FRONTIER RADIO LLC PRIVACY POLICY

INTRODUCTION AND OVERVIEW

Last updated: July 19, 2024

Frontier Radio LLC is committed to respecting your privacy. This Privacy Policy ("Privacy Policy") explains how Frontier Radio LLC and its current affiliates (“Frontier Radio,” "we," "us," or "our"), collects, uses, shares, and protects your Personal Information whenever you access or use our products and services such as visiting our website(s) ("Website"), visiting our physical sites (“Site Visits”), calling customer service, or sending an email (collectively, the "Services").

Please read this Privacy Policy carefully to understand our policies and practices regarding how we handle your Personal Information (defined below), by continuing to access or use our Services, whether through our Site,you accept and agree to be bound by all terms of this Privacy Policy. If you do not agree with any portion of it, then you must not access or use the Services.

This Privacy Policy is part of the terms for the use of our Services.

This Privacy Policy does not apply to information collected or submitted through websites, mobile apps, or other online services maintained by other companies, even those linked from our Services or who advertise or provide links to our Services. You should review the privacy policies of those third parties. We are not responsible for the actions of those third parties, including their policies and practices with regard to your Personal Information.

This Privacy Policy explains:

• What information we collect and why we collect it.
• How we use cookies and similar technologies.
• How we use the information we collect.
• How we may disclose the information we collect.
• Your Rights and Choices.
• Information Security.
• Changes to this Privacy Policy.
  

1.   INFORMATION WE COLLECT

We collect two types of information about you: Personal Information and Non-Personal Information. "Personal Information" generally means information that identifies you. It may be defined more particularly in the laws described below. "Non-Personal Information" is all other information—it does not identify you directly but may be linkable to you. When you interact with us, we may ask you to supply us with Personal Information so that we can provide, enhance, and personalize our Services and marketing efforts. We may combine the Personal Information you provide us with publicly available information about you, as well as information from other sources. When we do, that combined information will be considered and treated as Personal Information.

We take your privacy very seriously, and we have adopted this Privacy Policy to explain what Personal Information may be collected on our Services, how we use this Personal Information, and under what circumstances we may disclose such Personal Information to third parties. This Privacy Policy, together with the Terms of Use posted on our Services, sets forth the general rules and policies governing your use of our Services. Depending on your activities when visiting our Services, you may be required to agree to additional terms and conditions.

1. 1.   INFORMATION YOU PROVIDE DIRECTLY TO US

We may collect Personal Information directly from you in a number of ways through our Website.

Website and On-Line Services

You are not required to provide Personal Data to visit the Website. We may collect any content, record, or electronic communication of any kind that you elect to send to us as part of that process, so that we may provide you with such products and services, communicate with you regarding our products and services, and send you information and materials for marketing and other purposes.

Site Visits

To make a Site Visit, we require the following categories of information:

• Name
• Email Address. By providing your email address, you have the option to receive marketing emails. You have the choice to opt-out from marketing emails as further described below.
• Phone Number
• Physical Mailing Address and Zip Code
• Company Name

Site Monitoring

If you park your vehicle at one of our sites, we may collect information about your vehicle, including an image of the vehicle, the vehicle's make, model, and license plate number. We use this information for safety, security, fraud prevention, and other similar purposes.

For site visits to Rio Hotel & Casino please refer to their privacy policy:

https://www.riolasvegas.com/privacy-policy

For site visits to Harrah’s Hotel & Casino please refer to their privacy policy:

https://www.caesars.com/corporate/privacy

For site visits to any other property please refer to their privacy policy.

Other Contacts

When you contact us by any method, we may collect and log the details of your request, concern or inquiry, and the contact information you provide, in order to respond to you. This information is logged in our internal systems maintained by us or by third-party providers on our behalf. For example, if you contact us, we will use your email address to respond.

Video/Audio Surveillance

Frontier Radio employs video surveillance technology both inside and outside certain sites. Video surveillance technology may also allow for the use of facial recognition technology. We may maintain surveillance recordings for at least seven days and may maintain them for longer as necessary to meet our legal obligations and as contemplated by our policies.

Website Interactions

We use third-party vendors and their technologies to track how our Website visitors use our Website and services such as the links and content you view on our Website. These vendors allow us to monitor your use of our Website live and record that usage session, which we use to help improve our Website.

