Privacy Policy

Effective Date: April 10, 2020

Any users located within the European Economic Area (“EEA”) are prohibited from using our Platforms.  For avoidance of doubt, the Hubbard Television Group (defined below) Platforms are not intended for users located within the EEA.

This is the Privacy Policy for the websites and mobile apps (“Platforms”) operated by KSTP-TV, LLC, KSTC-TV, LLC, WDIO-TV, LLC, KAAL-TV, LLC, KOB-TV, LLC, WNYT-TV, LLC and WHEC-TV, LLC  (collectively, “Hubbard Television Group” “our,” “us,” or “we”)(“Hubbard” “our,” “us,” or “we”).  Your privacy is important to us, and we provide this Privacy Policy regarding our collection, use and disclosure practices to help you to make informed decisions regarding use of our Platforms, and exercising choices regarding our collection, use and disclosure of your personal information on our Platforms.

This Privacy Policy is incorporated by reference into and is subject to the Hubbard Television Group’s Terms of Use.

The Information We Collect

While using our Platforms, you may review content, register to listen to our live streams, sign up to receive marketing information from us, enter our various sweepstakes and contests, or link to our Facebook, Twitter or Instagram pages by liking or following us, along with a variety of other functions. Depending on how you use our Platforms, we may collect: your name, birth date, gender, email address, zip code, and any other information you may voluntarily provide to us (for example: your street address or telephone number, or your “friends” or contacts that you agree to allow us to access).  We may also gather information from the device you use when interacting with our Platforms, such as your location or I.P. address. We may gather this information in a variety of ways, such as when you email us, create a user profile, register for our web or mobile app live stream, or enter a sweepstakes or contest. We may also ask you to create a personal password when you register for one of our products or services. We also collect certain non-personally identifiable information whenever you visit our website, such as the type of browser you are using (for example: Chrome, Safari, etc.), the type of operating system you are using (for example: Windows or Mac OS), the domain name from which you receive Internet access, and aggregate information regarding what pages you access or visit.

Collection of Information by Third Party Sites, Sale Partners and Sponsors

Some of our Platforms contain links to other sites whose information practices may be different than ours. We encourage you to consult these other sites’ privacy policies, as we have no control over information that is submitted to, or collected by, these third parties. To try to bring you advertising that is of interest to you, we have relationships with reputable third parties that we allow to present or serve advertisements on our Platforms. Ad server companies may collect information about your use of our Platforms such as your domain type, your IP address and clickstream information. Our Privacy Policy does not cover any use of information that a third party ad server may collect from you. We sometimes may offer content (for example: contests, sweepstakes, or promotions) that is sponsored by or co-branded with identified third parties. By virtue of these relationships, these third parties may obtain personally identifiable information that you voluntarily submit to participate in the activity. We have no control over such third parties’ use of any information you provide to them.

To opt out of interest-based advertising, visit http://www.networkadvertising.org/choices or http://www.aboutads.info for desktop and mobile websites. To opt out of interest-based advertising on mobile apps, see your mobile device carrier.

Cookies and Other Technical Information

We send “cookies” to your computer, mobile device, or tablet primarily to enhance your online experience and to store visitor preferences, record session information, record user-specific information on what pages users access or visit, alert visitors to new areas that we think might be of interest to them when they return to our Platforms, record past activity on our Platforms in order to provide better service when visitors return to our Platforms, ensure that visitors are not repeatedly sent the same display advertising, customize content based on visitors’ browser type or other information that the visitor sends. Cookies are files that can identify you as a unique customer and store your personal preferences as well as technical information (including click through and click stream data). Cookies can either be permanent (that is, they remain on your computer until you delete them) or temporary (that is, they last only until you close your browser).

We may also use “Web beacons” that monitor your use of our Platforms. Web beacons are small strings of code that provide a method for delivering a display advertisement on a webpage for the purpose of transferring data, such as the IP (Internet Protocol) address of the device that downloaded the page on which the Web beacon appears, the URL (Uniform Resource Locator) of the page on which the Web beacon appears, the time the page containing the Web beacon was viewed, the types of browser that fetched the Web beacon and the identification number of any cookie on the device previously placed by that server. When corresponding with you via HTML-capable e-mail, Web beacons let us know whether you received and opened our e-mail.

We also use Remarketing with Google to advertise online. Third-party vendors, including Google, may show you our ads on websites across the Internet. We and third-party vendors, including Google, use first-party cookies (such as the Google cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on past visits to our Platforms.

For more information on Google’s privacy practices, please visit Google’s website at https://policies.google.com/privacy?hl=en%20and%20terms%20of%20use.  For more information on how to opt-out of certain advertising cookies used by Google, please visit Google’s website at https://adssettings.google.com/authenticated.

If you have installed an app on your mobile device or tablet and you wish to stop receiving push notifications, you can change the settings either on your device or through the app.

