Version Date: May 6 2015


ZenoRadio LLC (“Company” or “we” or “us” or “our”) respects the privacy of its users
(“user” or “you”) whether you access our services via a telephone, wireless or wired
device, a partner’s website, through a browser, website widget, player, a mobile
application, ZenoPivot, or other media forms or media channels, related or connected
thereto as may be available (collectively, the “ZenoRadio Service”).

The following privacy policy (“Privacy Policy”) is designed to inform you, as a user of
the ZenoRadio Service, about the types of information that Company may gather or
collect from you in connection with your access to the ZenoRadio Service. It also is
intended to explain the conditions under which Company uses and discloses that
information, and your rights in relation to that information. Changes to this Privacy
Policy are discussed at the end of this document. Each time you access the
ZenoRadio Service, however, the current version of this Privacy Policy will apply.
Accordingly, each time you access the ZenoRadio Service you should check the date
of this Privacy Policy (which appears at the beginning of this document) and review
any changes since the last time you accessed the ZenoRadio Service.

The ZenoRadio Service is hosted in the United States of America (“United States” or
“U.S.”) and is subject to U.S. state and federal law. If you are accessing the
ZenoRadio Service from other jurisdictions, please be advised that you are
transferring your personal information to us in the United States, and by accessing
the ZenoRadio Service, you consent to that transfer and use of your personal
information in accordance with this Privacy Policy. You also agree to abide by the
applicable laws of applicable states and U.S. federal law concerning your access to
the ZenoRadio Service and your agreements with us. Any persons accessing the
ZenoRadio Service from any jurisdiction with laws or regulations governing personal
data collection, use and disclosure different from those of the jurisdictions mentioned
above may only use the ZenoRadio Service in a manner lawful in their jurisdiction. If
your access to the ZenoRadio Service would be unlawful in your jurisdiction, please
do not access the ZenoRadio Service.



The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of
children under 13 years of age. We do not knowingly collect or maintain personal
information from anyone under the age of 13, unless or except as permitted by law.
Any person who provides personal information through the ZenoRadio Service
represents to us that he or she is 13 years of age or older. If we learn that personal
information has been collected from a listener under 13 years of age through the
ZenoRadio Service, then we will take the appropriate steps to cause this information
to be deleted. If you are the parent or legal guardian of a child under 13 who has
become a user of the ZenoRadio Service or has otherwise transferred personal
information to us through the ZenoRadio Service, please contact Company using our
contact information below to have that child’s personal information deleted.


The ZenoRadio Service is an interactive service that allows users to access radio
stations around the world through a wide variety of means such as telephones,
browsers, website widgets, players, apps, and mobile devices. We collect and store
both Non-Personally-Identifying Information and Personally Identifying Information
(both defined below) about users and their habits, activities and preferences when
listening to radio programming offered through the ZenoRadio Service. Such
information is collected, retained and used as set forth in this Privacy Policy.


Users have the opportunity to speak directly with radio broadcasters through the
ZenoRadio Service and such broadcasters may initiate such contact. Such
communication may be conducted via traditional telephone communication, but may
also be conducted via a mobile device or browser, website widget, or player. In order
to conduct such communications (other than via traditional telephone
communication), a user must enable the microphone on the applicable device.
who hears your conversation once you are on the air and cannot control the
broadcasters from re-broadcasting such conversations.



Users of the Service Generally

“Non-Personally-Identifying Information” is information that, without the aid of
additional information, cannot be directly associated with a specific person.
“Personally-Identifying Information,” by contrast, is information such as a name,
email address or telephone number that, without more, can be directly associated
with a specific person.

Company gathers from users of the ZenoRadio Service Non-Personally-Identifying
Information of the sort that devices, depending on their settings, may make
available. That information includes, for users accessing the ZenoRadio Service over
the Internet, a user’s Internet Protocol (IP) address, operating system and browser
type, and the locations of the web pages the user views right before arriving at,
while navigating and immediately after leaving the ZenoRadio Service. If you use a
mobile device to access the ZenoRadio Service or download any of our applications,
we may collect device information (such as your mobile device ID, model and
manufacturer), operating system and version information, and IP address.