Embedded Content

The Website may incorporate content, including feeds scripts embedded in the Website’s code and visible content (for example, videos), provided by third parties including YouTube and Meta.  In some cases, those third parties collect data about how you interact with their content. For example, YouTube may collect or otherwise have access to usage data on videos embedded on the Website, as described in YouTube’s Privacy Policy. See https://policies.google.com/privacy for more information about YouTube's Personal Data collection, use and sharing practices.

Payment Card Information

Purchases of products or services must be made by credit, debit card, check, or wire-transfer. All information is provided directly to our third-party payment processors, which vary based on the products and services requested. If you elect to make a purchase, you will need to submit your card number, expiration date, security code, and billing address as well as other information as may be required by the applicable purchasing service. Payment by credit or debit card is subject to the approval of the card issuer, and Frontier Radio will not be liable in any way if a card issuer refuses to accept a credit or debit card for any reason.

Social Media

Our Website may allow you to connect and share information with various social media platforms, such as Meta, YouTube, and LinkedIn. These features may require us to implement cookies, plug-ins, and/or APIs provided by such social media platforms to facilitate communications and features. We may share information that you provide us or that we may collect about your use of the Website with these platforms, and such information becomes subject to their privacy and data policies when we do so. We encourage you to visit the privacy policies of these platforms for further information:

• Meta's Data Policy at https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0
• YouTube's Privacy Policy at https://policies.google.com/privacy
• LinkedIn Privacy Policy at https://www.linkedin.com/legal/privacy-policy

In addition, by choosing to use any third-party social media platform or choosing to share content or communications with any social media platform, you allow us to share information with the designated social media platform. We cannot control any policies or terms of such third-party platform. As a result, we cannot be responsible for any use of your information or content by a third-party platform, which you use at your own risk.

We may also use the advertising services and networks offered by these social media platforms, such as Meta, YouTube, and LinkedIn, to deliver ad content. We may share Personal Data with these social media platforms to allow such platforms to identify similar platform users that may be interested in our ad content. Use of these services requires the social media platform to implement cookies and/or pixels to deliver ads to you while online with such platforms.

We may also monitor our presence on social media ourselves or through third-party vendors, which means we may view your pictures or postings on social media that are from or relating to Frontier Radio. We may contact you from time to time through Personal Data that we may have or receive through the third-party social media platform or otherwise in order to request permission to use your content on our Website or for other purposes.

1. 2.   INFORMATION WE COLLECT AUTOMATICALLY FROM YOU

We may collect the following categories of Personal Information automatically through your use of the Services:

• Online Identifiers, such as IP address and domain name.
• Device information, such as hardware model, operating system version, device event information such as crashes, system activity, hardware settings, unique device identifiers, and mobile network information including phone number. We may associate your device identifiers or phone number with your Account.
• Internet or Electronic Network Activity Information, such as browsing history, search history, browser type, browser language, the date and time of your request and referral URL, sites you visited before and after visiting our Site, cookies and other technology that may uniquely identify your browser or your Account (more information about cookies is below), web beacons, and pixel tags.
  

1. 3.   COOKIES AND SIMILAR TECHNOLOGIES

This Website may use both cookies that we implement, and third-party cookies implemented by our vendors to facilitate and enhance the user experience on the Website. "Cookies" are small pieces of information that are stored by your browser on your device. In general, these can make the Internet more useful by storing information about your preferences and other useful information on a particular system. They can show us, for example, popular pages, conversion rates, viewing patterns, click-through, and other information that can be used to improve, operate, and monitor our Sites and other aspects of our Services. Most web browsers automatically accept cookies, but you can disable this function so that your browser will not accept cookies. Please be aware that disabling the cookie function may impact your use and enjoyment of the Website.

2.   HOW WE USE YOUR PERSONAL INFORMATION

We use information we collect from you for a number of purposes and in a number of ways.

We will use it for any purpose indicated at the time it is collected, e.g., if you purchase a Service, we use the information to supply the Service; or if you provide us with information to use a Service, we may review the information to assist in making decisions.

We may use information we collect from you (alone or combined with other information) to communicate with you related to the Services, better provide Services, improve our Sites, understand your needs, improve our products, manage content and advertising, send you offers and information, make Service recommendations, maintain Site security, comply with law, protect intellectual property, and measure the effectiveness of our Services. For example, certain content or advertising may be connected to particular Site pages or videos or otherwise connected to your use of the Services.