If you choose to furnish one of our Platforms with personally identifiable information, this information can be stored in or linked to other data stored in the cookies/Web beacons. By accepting this Privacy Policy, you specifically agree to our use of cookies and Web beacons as described herein.

You may adjust your browser to reject cookies from us or from any other website. Additionally, by setting your Web browser to display HTML e-mails as text only, you may be able to prevent the use of some Web beacons. Please consult the “Help” section of your browser for more information. However, there is certain information on our Platforms that can only be accessed in conjunction with cookies or similar devices and you should be aware that disabling cookies or similar devices might prevent you from accessing some of our content or otherwise impair, prevent, or diminish certain functionality of our Platforms.

Our Use of Information Collected on Our Platforms and Your Choices Regarding that Use

We may use the personally identifiable information that we collect to provide you with an interactive online experience, to fulfill your requests for our products and services, to respond to your inquiries about our offerings, to notify you when we make changes to our subscriber agreements, to personalize or localize your experience on our Platforms, to allow us to make personalized recommendations of content you may be interested in, or to contact you about your account with us.  We may, on occasion, combine information we receive online from you with records from other sources. As provided in our Terms of Use, if you choose to post content on our Platforms, we may use that information in any manner. In addition, we may use the personally identifiable information we collect through our Platforms to offer you other programs, services or products that we believe may be of interest to you. If you do not want to receive e-mail offers from us in the future, please let us know by unsubscribing to any email at the bottom of each of our email messages. Please allow time for your request to be implemented. We use the non-personally identifiable information that we collect to improve the design and content of our Platforms and to enable us to personalize your online experience. We also may use this information in the aggregate to analyze usage, as well as to offer you products, programs, or services.

Disclosure of Personally Identifiable Information

We try to limit our disclosures of personally identifiable information to those that are important to carrying on our business. For example, if you choose to post content on our website (for instance: “comment on a story”), we may freely disclose that content to others, and may also freely disclose any other information you have provided to us, other than personally identifiable information. We may disclose personally identifiable information in response to a legal process–for example, in response to a court order or a subpoena. We also may disclose personally identifiable information in response to a law enforcement agency’s request or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use, or as otherwise required by law. In addition, we may transfer information about you if we are acquired by or merged with another company, or if our assets are acquired by another entity. Agents and contractors of Hubbard Television Group who have access to personally identifiable information are required to protect this information in a manner that is consistent with this Privacy Policy by, for example, not using personally identifiable information for any purpose other than to carry out the services they are performing for us.

Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that personally identifiable information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.

 

California Privacy Rights

If you are a California user, you have certain rights with respect to the collection, use, transfer, and processing of your “Personal Information,” as defined by the California Consumer Privacy Act (“CCPA”).  We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others.  To exercise any of the rights below, please contact us via the contact information below.  Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information.

Collection of Personal Information

When California consumers access our Platforms, purchase our products, enter our sweepstakes, contests, or promotions, interact with us on social media, visit one of our physical locations, we collect the following Personal Information:

Personal Identifiers

  • Name
  • Address
  • Email address
  • Telephone number
  • Date of birth
  • Social Security number
  • User Name and Password

Commercial Information

  • Purchase or transaction history
  • Sweepstakes, contest, or promotion activity

Internet or Other Electronic Network Activity Information

  • Browsing history
  • Search history
  • Information regarding a consumer’s interaction with an Internet website, application, or advertisement
  • Internet Protocol address
  • Device ID
  • Cookies
  • Beacons
  • Pixel Tags
  • Mobile ad identifiers
  • Social media interaction information

The foregoing pieces of Personal Information have been collected about our consumers in the past 12 months.

Sources From Which Personal Information Is Collected

We collect your identifiers, or other personal information (financial information), characteristics of protected classifications, and certain pieces of your internet and other electronic network activity information from you directly.  We collect your commercial information by keeping a log of your transactions.  We collect your internet and other electronic network activity information from your transactions with our Platforms.  We may also, on occasion, combine internet and other electronic network activity information with information we receive from other sources.

Business or Commercial Purposes for Which Personal Information Is Collected

Your Personal Information is used for the following purposes:

  • Respond to your requests for services or products
  • Provide you with customer support and respond to your communications
  • Send you transactional or administrative communications, as well as certain service-related announcements
  • Personalize your experience on our Platforms
  • Send you information relating to other programs, services, or products that we believe may be of interest to you
  • Run website analytics to evaluate performance
  • Fulfill our responsibilities as an employer

Third Parties With Whom Personal Information Is Shared

Hubbard shares your Personal Information with analytics and service providers, benefits providers, transaction processors, and law enforcement (if necessary).

In the preceding 12 months, we have sold the following Personal Information to third parties about consumers for business purposes:

  • We allow certain companies to use cookies, web beacons, or other online tracking devices to enhance online experiences and customize advertising. For more information, please see the “Cookies and Other Technical Information” section.

