Effective Date: July 21, 2021
WHAT INFORMATION WE COLLECT AND WHY
Information You Provide: We collect information that you provide to us directly, including your business contact information such as name, company name, job title, company address, zip code or state of residence, email address, and phone number. We will also collect information you provide regarding your advertising and business goals with SXM Media, such as the category of advertising you may be interested in, the types of media where you have advertised in the past, and any other topics or information you choose to share with us. If you enroll in AQ Academy or other similar programs offered through SXM Media (“Programs”), we will collect information about your progress through the Programs, including your progression through any courses or learning tracks, scores and performance, and other information you submit or provide through those Programs. If you post comments, queries, or feedback on the Site or send them to us electronically (either directly or through a survey) or through the postal mail we will receive the information contained in those communications. We use the information you provide as outlined in this Section to respond to your comments or inquiries, to send you badges and certificates of Program completion, information about the Programs, including new and updated Program offerings, information you requested from us or that we think you may find interesting or useful about our business and the Services we provide. You may follow the unsubscribe instructions contained in the promotional or marketing emails we send you to stop receiving these communications.
Technical and Device Information: We also collect information from you automatically when you interact with the Site (“Site Usage Data”). Such information may include without limitation the date and time you visit the Site, time spent on the Site, type of browser, and IP address, device identifiers (such as a mobile advertising ID, MAC address, or other unique identifier associated with your device), the type of device used to access the Site and what pages were visited. We use Site Usage Data to assess, administer and improve the visitor experience to the Site, to troubleshoot and maintain the Site, and to enhance the understanding and marketing of our business, including by measuring and analyzing the effectiveness of our advertising efforts.
WHO DO WE SHARE YOUR INFORMATION WITH AND WHY
Service Providers: We may share your information with third party suppliers to process and facilitate the purposes for which we may use the information, such as website and database hosting companies; learning management and other software providers website analytics companies; CRM service providers; providers of advertising services, helpdesk or other customer service providers; security firms; and marketing, print and email delivery services. We may use third party suppliers for the collection of Site Usage Data and for the collection of personal information that you enter during your visit to the Site. We do not sell your contact information or other personal information we collect from you to third parties for their own purposes.
Legal and Security Purposes: In response to a legal obligation or a valid subpoena or court order, we may disclose your information, including personal information, to law enforcement, government or quasi-government agencies, or in other instances to comply with the law or orders of courts or other governmental authorities, to enforce or apply the terms of our agreements with you, or to act under exigent circumstances to protect our property, rights or safety, users of the Services, the Site, or any third party.
Sharing of Deidentified, Aggregated, or Anonymized Information: We may share with third parties, and/or service providers deidentified, aggregated, or anonymized information we receive or collect, such as demographic information, information about the computer or device from which you access the Site, or information about your interactions with the Site. We share such information for a variety of reasons, such as to analyze Site usage, improve the Site and your user experience and or for other similar purposes.
Sharing of Device Information: We may share information we gather from devices you use to access the Site with our third-party vendors or service providers. We share this information for a variety of purposes such as analyzing how users interact with the Site and debugging problems with the Site.
UPDATING OR CHANGING YOUR INFORMATION You may modify, correct, change or update the information you provide to us by emailing us with your request at email@example.com.
SAFEGUARDING YOUR INFORMATION We use a variety of procedural, physical, and technological safeguards to protect your information from unauthorized access, use, or disclosure. All personal information is stored under secure measures with limited access by authorized individuals.
We will retain and use the information we collect for as long as necessary to fulfill the purposes for which it was collected (as specified in this Policy or as otherwise disclosed to users outside of this Policy), including, to provide the Site to you, comply with our legal obligations, resolve disputes, and enforce our agreements.
CHANGES TO THIS POLICY By using the Site and by submitting information, comments, or inquiries to us, you agree to the practices and procedures described in this Policy. We may change this Policy at any time by posting an updated Policy on this page with the applicable effective date. Your continued use of the Site after any such change is made constitutes acceptance of any modifications to the Policy.
OUR POLICY CONCERNING CHILDREN Neither the Site nor any Services offered by SXM Media are directed at children under 13, and we do not knowingly collect, store, use or share information about anyone under the age of majority as determined by the laws of the state, province or territory of their residence.
