This Privacy Policy (the “Privacy Policy” or the “Policy”) applies to and describes how
information obtained from visitors of or to the https://citadelfm.com website (the “Website”) is
collected, used, and disclosed.
Effective Date: This Privacy Policy was last updated on April 20, 2022.
The Website provides you with information about Ingress Audio LLC d/b/a Citadel FM (“Citadel,”
“us,” “our,” or “we”) and our Services, hereinafter defined, which are offered. The Website also
offers visitors the ability to:
(a) review information associated with Citadel;
(b) request to enter into a services partnership with Citadel; and/or
(c) request to enter into an advertising contract with Citadel
(the “Services”). This policy applies to visitors to our websites, clients, customers and users of
our Services, as well as individuals who have supplied us with details requesting information
about future Services (individually, “ you,” “your,” “yours,” “our customers,” or “our clients”).
Your use of the Website is subject to this Policy and the Terms and Conditions, including any
applicable limitations on damages and the resolution of disputes contained therein. The Terms
and Conditions are incorporated by reference into this Policy as if fully restated herein.
1. INFORMATION COLLECTION
Citadel may collect information about you directly from you and from third parties, as well as
automatically through your use of the Website.
Information collected directly from you:
When you use the Website, certain areas or features may require you to provide personal
information such as your name, email address, phone number, business name, venue, or other
requested identifying information (“Personally Identifiable Information” or “PII”), and
information about your desired Services (e.g. services, advertising, or technical support).
Information collected automatically:
Citadel may automatically collect the following information about you and your use of the Website,
and/or Services through cookies, web beacons, and other technologies:
(a) your domain name;
(b) your browser type and operating system;
(c) web pages you view;
(d) links you click;
(e) your IP address;
(f) the length of time you visit the Website; and
(g) the referring URL or the webpage that led you to the Website.
Citadel does not link the information that is automatically collected to any PII you submit while on
the Website. Please see the section “Cookies and Other Tracking Mechanisms” below for more
information.
2. HOW YOUR INFORMATION IS USED
Citadel may use your information, including your PII, for the following purposes:
(a) to fulfill or meet the reason the user provided the information. For example, if a
user shares their name and contact information to request technical support or ask
a question about Services, Citadel will use that PII to respond to your inquiry.
Citadel may also save your information to facilitate new Service requests;
(b) to provide, support, personalize, and develop the Website and the Services;
(c) to create, maintain, customize, and secure your account;
(d) to process your requests;
(e) to provide you with support and to respond to your inquiries, including to
investigate and address your concerns and monitor and improve responses;
(f) to help maintain the safety, security, and integrity of the Website, Services,
databases, and other technology assets and the business;
(g) to respond to law enforcement requests and as required by applicable law, court
order, or governmental regulations;
(h) as described to you when collecting your PII; and/or
(i) to evaluate or conduct a merger, divestiture, restructuring, reorganization,
dissolution, or other sale or transfer of some or all of Citadel’s assets, whether as
a going concern or as part of bankruptcy, liquidation, or similar proceeding, in
which PII held by Citadel about Website users is among the assets transferred.
3. SHARING INFORMATION
Citadel may share your PII with third parties in the following instances:
Sharing for Legal Purposes:
Citadel shall disclose PII when required by law or under the good-faith belief that such action is
necessary under applicable law. Citadel and the Citadel Entities may disclose PII in order to
establish or exercise its or their legal rights or defend against legal claims. Citadel also may share
information in order to investigate, prevent, or take action regarding illegal activities, suspected
fraud, to protect Citadel property or interests or that of their agents and employees, and to protect
guests of an independently owned and operated location or venue, to promote personal safety,
and/or to promote the safety of the public.
Sharing Aggregate Information (non-personally identifiable):
Citadel may share some aggregated demographic information (e.g. ages and zip codes) with
some of its partners. This information is not linked to any PII. Citadel may use third-party
advertising companies to serve ads on its behalf. These companies may employ cookies and
action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness.
Sharing with Third-Party Service Providers:
Citadel may disclose information about individual users to third parties who provide services to
Citadel or have a contractual relationship with Citadel. These third parties provide a variety of
services to Citadel, including, without limitation, web traffic tracking and internet marketing
campaigns. In addition, these third-party services may include enhancing the information Citadel
can collect about users. Citadel may also use third-party email providers to assist with sending
marketing emails for Citadel. Any PII that Citadel shares with any third-party service provider may
only be used to provide services to Citadel and the service providers will not be given permission
to use such information for other purposes such as contacting clients directly.
International Transfers
Information about you may be transferred to, or accessed by, Citadel Entities located around the
world. Some of the Citadel Entities may be located in countries that do not provide an equivalent
level of protection as your home country.