Company collects and analyzes Non-Personally-Identifying Information gathered
from users of the ZenoRadio Service to help Company better understand how the
ZenoRadio Service is being used, how to promote the ZenoRadio Service, and for the
delivery of targeted advertising. By identifying patterns and trends in usage,
including radio station listening habits and patterns, Company is able to better
design the ZenoRadio Service to improve users’ experiences, both in terms of
content, advertising and ease of use. From time to time, Company may also release
the Non-Personally-Identifying Information gathered from the ZenoRadio Service
users in the aggregate, such as by publishing a report on trends in the usage of the
ZenoRadio Service.

Web Cookies

A “Web Cookie” is a string of information which assigns you a unique identification
that a website stores on your computer or device, and that the user’s browser
provides each time the user logs on to or submits a query to the ZenoRadio Service.
We use cookies on the ZenoRadio Service to keep track of services you have used
and activities you have performed, radio stations you have listened to and listening
and call-in habits, to record, if applicable, registration information regarding your
login name and password, to record your use preferences, if applicable, to keep you
logged into the ZenoRadio Service, if applicable, and to facilitate purchase
procedures, if applicable. Company also uses Web Cookies to track the pages that
users visit and activities performed during each ZenoRadio Service session, both to
help Company improve users’ experiences and to help Company understand how the
ZenoRadio Service is being used. As with other Non-Personally-Identifying
Information gathered from users of the ZenoRadio Service, Company analyzes and
discloses in aggregated form information gathered using Web Cookies, so as to help
Company, its partners and others better understand how the ZenoRadio Service is

Flash Cookies

“Flash Cookies” are a form of persistent cookies technically called “Local Shared
Objects” (LSOs). Flash Cookies set an LSO to track your use of the ZenoRadio
Service. This tracking and storage can occur even after you have deleted your Web
Cookies or opted-out of network advertising. This tracking sets two cookies on your
computer – a standard cookie and a Flash Cookie. Flash Cookies can be considered to
be equivalent to “normal” Web Cookies, except for a few minor differences. With
Flash Cookies your data is stored in multiple places and it is restored once you delete
it. Normal Web Cookies can be managed via the preferences dialog of most web
browsers, but no similar utility for managing Flash Cookies is included in most web
browsers. It is possible for Flash Cookies to remain on your computer indefinitely
because an expiration date cannot be set for them. As with normal Web Cookies, a
website that placed the Flash Cookie can only access data that it captured; it is not
allowed to read Flash Cookies created by other websites.

Web Beacons

A “Web Beacon” is an object that is embedded in a web page that is usually invisible
to the user and allows website operators to check whether a user has viewed a
particular web page or an email. Company may use Web Beacons on the ZenoRadio
Service and in emails to count users who have visited particular pages, viewed
emails, and to deliver co-branded services. Web Beacons are not used to access
users’ Personally-Identifying Information; they are a technique Company may use to
compile aggregated statistics about the ZenoRadio Service usage. Web Beacons
collect only a limited set of information including a Web Cookie number, time and
date of a page or email view, and a description of the page or email on which the
Web Beacon resides. You may not decline Web Beacons, however, they can be
rendered ineffective by declining all Web Cookies or modifying your browser setting
to notify you each time a Web Cookie is tendered and permit you to accept or decline
Web Cookies on an individual basis.

Telephone Access

When you access the ZenoRadio Service via a telephone we obtain your telephone
number (unless the caller ID is blocked), keep track of services you have used and
activities you have performed, radio stations you have listened to and your listening
and call-in habits.


We or broadcasters may either directly or through third-party companies serve ads
to you when you access the ZenoRadio Service. Advertisers may use information
about your visits to and use of the ZenoRadio Service (including, without limitation,
stations accessed, listening habits, and location of accessing telephone number) that
are contained in Web Cookies, Flash Cookies or that we gather when you access the
ZenoRadio Service via a telephone (wireless or wired device) or other application or
access method in order to provide advertisements about goods and services that
may be of interest to you. We also allow advertisers to choose the characteristics of
listeners who will be presented with their advertisements and we may use any of the
non-personally identifiable attributes we have collected to select the appropriate
audience for those advertisements. Advertisements may be served via SMS/text
messages, voice messages, email, push messaging or other means from ZenoRadio
or affiliated third parties.