LINKS TO OTHER WEBSITES The Site may include links to other websites or content hosted by other websites whose privacy practices may differ from ours. If you submit personal information to any of those websites, the privacy statements and practices of those websites govern their use of your information. We encourage you to carefully read the privacy statement of any website you visit.
TERRITORY-SPECIFIC PRIVACY RIGHTS Please see below for additional provisions depending on your state or country of residence:
Your rights under the California Consumer Privacy Act of 2018 (CCPA): The California Consumer Privacy Act applies to personal information collected and handled about California consumers by a business. This Site is intended solely for use by individuals acting in their official capacity as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit, or government agency. We do not sell your personal information to other businesses for their own marketing purposes, or exchange it for any other form of consideration to our business.
Your rights under Cal. Civ. Code § 1798.83 (Shine the Light law): We do not share personal information of individual, non-business customers (as defined under Cal. Civ. Code § 1798.83) with unaffiliated third parties for their own independent marketing purposes without consent.
Your rights under Cal. Bus. & Prof. Code Section§ 22575(b) (“Do Not Track” Browser Settings): You are entitled to know how we respond to “Do Not Track” browser settings. We do not currently alter our practices when we receive Do Not Track signals. To find out more about “Do Not Track,” you can visit https://www.allaboutdnt.com.
Nevada Consumers: SXM Media does not sell personal information to third parties for their resale or licensing.
Residents of Canada: Information, including personal information, may be collected from or about you as set forth in the Policy and may be transferred, stored, or processed outside of Canada, including in the United States. While outside of Canada, such information will be subject to applicable foreign laws, which may allow foreign government and national security authorities to access your personal information under certain circumstances. This Policy does not restrict our use or sharing of information which is anonymized or in an aggregated form. By using this Site and/or providing us with your personal information, you agree and consent that we may collect, use and disclose the information, including personal information, in accordance with this Policy. You also consent to allow us to contact you using the information you have provided to us.
Residents of the EU, EEA, or UK
If you are a resident of the EU, EEA, or UK and have questions about the processing of your personal information or wish to exercise the rights granted to you under your local data protection legislation, including the right to request access to and rectification or erasure of personal data or restriction of processing, object to processing, as well as the right to data portability, please contact our Chief Privacy Officer at privacy @ siriusxm.com. We will work with you directly to address any questions or concerns you have regarding our processing of your personal information. However, you also have the right to lodge a complaint with the Supervisory Authority of your country of residence or where the issue that is subject to the complaint occurred. Contact details for the EU national Supervisory Authorities can be found here. Contact details for the UK Information Commissioner’s Office can be found here.
TRANSFER TO OTHER COUNTRIES
If you access the Site from outside of the U.S., the information you submit to us may be transferred to the U.S. and other countries to be processed by us or our service providers in order for the purposes set forth in this Policy. Please be aware that such information will be subject to U.S. law and the laws of other countries where we may store and process your information.
In the instance where personal data is collected about residents of the EU/EEA or UK and transferred outside their country of residence to the US, we take steps to provide appropriate safeguards for such data such as the Standard Contractual Clauses as approved by the European Commission.
If you are not a resident of the U.S., you hereby consent and agree that we may collect, process, use, and store your information, as discussed in this Policy, outside your resident jurisdiction, including in the U.S.
LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
Privacy laws in certain countries require us to disclose the legal basis for which we process your personal information. We may rely on the following legal bases when processing your personal information as a result of your interaction with us through this Site:
Consent: We may rely on your consent to process your information when you provide it at the point of data collection. You may withdraw your consent for processing at any time by contacting us.
Legitimate Interests: We may rely on our legitimate business interests to process your personal information, except where such interests are overridden by your interests or fundamental rights and freedoms.
Compliance with a Legal Obligation: We may process your personal information if such processing is necessary for compliance with a legal obligation to which we are subject.
For Performance of a Contract: We may process your personal information if such processing is necessary to perform a contract we enter with you or in order to take steps at your request prior to entering into a contract.
If you have any questions or require additional information about the legal basis upon which we process your personal information, please contact us at firstname.lastname@example.org
CONTACT US You may contact us regarding this Policy by sending an email to privacy @ siriusxm.com. Please do not send personal or sensitive information in your emails to us.
You may also write to us at: Chief Privacy Officer Sirius XM Radio Inc. 8550 Freeport Parkway Irving, Texas 75063