your listening habits, or other information based on your use of the WERS Platforms.

B.  Information we collect automatically.

In addition to the information you provide directly, WERS may collect certain information automatically, regardless of whether you register or request any services, including the following:

• Your browser type and operating system;
• Your Internet Protocol (IP) address, which is the number automatically assigned to your computer or other device whenever you access the Internet and that can sometimes be used to derive your general geographic area;
• Websites you visited before and after visiting the WERS Platforms;
• Web pages and advertisements you view and links you click on the WERS Platforms;
• Unique identifiers, including mobile device identification numbers, which can identify the physical location of such devices in accordance with applicable law;
• Information collected through cookies, web beacons, and other similar technologies. Click here for more information.
• Interactions with audio and video content, such as the type of content listened to (including music applications such as iTunes, Spotify and Last.fm) and content viewed;
• Information about your interactions with email messages, such as the links clicked and whether messages were opened or forwarded;
• Upon request, your bandwidth speed and information about the software programs installed on your computer; and
• Standard server log information.

C.  Information we obtain from other sources

Where permitted by applicable law, we may collect information about you from other sources, including through interactive applications (e.g. third party services that enable the delivery of our live radio feed and embedded audio and video players (the “Music Vendors”), the company operating the WERS mobile app, and social media platforms such as Facebook or Twitter.  We also may collect information about you from commercially available sources (such as data aggregators and public databases).  The following are examples of the type of information we may collect from other sources:

• Name, postal address, and telephone number;
• Demographic data, such as age, gender, and income level;
• If you access our content via one of the WER Platforms  such as Facebook, Twitter,  Instagram, or YouTube, your username and password for those services and other information available about you on those services such as your online purchasing behavior;
• Publicly-observed data, such as activities on blogs, videos, and other online postings; and
• Other navigation data, such as websites visited and advertisements viewed or clicked on.

This Privacy Policy does not cover the practices of third parties including those that may disclose information to WERS.

SPECIAL NOTE REGARDING OUR USE OF GOOGLE ANALYTICS

This Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer to help Google (and us)  analyze how visitors use the Site. (You can read more about cookies below INSERT JUMP LINK).  The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States . Google will use this information for the purpose of evaluating your use of the Site, compiling reports on Site activity for us and those providing other services relating to activity on the Site and internet usage generally. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this Site. By using this Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

D.  Combining Information

Please note that all of the information we collect about you may be combined.  This allows us, among other things, to tailor our communications to you and to develop rich online content and services across the WERS Platforms.

3.  Use of Information

We only use payment and identity verification information, such as credit card numbers, driver’s license numbers, social security numbers, or comparable national identifiers as necessary for completing a particular transaction or fulfilling a service (e.g., when you make a contribution or  awarding prizes to contest winners) or as otherwise required by law.

Generally, we use other information collected about you to:

• Fulfill your requests for products, services, and information, and to authorize a purchase, send you electronic newsletters, and complete a transaction that you have requested;
• Enable you to participate in features such sweepstakes or creating playlists;
• Provide you with special offers and promotional materials;
• Analyze the use of the WERS Platforms and information about visitors to the WERS Platforms to understand and improve our offerings and, in accordance with our sharing policies discussed below, to produce anonymous or aggregated data and statistics that might help third parties develop their own products and service offerings;
• Customize the content you see when you visit the WERS Platforms;
• Develop and provide advertising tailored to your interests;
• Prevent potentially prohibited or illegal activities and otherwise in accordance with the WERS Terms of Use and
• For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

If you decide to make a donation to WERS via the Site, we collect your payment information.  If you use our option to create repeating donations, we will store your payment information.

4.  The Sharing of Information Collected

WERS is committed to maintaining your trust and we want you to understand when and with whom we may share information collected about you.

A.  Authorized Third Party Service Providers

We share your contact information with third party vendors who help us with specialized services, including customer support, business analytics, marketing, suppression list management, data processing.  These third parties use your contact information to help us provide our services, and not for any other purpose. Also, authorized third party service providers may collect non-contact information about your use of our services with cookies, web beacons and other similar technologies that may be used to deliver advertisements tailored to your interests. For more information, the discussion below on cookies, web beacons, and other similar technologies including Do Not Track).