If you are accessing the ZenoRadio Service via the Internet, then using a tool
created by the Network Advertising Initiative, you can opt out of several third party
ad servers’ and networks’ Web Cookies simultaneously. If you would like more
information about this practice and to know your choices about not having this
information used by these companies, please follow the following link: Please contact us if you would
like to know the identity of the third-party advertising companies we are currently
using to serve ads.


One of the third party services that we use to track activity related to our service,
e.g., by placing cookies, is Google Analytics. We may use third-party vendors,
including Google, who use first-party cookies (such as the Google Analytics cookie)
and third-party cookies (such as the DoubleClick cookie) together to inform,
optimize, and serve ads based on your past activity on our websites and applications,
including Google Analytics for Display Advertising. If you do not want any
information to be collected and used by Google Analytics, you can install an opt-out
in your web browser ( and/or opt out
from Google Analytics for Display Advertising or the Google Display Network. You can
do so by using Google’s Ads Settings (

Aggregated and Non-Personally-Identifying Information

We may share aggregated and Non-Personally Identifying Information we collect
under any of the above circumstances. We may also share it with third parties and
our affiliate companies to develop and deliver targeted advertising on the ZenoRadio
Service and on websites of third parties. We may combine Non-Personally Identifying
Information we collect with additional Non-Personally Identifying Information
collected from other sources. We also may share aggregated information with third
parties, including advisors, advertisers and investors, for the purpose of conducting
general business analysis. For example, we may tell our advertisers the number of
visitors to the ZenoRadio Service and the most popular features or services
accessed. This information does not contain any Personally-Identifying Information
and may be used to develop website content and services that we hope you and
other listeners will find of interest and to target content and advertising.

Mobile Device Additional Terms
  • Geo-Location Information. Unless we have received your prior consent, we do
    not access or track any specific location-based information from your mobile
    device at any time while downloading or using our mobile applications or the
    ZenoRadio Services. However, based upon your IP address, the telephone
    number that you use to access the ZenoRadio Service, Wi Fi network data or
    cell tower triangulation, we may record general non-specific locations.
    However, we may also automatically collect anonymous information about
    you when you have geographical location tools on your Internet-enabled
    device which have not been disabled. We may also collect anonymous
    information about you whenever you deliberately interact with one of our ads
    containing a quick response code or follow instructions to send a text, or visit
    a URL. If you have geo-location tools on your Internet-enabled device which
    you have not disabled, we automatically receive information on your device’s
    location and may use it to comply with our contractual arrangements which
    restrict our sending certain programming channels outside of defined areas,
    such as when you want to listen to the ZenoRadio service while in another
  • Push Notifications. We may send you push notifications if you choose to
    receive them for other service-related matters. If you wish to opt-out from
    receiving these types of communications you may request to have them
    stopped at any time via preferences on your mobile device.
  • Mobile Analytics. We use mobile analytics software to allow us to better
    understand the functionality of our mobile software on your mobile device.
    This software may record information such as how often you use the
    application, the events that occur within the application, aggregated usage,
    performance data, and where the application was downloaded from.
Information Collection

As defined above, Personally-Identifying Information is information that can be
directly associated with a specific person. Company may collect PersonallyIdentifying
Information from and about the ZenoRadio Service users. Much of the
Personally-Identifying Information collected by Company about users is information
provided by users themselves when (1) registering for the ZenoRadio Service, (2)
dialing in to the ZenoRadio Service, (3) logging in with social network credentials,
(4) participating in polls, contests, surveys or other features of the ZenoRadio
Service, or responding to offers or advertisements on the ZenoRadio Service, (5)
communicating with us, or (6) signing up to receive newsletters or other
communications. That Personally Identifying Information may include each user’s
name, address, email address, and telephone number. We also may request
information about your interests and activities, your gender, age, date of birth,
language preference, hometown and other demographic information, and other
relevant information as determined by Company from time to time. Additionally,
when you access the ZenoRadio Service from a telephone or mobile device we may
also obtain your telephone number which may also be used for tracking your use of
the ZenoRadio Service. Users of the ZenoRadio Service are under no obligation to
provide Company with Personally-Identifying Information of any kind, though some
information, like a telephone number, may be provided automatically when using the
ZenoRadio Service. We may also use reverse look up functionality in order to obtain
the name of a person associated with a particular phone number.