Sharing in Business Transitions:
In the event Citadel goes through a business transition, such as a merger, an acquisition by
another company, or a sale of all or a portion of its assets, PII of users collected by Citadel through
the Website will, in most instances, be part of the assets transferred. Users will be notified via
prominent notice on the Website for thirty (30) days after a transfer of their PII, if PII will be used
contrary to this policy. If as a result of the business transition, the users’ PII will be used in a
manner different from that stated at the time of collection, users will be given the option to
discontinue sharing their information. As a result of the business transition, you may elect to
discontinue the sharing of your PII and such information will not be transferred to the new entity.
However, nothing in this Privacy Policy is intended to interfere with the ability of Citadel to transfer
all or part of its business and/or assets (including the Website), for any purposes, without any
limitation whatsoever, and Citadel specifically reserves the right to transfer or share a copy of PII
collected from the Website to the entity to whom that portion of its business relating to that
information is transferred.
Cookies and Other Tracking Mechanisms:
Citadel and/or third-party service providers may use cookies and other tracking mechanisms to
track information about your use of the Website. Citadel may combine this information with other
PII collected from you (and third-party service providers may do so on behalf of Citadel).
Cookies:
Cookies are alphanumeric identifiers that Citadel transfers to your computer’s hard drive through
your web browser for record-keeping purposes. Some cookies allow Citadel to make it easier for
you to navigate the Website and Service, while others are used to enable a faster log-in process
or to allow Citadel to track your activities at the Website. There are two types of cookies: session
and persistent cookies.
● Session Cookies. Session cookies exist only during an online session. They
disappear from your computer when you close your browser or turn off your computer.
Citadel may use session cookies to allow its systems to uniquely identify you during
a session or while you are logged into the Website. This allows Citadel to process
your online transactions and requests and verify your identity, after you have logged
in, as you move through the Website.
● Persistent Cookies. Persistent cookies remain on your computer after you have
closed your browser or turned off your computer. Citadel may use persistent cookies
to track aggregate and statistical information about user activity.
Disabling Cookies:
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser
options to block them in the future. The Help portion of the toolbar on most browsers will tell you
how to prevent your computer from accepting new cookies, how to have the browser notify you
when you receive a new cookie, or how to disable cookies altogether. Visitors to the Website who
disable cookies will be able to browse certain areas of the Website, but some features may not
function.
Clear GIFs, pixel tags, and other technologies:
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to
cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on
web pages. Citadel may use clear GIFs (aka web beacons, web bugs, or pixel tags), in connection
with the Website to, among other things, track the activities of Website visitors, help Citadel
manage content, and compile statistics about Website usage. Citadel and third-party service
providers also use clear GIFs in HTML emails to customers of Citadel to help Citadel track email
response rates, identify when emails are viewed, and track whether emails are forwarded, for
example. Third party vendors may also use pixels and tags on social media posts, ads, and
chatbots to track click through rates to the Citadel Website.
Third-Party Analytics:
Citadel may use automated devices and applications, such as Google Analytics and reCAPTCA,
to evaluate usage of the Website and, to the extent permitted, any application(s) used to access
Citadel information. Citadel also may use other analytic means to evaluate the Service. Citadel
uses these tools to help it improve the Services, performance, and user experiences. Third-party
entities may also use cookies and other tracking technologies to perform or enhance their
services.
Do-Not-Track:
Currently, the Website does not recognize browser “do-not-track” requests. You may, however,
disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may optout of targeted advertising by following the instructions in the Third-Party Ad Networks section
below.
Third-Party Ad Networks:
Citadel may use third parties, such as network advertisers, to serve advertisements on third-party
websites or other media (e.g., social media platforms). This enables Citadel and these third
parties to target advertisements to you for services offered by Citadel in which you might be
interested. Third-party ad network providers, advertisers, sponsors, and/or traffic measurement
services may use cookies, JavaScript, links, web beacons (including clear GIFs), Flash LSOs,
and other tracking technologies to measure the effectiveness of their ads and to personalize
advertising content to you. These third-party cookies and other technologies are governed by
each third party’s specific privacy policy.
Users in the United States may opt out of many third-party ad networks. For example, you may
go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting
out of interest-based advertising and their choices regarding having information used by DAA
companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page
for information about opting out of interest-based advertising and their choices regarding having
information used by third-party companies who are NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI
Consumer Opt-Out Page will remove you from those companies’ delivery of interest-based
content or ads to you, but it does not mean you will no longer receive any advertising through the
Website or on other third-party websites. Even if you opt out from one or more companies listed
on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page, you may continue to
receive advertisements, for example, based on the particular website that you are viewing (i.e.,
contextually based ads). Also, if your browsers are configured to reject cookies when you opt out
on the DAA or NAI websites, your opt out may not be effective. Additional information is available
on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.