B.  Sweepstakes, Contests, or Promotions

When you choose to enter a sweepstake, contest, or other promotion, and in accordance with the terms and conditions of a specific promotion, your information may be disclosed to our sponsors and/or to third parties who assist in administering the promotion, including assistance with winner selection, prize fulfillment, and aggregated data analysis.  Your information also may be disclosed as required by law, such as disclosure on a winners list.  Further, by entering a promotion, you are agreeing to the official rules that govern that promotion, including allowing us and our sponsors to use your name, voice, and likeness in advertising and marketing associated with the promotion in accordance with applicable law.  All terms applicable to the particular promotion will be made available to you at the time you enter the promotion.

C.  Music Vendors and Social Media Sites

Our music vendors refer to the vendors who enable our live music feed or the embedded player to hear our programs.  These services are provided by Triton Digital and Tune Genie (collectively referred to as “Music Vendors”).  By listening to our content via the WERS Platforms, you are authorizing us to share any information we collect or any information our Music Vendors may collect via their services.  You should review the Music Vendors’ privacy policies to learn more about the information they collect and with whom they share this information.   http://info.tunegenie.com/privacy-policy.html https://www.tritondigital.com/privacy-policy

If you access our content via Facebook, Twitter, or any other social media platform (collectively referred to as “Social Media Platforms”), you are also authorizing us to share and receive information about you with that platform.  Each platform has its own privacy policy concerning what information they collect, how they use it, and with whom they will share it.  Please review the relevant policies of these social media platforms carefully.   You can find some of these privacy policies here:  Facebook:  https://www.facebook.com/about/basics   Twitter:  https://twitter.com/privacy?lang=en  Instagram:   https://www.instagram.com/about/legal/privacy/  You Tube:   https://www.youtube.com/static?template=privacy_guidelines

D.  Business Transfers

We may share your information in connection with a substantial corporate transaction, such as the sale of the WERS, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.

E.  Legal Requirements

We may disclose information about our users, including contact information, to respond to subpoenas, court orders, legal process, and other law enforcement measures, and in order to comply with other legal obligations, such as FCC requirements.

F.  Sharing Information To Protect WERS, our Users, and Emerson College

We may disclose information to protect and defend the legal rights, interests, and safety of WERS, our users, and Emerson College including  employees, agents, and contractors (including enforcing our agreements); to protect the safety and security of users of the WERS Platforms, Emerson College and its employees, agents, and contractors, and members of the public.

G.  Sharing Information With Advertisers

When you use this Site or the WERS Platforms you will find third-party advertisements.  We share information with advertisers as in the privacy policies of our Music Vendors and Social Media Platforms.

In addition, information collected about your interactions with audio and video content is shared with our Music Vendors and Social Media Platforms, who may sell this information to advertisers as they disclose in their respective privacy policies.

H.  Aggregated Or Anonymized Data 

Finally, we also may share aggregated or anonymized information with third parties to help us develop content and services we hope will interest you, or to help these third parties develop their own product and service offerings, including targeted marketing.

5.  Your Choices

You can choose to enjoy content and features on the WERS Platforms without providing us directly with any information about you; however, as described above, some information may be collected automatically or be requested so that you can take advantage of certain features and services offered on the WERS Platforms.

You can opt out of receiving commercial email or text messages from us by following the instructions contained in any such message or by contacting us at info@wers.org.  Please note that even if you unsubscribe to commercial messages, we may still need to send you communications relating to your use of the WERS Platforms, such as service announcements.

You have choices about whether cookies and other similar technologies are placed on your computer or mobile device. We describe these practices below in our overview of cookies, web beacons, and other similar technologies (including Do Not Track).

Finally, you may also have choices about the collection and use of your information by third parties or by Social Media Platforms, with respect to displaying relevant advertisements.  You should review the privacy policies of these third parties and platforms.

6.  Access

If you choose to share contact information with us, you may have the opportunity to update that information by contacting us at info@wers.org.  If you ask us to shut down your account or delete your information, we will disable your account within a reasonable period of time.  Please note that we may need to retain some information about you in order to satisfy our legal and security obligations.  For example, some of your information may remain in backup storage even if you ask us to delete it. In some cases, you may be entitled under local law to access or object to the processing of information that we hold, which specifically relates to you.

7.  Protection of Information

We are committed to protecting your information.  We have adopted commercially reasonable technical, administrative, and physical procedures to help protect your information from loss, misuse, unauthorized access and alteration.  Please note that no data transmission or storage can be guaranteed to be 100% secure.  We want you to feel confident using the WERS Platforms, but we cannot ensure or warrant the security of any information you transmit to us.