We store Personally-Identifying Information and linked Non-Personally-Identifiable
Information that we gather about you through the ZenoRadio Service, through social
media, through linked social media applications, or that you give to us voluntarily in
any other way, and we may use it in accordance with this Privacy Policy.


Online Postings

We may provide areas or features on or via the ZenoRadio Service where you can
post reviews, provide audio or other content during interactive sessions, and other
information relating to your activities on or via the ZenoRadio Service. Such postings
are governed by our Terms of Use. In addition, such postings may appear on other
websites or when searches are executed on the subject of your posting. Also,
whenever you voluntarily disclose personal information on publicly-viewable web
pages, that information will be publicly available and can be collected and used by
others. For example, if you post your email address, you may receive unsolicited
messages. We cannot control who reads your posting or what other users may do
with the information you voluntarily post, so we encourage you to exercise discretion
and caution with respect to your personal information. USERS ASSUME ALL

Company Communications

We may occasionally use your name and email address to send you notifications
regarding new services or products offered by Company that we think you may find
valuable. If we have obtained proper authorization, we may also contact you via
email, telephone, text or push notification. We may also send you service-related
announcements from time to time through the general operation of the Service.
Generally, you may opt out of receiving such communications, though we reserve
the right to email you notices about your account even if you opt out of all voluntary
email notifications.

Social Media

We may provide you the option to connect your account, if applicable, on the
ZenoRadio Service to your account on some social networking sites (such as via
Facebook Connect) for the purpose of logging in, uploading information or enabling
certain features on the ZenoRadio Service. When logging in using your social
network credentials, such as your Facebook account, we may collect the PersonallyIdentifying
Information you have made publicly available in Facebook, such as your
name, profile picture, cover photo, username, gender, friends network, age range,
locale, friend list, and any other information you have made public. We may also
obtain other non-public information from the social network website with your
permission. Once connected, others may also be able to see information about your
social network, such as the size of your network and your friends, including common
friends. By connecting your account on the ZenoRadio Service to your account on
any social networking site, you hereby consent to the continuous release of
information about you to us. We will not send any of your account information to the
connected social networking site without first disclosing that to you. Each social
network may further allow you to set privacy controls around your information on
their system, and our collection of information will always follow such controls and
permissions. This feature is subject to continuous change and improvement by us
and each social networking site involved, and therefore the available features and
shared information are subject to change without notice to you.