By using our Services, including our Site, or providing information to us through any means, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. This includes posting information on the Site, or sending an email to the email address you provided to us, or both.

2.1.   Information We Disclose

We are committed to maintaining your trust, and we want you to understand when and with whom we may share information collected about you.

With Your Consent

With your consent, we may share your Personal Information with third-party business partners and others included in the notice we gave to obtain your consent.

Authorized Service Providers, Agents, Consultants, Vendors, and Contractors

We share your information with service providers and contractors for business purposes to help us with specialized services such as third-party payment processing, customer support, email and text message deployment, business analytics, marketing, and data processing. For example, we may share information with partners that analyze data regarding performance, or provide applications and services.

Affiliates and Subsidiaries

We disclose your Personal Information among the Frontier Radio LLC. family, including Marnell Companies LLC and its current affiliates and subsidiaries, for business purposes to help us provide the Services and to support our internal and business operations, including marketing, analytics, security, and advertising.

Analytics & Marketing Partners

We may share your Personal Information, including without limitation your contact information with entities that perform marketing or data aggregation services on our behalf, or with which we or an affiliate has joint marketing arrangements. We may share Personal Information, including without limitation your device information, location, usage data, and IP address, to analytics-based technologies to assist with personalization, advertising, and marketing. These technologies capture how you interact with our Services through behavioral metrics to improve and market our products and services.

• Google Analytics. We use Google Analytics on our Sites to help us analyze traffic and improve services. For more information on Google Analytics’ processing of Personal Information, please see https://www.google.com/policies/privacy/partners/. You may opt out of the use of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
  

2.2.   Business Transfers

We reserve the right to transfer information about you to a successor organization if, for example, we transfer the ownership of some or all our assets, transfer operations of a Site, enter bankruptcy, or merge with another organization. If such a transfer occurs, we will use reasonable efforts to direct the transferee to use Personal Information in a manner consistent with this Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your Personal Information with any inquiries concerning the processing of that information. After transfer we will not be liable or responsible for the acts or omissions of the transferee.

2.3.   Legal Requirements

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

2.4.   Protecting Our Sites and Users

If we believe that anyone’s use of the Services may damage us, our Services, or any person or property, we may use or disclose relevant Personal Information to prevent such harm. We also may disclose information about you when we, in good faith, believe disclosure is appropriate in order to: prevent or investigate a possible crime, such as fraud or identity theft; protect the security of our Site; or other agreements; or protect our own rights or property or the rights, property, or safety of our users or others.

2.5.   Non-Personal Information

We share Non-Personal Information and may do so for any reason. Likewise, we may share anonymized information (information that has had all data identifying an individual removed) with third parties, including to help us develop content and services we hope you will find of interest or to help these third parties develop their own products and service offerings. This sharing of anonymized information will not include Personal Information.

3.   PUBLICLY AVAILABLE INFORMATION

Please be advised that some information you provide may be publicly accessible, such as information posted in forums, or comment sections ("Publicly Available Information"). Content, including such posted information, comments, feedback, and notes that you choose to post through features of our Services available to the public becomes public information for both us and other users to use and share. Please do not disclose Personal Information unless you intend for that data to become public. We reserve the right, but do not have the obligation, to review and monitor such posting or any other content on our Services, and to remove postings or content that may be viewed as inappropriate or offensive to others. You further agree that we are under no obligation of confidentiality, express or implied, with respect to the Publicly Available Information and may use this information as described in this Privacy Policy.

4.   INFORMATION RETENTION

We will only keep Personal Information for as long as necessary to fulfill the purposes for which we collected the information, as described in this Privacy Policy, unless a longer retention period is required or permitted by law (for example, for tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize your information, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

5.   NEWSLETTERS AND PROMOTIONAL EMAILS

We may use your e-mail address or other methods to send you newsletters and messages about new business features, special offers, promotional announcements, consumer surveys, and other correspondence concerning our Services. If you no longer want to receive marketing promotions from us, click on the UNSUBSCRIBE link in our email communications.

6.   YOUR RIGHTS AND CHOICES

People have different privacy concerns. Our goal is to be clear about what information we collect and how we use and disclose it so that you can make meaningful choices about how it is used.