8.  The WERS Platforms Are Governed By U.S. Law

WERS is headquartered in the United States.  If you access the WERS Platform from outside the United States, the laws of the country from which you access our content may not be equivalent to the laws of the United States.  You acknowledge that WERS may not comply with the laws of every jurisdiction and expressly agree that the laws of any other jurisdiction do not apply to the WERS Platform.  You expressly consent to the collection, transfer, storage, and processing of your information in accordance with this Privacy Policy.

9.  California Visitors

For additional information for residents of the State of California, please see Section 19 below.

10.  Privacy Protections for Children

As a not-for-profit college, Emerson College is not required to comply with the Children’s Online Privacy Protection Act.  Nevertheless, WERS does not knowingly collect information over visitors under the age of 13. If you are aware of any user under the age of 13 from whom we have collected personal identifying information, please contact us (insert link) so that we may address this issue immediately.

11.  User-Generated Content

The WERS Platforms may enable users to submit their own content for use in contests, social media, blogs, over-the-air radio broadcasts, online audio and video streams, message boards, and other functions.  Publication of user-generated content on the WERS Platforms is subject to our Terms of Use.  Please remember that any information you disclose becomes public information.  Exercise caution when choosing to disclose your contact, financial, and other information in a submission.  We cannot prevent such information from being used in a manner that may violate this Privacy Policy, the law, or your personal privacy and safety.  You should also be aware that we may also engage a third party to provide some of the services associated with the blogs, message boards and similar functions.  This third party will collect and host the information that you submit to the WERS Platform, but will not use any of this information for purposes other than providing the service.

12.  Third Party Websites and Services

Please note that there may be links to other websites and services on the WERS Platforms.  We are not responsible for the privacy practices of those websites, and we recommend that you review the privacy policies of each website that you visit. When you select a link to a third party website from the WERS Platform (e.g., if you click on one of the advertising links on the Site), you will be leaving the WERS Platform.  Any information that you disclose on the third party website will be governed by that website’s privacy policy.

13.  Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in our practices and service offerings. If we modify our Privacy Policy, we will update the “Last Modified Date” and such changes will be effective upon posting.  Your continued use of the WERS Platforms constitutes your acceptance of the Privacy Policy in effect at the time you visit.

14.  Questions

If you have questions regarding this Privacy Policy, please contact us at info@wers.org and we will endeavor to respond to your request within a reasonable period of time.  You may also submit questions or comments using the postal address listed below:

WERS Radio

Attention:  Webmaster

120 Boylston Street

Boston, Mass. 02116

We are committed to working with you to obtain a fair resolution to any privacy concern.

General Information Regarding Privacy

15. Cookies, Web Beacons and Other Similar Technologies

Cookies are small amounts of data that are stored in separate files within your computer’s Internet browser.  Cookies are accessed and recorded by the websites you visit, and by the companies that show advertisements on these websites, so that they can recognize the same browser.

Web beacons (sometimes called transparent GIFs, clear GIFs, or web bugs) are small strings of code that provide a way for us to deliver a small graphic image (usually invisible) on a web page or in an email.  Web beacons can recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed.

A.  How Cookies, Web Beacons and Other Similar Technologies Are Used On The WERS Platforms 

The WERS Platforms use cookies, web beacons and other similar technologies for the following general purposes:

• To help us recognize your browser as a previous visitor and to save and remember any preferences that may have been set while your browser was visiting one of our services.
• To help us customize the content and advertisements you are shown while visiting the WERS Platforms.
• To help measure and research the effectiveness of our online content, features, advertisements and other communications.
• WERS may also allow third parties to place their own cookies within your browser in order to serve you relevant advertising online, to help us measure traffic and effectiveness as described above, to provide you with access to social media networks, functionality and services, and to allow us to conduct surveys and research in which you agree to participate. (For instance, our Music Partners and Social Media Partners place their cookies on the WERS Platforms to support social network integration and functionality and for use according to their respective privacy policies.).
• To help us improve your experience on the WERS Platform, including helping provide you with content customized to your interests.  They also help us understand whether users read email messages and click on links contained in those messages so that we can deliver relevant content and offers.  Our web beacons may collect some contact information (e.g., the email address associated with an email that contains a web beacon).
• The WERS Platform also may include third party web beacons.  These web beacons allow third party service providers to collect certain information such as your IP address, your browser type, and the web page that you visited before arriving at and after leaving the WERS Platforms.  These service providers process the information they collect to audit, research, and report information about the WERS Platforms and advertisements viewed on thereon.
• Authorized third party service providers may collect non-contact information about your visits to the WERS Platforms with cookies, web beacons and other similar technologies that may be used to deliver advertisements or marketing tailored to your interests.  These third parties may collect information about your online activities over time and across different websites.  You should visit the privacy policies of our Music Vendors and Social Media Platforms to learn how you may opt out of targeted advertisements on their sites.