4. COMMUNICATIONS FROM THE
WEBSITE AND YOUR CHOICES
Transactions and Service Announcements:
Users who request information through the Website may receive a number of emails and/or text
messages throughout the transaction process and they may sometimes receive phone calls from
Citadel to ensure smooth transactions. Citadel may also occasionally send out Service-related
announcements, for instance, if Service on the Website is temporarily suspended for
maintenance. Generally, these communications are not promotional in nature.
Communications and Updates:
Out of respect for the privacy of users, Citadel presents the option to not receive these types of
communications, as explained in the Choice and Opt-out section below.
Choice and Opt-out:
A user can change their opt-in or opt-out status in the following ways:
● From an email: Click on the “Unsubscribe” link within the email.
● You may additionally unsubscribe by sending your request to legal@citadelfm.com.
5. SECURITY
Citadel takes commercially reasonable precautions to protect users’ information. When users
submit information via the Website, Citadel takes steps to protect users’ information both online
and offline.
Although Citadel endeavors to create secure and reliable Websites and to safeguard against
unauthorized disclosures of information, Citadel cannot assure you that PII collected will never be
disclosed in a manner that is inconsistent with this Privacy Policy.
You hereby acknowledge and agree that, to the extent permissible by applicable law, Citadel is
not responsible for any intercepted information sent via the internet and you hereby release, to
the extent permissible by applicable law, Citadel from any and all claims arising out of or related
to the use of any intercepted information in a manner that may violate this Privacy Policy, the law,
and/or your personal privacy.
6. EXTERNAL LINKS
The Website may contain links to (or be hosted on) other websites maintained by third parties.
Please be aware that Citadel exercises no control over linked sites or other sites and the Citadel
Entities as defined in the Terms and Conditions are not responsible for the privacy practices or
the content of such sites. Each linked site or other site maintains its own independent privacy and
data collection policies and procedures and its own terms and conditions or terms of use, and you
are encouraged to view the privacy policies and terms and conditions or terms of use of these
other sites before providing any Personally Identifiable Information and/or other information. You
hereby acknowledge and agree that the Citadel Entities are not responsible for the privacy
practices, data collection policies and procedures, or the content of such third-party sites, and you
hereby release the Citadel Entities from any and all claims arising out of or related to the privacy
practices, data collection policies and procedures, and/or the content of such third-party sites.
7. WEBSITE USAGE BY MINORS
Use of the Website is not designed for children under the age of eighteen (18). If Citadel discovers
that a minor has provided PII to Citadel, Citadel will delete such information from its systems.
If you discover that your child or ward who is under the age of eighteen (18) or any other child
under the age of eighteen (18) has provided PII through the Website and you wish that such PII
be deleted, please contact Citadel at:
18 Shipyard Drive
Suite 2A-50
Hingham, MA 02043
legal@citadelfm.com
You hereby acknowledge and agree that the Citadel Entities are not responsible for any PII
provided by any child under the age of eighteen (18) sent via the Website without the Citadel
Entities’ permission or knowledge, and you hereby release the Citadel Entities from any and all
claims arising out of or related to the use of any such information in a manner that may violate
this Privacy Policy, the law, and/or your personal privacy.
8. CHANGES TO THIS POLICY
Except to the extent limited by applicable law, Citadel reserves the right to update this Policy to
reflect changes to our information practices by prominently posting notice of the update on our
Website and, to the extent required, obtaining your consent. Any updates will become effective
immediately after posting the updates to this Policy and apply to all information collected about
you or will become effective, when required, upon your consent. You agree that you will review
this Policy periodically. If we make any changes to this Policy, we will change the “Last Updated”
date above. You are free to decide whether or not to accept a modified version of this Policy, but
accepting this Policy, as modified, is required for you to continue using our Services and
accessing our website. If you do not agree to the terms of this Policy or any modified version
of this Policy, your sole recourse is to terminate your use of Citadel’s Services and its
Website immediately.
If we make any changes to this Policy that materially impact previously collected information about
you, we will obtain your prior express consent.
If you have any questions about this Policy or information Citadel has collected about you, please
contact Citadel FM by email at legal@citadelfm.com.
To the extent specific states, countries, or jurisdictions have rules related to privacy and security
and/or Privacy Policies and/or the collection and use of information, this Privacy Policy and the
corresponding Terms of Use/Terms and Conditions are intended to comply fully therewith. To the
extent a court of competent jurisdiction determines that this Privacy Policy and/or the
corresponding Terms of Use/Terms and Conditions do not conform therewith this Privacy Policy
and the corresponding Terms of Use/Terms and Conditions should be deemed reformed to
whatever extent necessary to comply therewith.