In the preceding 12 months, we have not sold Personal Information about minors.

In the preceding 12 months, we have disclosed the following Personal Information about consumers for business purposes:

  • We share content posted on our Platforms (g., if a consumer “comments” on a story) with other consumers.
  • We share entry information from sweepstakes and contests that we sponsor with prize providers and marketing partners.
  • We allow certain companies to use cookies, web beacons, or other online tracking devices to enhance online experiences and customize advertising. For more information, please see the “Cookies and Other Technical Information” section.

Individual Rights

Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that Hubbard disclose the Personal Information it collects, uses, and discloses about you to third parties. If you make a Request for Information about your Personal Information, you will receive the following information about you:

  1. Categories of Personal Information collected about you during the preceding 12 months;
  2. Categories of sources from which Personal Information is collected;
  3. Business purpose for collecting or selling Personal Information;
  4. Categories of third parties with whom Personal Information is shared or sold; and
  5. Specific pieces of Personal Information collected about you.

This information will be provided to you free of charge, unless Hubbard determines that your request is manifestly unfounded or excessive.  You may request this information twice in a 12-month period.

There are certain exceptions to a consumer’s Right to Know, including exceptions relating to employment information.  Hubbard will state in its response if an exception applies.

Right of Deletion

You have the right to request that Hubbard and our service providers delete any Personal Information about yourself which Hubbard has collected from you upon receipt of a verifiable request.  If you choose to delete your personal information, you may not be able to use certain website functions that require your personal information to operate. This right is subject to certain exceptions, including exceptions relating to employment information.  Hubbard will state in its response if an exception applies.

Right to Opt-Out of the Sale of Personal Information

You have the right to opt-out of the sale of your personal information by a business subject to certain laws and regulations.

Hubbard does not, and will not, sell any Personal information of California consumers for monetary consideration.  Therefore, we do not offer the right to the opt-out of the sale of your Personal Information.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising the privacy rights conferred by California law.  Hubbard will not discriminate against you because you exercised any of your privacy rights, including, but not limited to, by: 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 of 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.

Submitting Requests

You can submit your request by calling us at 877-646-9595 or visiting our request website at hubbardbroadcasting.com/data-request.   You may also submit a request via email at datarequest@hbi.com.

Verifying Requests

Hubbard provides California consumers with an online webform to submit requests.  The webform is accessible at hubbardbroadcasting.com/data-request.   As stated in the webform, Hubbard must verify that the person requesting information or deletion is the California consumer about whom the request relates in order to process the request.  To verify a California consumer’s identity, we may request up to three pieces of Personal Information about you when you make a request to compare against our records.  We may also request that you sign a declaration under the penalty of perjury from the consumer whose personal information is the subject of the request.

Making a verifiable consumer request does not require you to create an account with us.  We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request.  Hubbard reserves the right to take additional steps as necessary to verify the identity of California consumers where we have reason to believe a request is fraudulent.

Authorized Agents

You may choose a person registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”).  If you choose to use an Authorized Agent, Hubbard requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with Hubbard.  Failure to do so may result in Hubbard denying your request.

Contact for More Information

If you have any questions or concerns regarding your California Privacy Rights under this Privacy Policy, you may write to us at our postal address:

Hubbard Television Group

3415 University Avenue
St. Paul, MN 5514
Attn: Legal

Last Updated:  April 10, 2020

Our Commitment to Security

We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access to personally identifiable information, maintain data security, and to insure that use of personally identifiable information is in accordance with this Privacy Policy.

Notice Regarding Changes to this Policy

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in this Privacy Policy. If our information practices change at some time in the future we will post the policy changes to our Platforms to notify you of these changes, together with a new date at the top of the Privacy Policy, and will provide you with the ability to opt-out of these new uses by visiting the Contact page of the applicable Platforms you provided information through. Please note that there are certain service notifications that you may not opt-out of, such as notifications of changes to our products, services, or policies.

We encourage you to refer this Privacy Policy periodically and review the effective date at the top of the Privacy Policy to see if the Policy has changed, so that you are always current on our privacy practices pertaining to your information.

Notice Regarding Nielsen Market Research and Measurements

Our Platforms may feature Nielsen proprietary measurement software, which will allow you to contribute to market research, such as Nielsen Ratings. To learn more about the information that Nielsen software may collect and your choices with regard to it, see the Nielsen Digital Measurement Privacy Policy at http://www.nielsen.com/digitalprivacy. To opt-out or opt back into Nielson Measurement, click here.

How to Contact Us

If you have any questions or concerns about this Privacy Policy or its implementation you may write us at our postal address:

Hubbard Television Group
3415 University Avenue
St. Paul, MN 55114
Attn: Legal