By continuing to use the WERS Platforms, you consent to our use of cookies, web beacons and other similar technologies as described above.

B.  How Third Parties Use Cookies and Other Similar Technologies

Some of the advertisements you see on the WERS Platforms are delivered by third parties who also collect information through cookies, web beacons and other similar technologies about your online activities, either on the WERS Platforms or across the Internet, so that they may understand your interests and deliver advertisements that are tailored to your interests. These third parties include advertisers, advertising agencies, and ad networks that may collect information when you view or interact with one of their advertisements.

Please note that WERS does not have access to the information these third parties may collect about your interests in order to deliver relevant advertising.  The information practices of these third parties are not covered by this Privacy Policy.  Third parties that may serve, track and/or analyze advertisements on our services, and thereby may collect information about your online activities on such services include, but are not limited to our Music Vendors and Social Media Platforms.

C.  Do Not Track

Some Internet browsers include the ability to transmit “Do Not Track” signals.  Since uniform standards for “Do Not Track” signals have not been adopted, the WERS Platforms do not process or respond to “Do Not Track” signals.

D.  Mobile Devices

The WERS Platforms are available on mobile devices via Soundcloud.com.   You should review their privacy policy to learn how they manage your PII across multiple platforms and how they manage location tracking information.    https://soundcloud.com/pages/privacy

Please note that triton (now soundcloud) has still not updated their Privacy policy since 2016.   

E.  Managing Cookies

Whether cookies are placed on your computer is something you can control.  This section provides some information about how you can manage the cookies that are placed on your computer by WERS or third parties.

F.  Managing Third Parties’ Behaviorally Targeted Advertising Cookies on Your Computer

A number of companies that use cookies to collect information about your online activities by using web-based advertising are members of the Network Advertising Initiative (“NAI).  https://www.networkadvertising.org/understanding-online-advertising/what-are-my-options.  The NAI offers a single location to opt out of receiving tailored ads from member companies.  To opt out of information collection by NAI member companies, or to obtain information about the technologies they use or their own privacy policies, please visit the NAI consumer opt-out page.  Also, through the Digital Advertising Alliance (“DAA”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of and greater control over ads that are customized based on their online behavior across different websites.  To make choices about interest-based ads from participating third parties, please visit the DAA consumer opt-out page.

If you opt out of having your information used to deliver advertisements tailored to your interests, you will continue to see advertisements on the WERS Platforms but these advertisements may not be as relevant to you.

G.  Adjusting Your Browser Settings

You have the option to set your browser to accept all cookies, reject all cookies, notify you when a cookie is set, and delete cookies periodically (including third party behaviorally targeted advertising cookies).  Each browser is different, so please refer to the guide below that describes how to set the cookie options on a number of different browser types.  If your browser is not listed below, please visit All About Cookies, where you may find more information about your specific browser, or select the “Help” menu in your browser.

Web beacons are generally used in conjunction with cookies, so if your browser is set to reject cookies, or if you delete cookies, web beacons will not be able to track your activity as you navigate between websites.

It is up to you whether to allow us or third parties to send you cookies, but if you block cookies, you may not be able to view or access some, or all, the features on the WERS Platforms.

Below you will find directions to help you disable cookies in some of the most popular desktop browsers and mobile browsers.

Mozilla Firefox version 3.5 or later

• In the “Tools” menu, select “Options”
• Under the “Firefox will:” dropdown, select “Use custom settings for history”
• Uncheck the “Accept Cookies from Sites” box to block all cookies, or
• Click the “Exceptions” button to enter specific websites that you wish to allow/disallow to set cookies

Internet Explorer version 6 or later

• In the “Tools” menu, select “Internet Options”
• Click the “Privacy” tab
• Move the “Settings” slider up or down to adjust your cookie acceptance settings (moving the slider all the way to the top will block all cookies) or
• Click the “Sites” button to enter specific websites that you wish to allow/disallow to set cookies