Company Disclosures

Company will disclose Personally-Identifying Information under the following

  • Broadcasters/Advertisers. Through your access to the ZenoRadio Service,
    we collect a variety of information regarding how you use the ZenoRadio
    Service, and this information can be linked to Personally-Identifiable
    Information we have obtained about you. We may disclose this information to
    broadcasters of radio stations that you access via the ZenoRadio Service as
    well as to our advertisers. Broadcasters may use the information we disclose
    about you only for their internal purposes, such as improving programming,
    identifying you if you call in to a radio show, contacting you as a listener of
    their programming, in order to deliver advertising, and for related purposes.
  • Marketing Communications. Unless users opt-out from receiving Company
    marketing materials, Company may email, SMS/text, deliver recorded
    messages and otherwise communicate with users, or contact users via other
    means (all in compliance with applicable law), about products and services
    that Company believes may be of interest to them and Company also will
    provide users’ email information (and other contact information) to third
    parties, so that those third parties may directly contact users about additional
    products and services. If a user wishes to opt-out of receiving marketing
    materials from Company, user may do so by following the unsubscribe link in
    email communications, by going to your account settings (if applicable) or
    contacting us using the contact information below. Similarly, to cease having
    your email or other contact information provided to third parties, you may do
    so by going to your account settings (if applicable) or contacting us using the
    contact information below. Even after opting-out, a user may continue to
    receive marketing emails or other communications from third parties to whom
    Company already has provided the user’s email or other contact information.
    Users will be responsible for directly contacting such third parties to request
    cessation of further marketing communications.
  • Disclosure to Trusted Third Parties at Your Request. When using the
    ZenoRadio Service, we may provide you with advertisements, promotions,
    sweepstakes and offers from Company or third party providers. If you choose
    to accept any such offers, or agree to listen to or view additional information
    concerning the advertisement or promotion, or to be contacted by Company
    or a third-party, you may either (depending on the situation) be transferred
    to and directly provide your information in connection with the advertisement
    or promotion to such third party provider, or we will provide your information
    to the third party provider. Your information will not be transferred until you
    actually agree to listen to or view additional information, or agree to be
    contacted, or accept the offer, as the case may be. You may opt-out of such
    activities at any time up until this point. Please refer to the third party
    provider’s own privacy policy if you have any questions regarding how your
    information is used by such providers. Please be aware that these offers may
    be presented while using the ZenoRadio Service on your telephone (wired or
    wireless device), via a website or browser, website widget, player,
    application, or otherwise. We do this to provide a seamless experience.
    Although these offers may have the look and feel of the ZenoRadio Services,
    you will be submitting your information directly to the third-party advertiser.
    You agree that we will not be responsible or liable for any loss or damage of
    any sort incurred as the result of any such dealings, including the sharing of
    the information you supply to us with third party providers described here, or
    as the result of the presence of such providers on a Company website.
  • By Law or to Protect Rights. When we believe disclosure is appropriate in
    connection with efforts to investigate, prevent, or take other action regarding
    illegal activity, suspected fraud or other wrongdoing; to protect and defend
    the rights, property or safety of our Company, our users, our employees, or
    others; to comply with applicable law or cooperate with law enforcement; or
    to enforce our Terms of Use or other agreements or policies, in response to a
    subpoena or similar investigative demand, a court order, or a request for
    cooperation from a law enforcement or other government agency; to
    establish or exercise our legal rights; to defend against legal claims; or as
    otherwise required by law. In such cases, we may raise or waive any legal
    objection or right available to us.
  • Affiliates. We may share some or all of your personal information with our
    affiliates, in which case we will require those affiliates to honor this Privacy
    Policy. Affiliates would include a parent company or any subsidiaries, joint
    venture partners, or other companies that we control or that is under
    common control with us. Such intercompany transfers may be to and from
    the United States and any other country in which we or our agents maintain
    facilities for the purposes identified in this Privacy Policy, as well as for
    storage, processing or other business use as permitted under this Privacy
    Policy. By accessing or using the ZenoRadio Service you consent to the
    transfer of your personal information among these entities, including those
    located outside of your country of residence.
  • Third Party Service Providers. We may share your Personally-Identifying
    Information, which may include your name and contact information with our
    authorized service providers that perform certain services on our behalf.
    These services may include fulfilling orders, providing customer service and
    marketing assistance, performing business and sales analysis, supporting our
    website functionality, supporting or maintaining our service platform or
    technologies, and supporting contests, sweepstakes, surveys and other
    features offered through the ZenoRadio Service. We may also share your
    name, contact information and credit card information with our authorized
    service providers who process credit card payments. These service providers
    may have access to personal information needed to perform their functions
    but are not permitted to share or use such information for any other purpose.
  • Business Transfers; Bankruptcy. Company reserves the right to transfer
    all Personally-Identifying Information in its possession to a successor
    organization in the event of a merger, acquisition, or bankruptcy or other sale
    of all or a portion of Company’s assets. Other than to the extent ordered by a
    bankruptcy or other court, the use and disclosure of all transferred
    Personally-Identifying Information will be subject to this Privacy Policy, or to a
    new privacy policy if you are given notice of that new privacy policy and are
    given an opportunity to affirmatively opt-out of it. Personally-Identifying
    Information submitted or collected after a transfer, however, may be subject
    to a new privacy policy adopted by the successor organization.
General Use