6.1.   Accessing and Updating Your Personal Information

If you choose to share personal information with us, you may update or amend your information by contacting us. Please note that we may retain some information about you in order to address legal or security concerns. For example, some of your information may remain in back-up storage even if you ask us to delete it. In some cases, you may be entitled under local laws to access or object to the processing of information that we hold relating to you.

We may reject requests that are unreasonable in our sole and absolute discretion, unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be impractical (for instance, requests concerning information residing on backup systems).

Access, correction, or deletion requests can be made by contacting us as directed below in the CONTACTING US section.

6.2.   Do Not Track

Your browser may offer you a "Do Not Track" option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time, which means that we collect information about your online activity while you are using our Services. We do not collect online activity after you leave our Services. We will continue to evaluate potential responses to “Do Not Track: signals in light of industry developments or legal changes.

Below are lists of Personal Data required by California law identifying the Personal Data collected, where they are sourced, why they are collected, and if we disclose such Personal Data, the categories of service providers or other third parties to whom we disclose them:

Although the categories of information above are collected for the designated purposes, Personal Data may be otherwise used for the purposes set forth in this Policy to the extent such use is consistent with the purpose for which it is collected.

7.   INFORMATION SECURITY

We take information security very seriously and use reasonable administrative, technical, and physical measures to protect your Personal Information from unauthorized access. Unfortunately, no security system can be guaranteed to be 100% secure. Accordingly, we cannot guarantee the security of your information and cannot assume liability for improper access to it.

8.   GOVERNING LAW AND NOTICE TO NON-US USERS

Our Services are solely intended for individuals located within the United States and its territories and are subject to U.S. law. If you are located outside of the United States and its territories, please do not use the Services. By utilizing the Services, you consent to the transfer of your data to the United States and its maintenance in the United States.

We may transfer the Personal Information we collect about you to countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Policy.

9.   REGIONAL PRIVACY RIGHTS

Depending on where you live and subject to certain exceptions, you may have some or all of the following rights:

• Right to Access: The right to confirm whether or not we are processing your Personal Information and to access such information.
• Right to Know: The right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices.
• Right to Request Correction: The right to request that we correct inaccurate Personal Information that we maintain about you.
• Right to Request Deletion: The right to request that we delete your Personal Information that we have collected from or about you.
• Right to Opt Out of Targeted Advertising: The right to opt out of the processing of your Personal Information obtained from your activities on nonaffiliated websites or online applications for the purposes of targeted advertising.
• Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights.

To submit a request for information regarding your rights under a specific state’s privacy law, to exercise your rights, or as applicable, to appeal a consumer rights action, please refer to the CONSUMER REQUESTS AND VERIFICATION section below.

Please note that to protect your information and the integrity of our products, we may need to verify your identity before processing your request. In some cases, we may need to collect additional information to verify your identity, such as a government issued ID.

9.1.   SHINE THE LIGHT

Under California Civil Code Section 1798.83 ("Shine the Light"), California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, e-mail and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us as directed in the CONTACTING US section below with a reference to California Disclosure Information.

9.2.   CALIFORNIA CONSUMER PRIVACY ACT OF 2018, AS REVISED AND UPDATED BY THE CALIFORNIA PRIVACY RIGHTS ACT (COLLECTIVELY, "CCPA")

A.   Collection, Disclosure, and Retention of Personal Information

The Personal Information we collect and the sources from which we collect is described above in INFORMATION WE COLLECT. The Personal Information we disclose for business or commercial purposes is described above in INFORMATION WE DISCLOSE. The length of time that we retain your Personal Information is described above in INFORMATION RETENTION.

B.   Selling and Sharing Personal Information

We do not sell or share your Personal Information in exchange for monetary consideration; however, we may use tools described above such as Google Analytics, which may be interpreted as sharing your Personal Information. As such, please reference the above INFORMATION WE DISCLOSE for opt out rights regarding these tools.

C.   CCPA Consumer Rights

Under CCPA, consumers have certain rights regarding their Personal Information, as described below.