Google Chrome version 4 or later

• Click the wrench icon in the top right of your browser window
• Select “Options”
• Click the “Under the Hood” tab
• Click the “Content Settings” button
• Click the option to “Block sites from setting any data” to block all cookies Or
• Click the “Exceptions” button to enter specific websites that you wish to allow/disallow to set cookies

Safari version 4 or later

• Click the geared wheel icon in the top right of your browser window
• Select “Preferences”
• Select the “Security” tab
• Under “Accept Cookies:”, click the “Never” option to block all cookies

H.  Managing Flash Cookies

Flash cookies, also called local shared objects (LSOs), function similarly to standard cookies except that they are often larger and are downloaded to a computer or mobile device by the Adobe Flash Player. In some cases, these Flash cookies can be managed through browser settings. Adobe also provides a means of controlling Flash cookies on its Flash Player: Setting Manager page.

16.  Third Party Online Advertising

The advertisements you see on the WERS Platforms are delivered by third parties who also collect information through their own cookies, web beacons and other similar technologies about your online activities, either on our services or across the Internet, in an effort to understand your interests and deliver advertisements that are tailored to your interests. These third parties include advertisers, advertising agencies and ad networks that may collect information about you when you view or interact with one of their advertisements and may collect information about your online activities over time and across different websites.

Third parties that may serve, track and/or analyze ads on our services, and thereby may collect information on such services about your online activities for the purpose of delivering tailored ads to you include, but are not limited to, A9, Admob, Criteo , Google/DFP, Jivox , LiveRail, Mixpo, PointRoll, Sizmek, Yieldbot and YieldMo.  WERS does not have access to the information these third parties may collect about your interests, in order to deliver relevant advertising to you, and the information practices of these third parties are not covered by this Privacy Policy.  These companies may offer a way for you to choose not to have your information used for advertising purposes.  You can find more information by clicking on the company names above and following the links to each company’s website.

In addition, some of these companies are members of the Network Advertising Initiative (“NAI”), which offers a single location for consumers to opt out of receiving tailored advertisements from member companies.  To learn more and opt out of information collection by NAI member companies, please visit the NAI Consumer Opt-Out page. Also, through the Digital Advertising Alliance (“DAA”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of and greater control over advertisements that are delivered based on their online behavior across the WERS Platforms.  WERS is committed to complying with the DAA’s Self-Regulatory Program for Online Behavioral Advertising. To learn more, and make choices about interest-based advertisements from participating third parties, please visit the DAA Consumer Opt-Out page.

In addition, WERS works with third parties to help us track the advertisements that are delivered to you; in particular, to control the number of times you receive the same advertisement and to analyze the effectiveness of advertising on the WERS Platforms.  Third parties that use cookies, web beacons and other similar technologies to help us with traffic measurement, research and analytics include Google Analytics.  We do not share your contact information with these third parties.

If you opt out of having your information used to deliver advertisements tailored to your interests, you will continue to see advertisements on our services, but these advertisements may not be as relevant to you.

17.  Video Services and Social Networking Policy

Your video content viewing activities may be collected through your use of the WERS Platforms.  By viewing our video content, you are consenting to share your video activities with others, including what videos you have watched on the WERS Platforms.  Sharing this information will allow you to take advantage of social networking and other features on the WERS Platforms.

18.  WERS FCC Requirements

If you send a written communication (including an email) regarding the programming or operation of WERS, your communication may be placed in the public inspection file of that station or made available via electronic file access at the station. In either case, your communication may be subject to review by members of the general public, as required by Federal Communications Commission (“FCC”) regulations.  Be advised that we are not responsible for information that may be disclosed if your communication is made available for review by members of the general public in compliance with FCC regulations.

19.  California Visitors

Residents of the State of California may request a list of all third parties to which WERS has disclosed certain information during the preceding year for the third parties’ direct marketing purposes.  If you are a California resident and would like such a list, please contact us at (insert link).  If you are a California resident under 18 years of age, and a registered user of any website where this policy is posted, you may request removal of content or information you have publicly posted.  Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you posted and there may be circumstances in which the law does not require or allow removal, even if requested.

For all requests, you must put the statement “Your California Privacy Rights” in the subject field of your request and indicate if the information was collected via the Site or the Social Media Platform.  You must also include your full name, street address, city, state, and zip code. We will not accept requests via telephone, postal mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

20.   Contact Us

If you need further assistance, please contact us at info@wers.org If you would prefer to submit your questions or comments by postal mail, please send a letter to the following address:

WERS Radio

Attention:  Webmaster

120 Boylston Street

Boston, Mass. 02116