We use the Personally-Identifying Information in the data we maintain about you,
and other information we obtain from your current and past activities in connection
with the ZenoRadio Service to: deliver the products and services that you have
requested, manage your account, if applicable, and provide you with customer
support, communicate with you by email, postal mail, telephone and/or mobile
devices about products or services that may be of interest to you either from us, our
affiliate companies or other third parties, develop and display content and
advertising tailored to your interests on the ZenoRadio Service and other sites,
resolve disputes, troubleshoot problems, measure consumer interest in our services,
inform you of updates, customize your experience, detect and protect us against
error, fraud and other criminal activity, enforce our Terms of Use, and as otherwise
described to you at the time of collection. At times, we may look across multiple
users to identify problems. In particular, we may examine your PersonallyIdentifying
Information to identify users using multiple listener IDs or aliases. We
may compare and review your Personally-Identifying Information for accuracy and to
detect errors and omissions. We may use financial information or payment method
to process payment for any purchases made through the ZenoRadio Service, enroll
you in the discount, rebate, and other programs in which you elect to participate, to
protect against or identify possible fraudulent transactions, and otherwise as needed
to manage our business.


From time to time, Company may offer users the opportunity to participate in
contests, giveaways and other promotions. Any information submitted in connection
with such activities will be treated in accordance with this Privacy Policy. From time
to time, Company may also ask users to participate in surveys designed to help
Company improve the ZenoRadio Service. Any Personally-Identifying Information
provided to Company in connection with any survey will be used only in relation to
that survey, and will be disclosed to third parties not bound by this Privacy Policy
only in non-personally-identifying, aggregated form.


Third parties are under no obligation to comply with this Privacy Policy, with respect
to Personally-Identifying Information that users provide directly to those third parties
or that those third parties collect for themselves. These third parties include
advertisers, providers of games, utilities, widgets and a variety of other third party
applications accessible through the ZenoRadio Service. Company neither owns nor
controls the third-parties and applications accessible through the ZenoRadio Service.
Thus, this Privacy Policy does not apply to information provided to or gathered by the
third parties. Before visiting a third-party, or using a third party application, whether
by means of a link on the ZenoRadio Service, directly through the ZenoRadio
Service, or otherwise, and before providing any Personally-Identifying Information to
any such third party, users should inform themselves of the privacy policies and
practices (if any) of the third parties, and should take those steps necessary to, in
those users’ discretion, protect their privacy.


We take security of your Personally-Identifying Information seriously and use
reasonable electronic, personnel, and physical measures to protect it from loss, theft,
alteration, or misuse. However, please be advised that even the best security
measures cannot fully eliminate all risks. We cannot guarantee that only authorized
persons will view your information. We are not responsible for third party
circumvention of any privacy settings or security measures.

Wireless Consent Policy

You authorize your wireless operator (AT&T, Sprint, T-Mobile, US Cellular, Verizon, or any other branded wireless operator) to use your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status details, if available, solely to allow verification of your identity and to compare information you have provided to ZenoRadio with your wireless operator account profile information for the duration of the business relationship. See our Privacy Policy for how we treat your data.

social media

By using this service you authorize your wireless operator (AT&T, Sprint, T-Mobile, US Cellular, Verizon, or any other branded wireless operator) to use your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status details, if available, solely to allow verification of your identity and to compare information you have provided to ZenoRadio with your wireless operator account profile information for the duration of the business relationship. See our Privacy Policy for how we treat your data.


Company may, in its sole discretion, change this Privacy Policy from time to time.
Any and all changes to Company’s Privacy Policy will be reflected on this page and
the date new versions are posted will be stated at the top of this Privacy Policy.
Unless stated otherwise, our current Privacy Policy applies to all information that we
have about you and your account, if applicable. Users should regularly check this
page for any changes to its Privacy Policy. Company will always post new versions of
the Privacy Policy on the ZenoRadio website.


California Civil Code Section 1798.83, also known as the “Shine The Light” law,
permits our users who are California residents to request and obtain from us once a
year, free of charge, information about the personal information (if any) we disclosed
to third parties for direct marketing purposes in the preceding calendar year. If
applicable, this information would include a list of the categories of personal
information that was shared and the names and addresses of all third parties with
which we shared information in the immediately preceding calendar year. If you are
a California resident and would like to make such a request, please submit your
request in writing to our privacy officer as listed below.


The ZenoRadio Service does not respond to “Do Not Track” signals or mechanisms.


If you have any questions regarding our Privacy Policy, please contact our privacy
officer at:

Privacy Officer

ZenoRadio LLC


Phone: (212) 822-3460