• Right of Access: You have the right to request, twice in a 12-month period, that we disclose to you the following information about you, limited to the preceding twelve (12) months:
  • The categories of Personal Information that we collected about you;
  • The categories of sources from which the Personal Information is collected;
  • The business or commercial purpose for collecting or selling Personal Information;
  • The categories of third parties with whom we share Personal Information;
  • The specific pieces of Personal Information that we have collected about you;
  • The categories of Personal Information that we disclosed about you for a business purpose or sold to third-parties; and
  • For each category of Personal Information identified, the categories of third parties to whom the information was disclosed or sold.
• Right of Deletion: You have the right to request that we delete any Personal Information about you which we have collected from you, subject to exceptions within the law.
• Right to Opt-Out: You have the right to opt-out of the disclosure of Personal Information about you for monetary or other valuable consideration. However, we do not sell your Personal Information in exchange for monetary consideration. We may use tools described above such as Google Analytics, which may be interpreted as sharing your Personal Information. As such, please see the above sections for more information regarding opting out of the use of these tools.
• Right to Opt-In: We do not have actual knowledge that we collect, share, or sell the Personal Information of minors under the age of 16 without proper consent of a parent or guardian.
• Right to Limit Use and Disclosure of Sensitive Personal Information: You may request specific limitations on further sharing, use, or disclosure of your Sensitive Personal Information that is collected or processed for certain reasons outside of providing the Services. However, we do not collect or process Sensitive Personal Information for any of these reasons.
• Right to Correction: You have the right to request that we maintain accurate Personal Information about you and correct any Personal Information about you which we have collected from you, subject to exceptions within the law.

If you would like to exercise any of the rights provided, please refer to the CONSUMER REQUESTS AND VERIFICATION section below.

10.   CONSUMER REQUESTS AND VERIFICATION

10.1.   Right to Non-Discrimination

We may not discriminate against you because you exercise any of your privacy rights contained in this Privacy Policy including, but not limited to:

• Denying goods or services to you;
• Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Providing a different level or quality of goods or services to you; or
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
  

10.2.   Verifying Requests

You may request to exercise your rights of access, deletion, or correction by contacting us as described in the CONTACTING US section below. To help protect your privacy and maintain security, we will take steps to verify your identity before processing your request. If you request access to or deletion of your Personal Information, we may require you to provide any of the following information: name, company name, email address, telephone number, or postal address. When you make such a request, you can expect the following:

• As required under applicable law, we will verify your identity. You will need to provide us with your email address and full name. We may ask for additional information if needed.
• We will confirm that you want your information accessed, corrected, and/or deleted.
• We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us at the webpage or phone number listed below.
• We will respond to your request within 45 days upon receipt of your request. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
• In certain cases, a request for access, correction, or deletion may be denied. For example, if we cannot verify your identity, the law requires that we maintain the information, or if we need the information for internal purposes such as providing Services or completing an order. If we deny your request, we will explain why we denied it and delete any other information that is not protected and subject to denial.
  

10.3.   Authorized Agents

You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as described in the CONTACTING US section below to make a request on your behalf. Even if you choose to use an agent, we may, as permitted by law, require:

• The authorized agent to provide proof that you provided signed permission to the authorized agent to submit the request;
• You to verify your identity directly with us; or
• You to directly confirm with us that you provided the authorized agent permission to submit the request.
  

11.   PRIVACY POLICY UPDATES

This Privacy Policy is subject to occasional revision, and we may, with or without prior notice to you, change its terms in our sole discretion. If we make any material changes in the way we collect, use, or disclose your Personal Information, we may post a notice on the Website or send you an email to the email address associated with your company. The most current version of this Privacy Policy can be viewed by visiting our Website and clicking on "Privacy Policy" located at the bottom of the page. The most current version of the Privacy Policy will take effect immediately and supersede all previous versions. The effective date of this Privacy Policy is stated above. Continued access or use of our Services following the effective date of any changes shall indicate your acceptance of such changes. If you do not agree to the modified provisions of this Privacy Policy, you should discontinue your access and use of the Services.

12.   CONTACTING US

If you have questions concerning your Account or this Privacy Policy, including the treatment of your Personal Information, or to exercise your privacy rights, please contact us via email at info@FrontierRadioLV.com, or at the following:

Frontier Radio LLC.

222 Via Marnell Way

Las Vegas, Nevada

Attn: Legal Department

PHONE NUMBER 702-739-2940

If you submit your request via email, please identify in the subject line the type of request that you are submitting (Request to Access Data, Request to Know Categories Collected/Shared, Request to Delete) and provide your name. The email address of the request will be used as contact information for you.