Effective Date July 2, 2024

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

This is the Privacy Policy for the websites and mobile apps (“Platforms”) operated by Hubbard Radio, LLC’s subsidiaries, including KSTP-FM, LLC, Hubbard Radio Seattle, LLC, Hubbard Radio St. Louis, LLC, Hubbard Radio Phoenix, LLC, Hubbard Radio Cincinnati, LLC, Hubbard Radio West Palm Beach, LLC, Hubbard Radio Chicago, LLC, Hubbard Radio Washington D.C., LLC, and HBI Radio, LLC and its subsidiaries, including KTMY-FM, LLC, KSTP-AM, LLC, HBI Radio Brainerd/Wadena, LLC, HBI Radio Alexandria, LLC, HBI Radio Bemidji, LLC  (“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. Please see the U.S. State Privacy Rights section of this Privacy Policy for more information about these rights and how to exercise them.

As set forth in our Terms of Use, our Platforms are for a general audience, are not targeted to children, and do not knowingly collect personal information from children under 13 years of age.

How We Collect Personal Information

  • From you. This may include personal information we collect when you view or consume content, register to listen to our live streams, create a user profile, sign up to receive marketing information from us, post on our Platforms, enter our various sweepstakes and contests, contact us, or submit a news tip. This may also include streaming or listening metrics, duration of listening sessions, likes, and interactions with an Internet radio player.
  • From third parties and publicly available sources. This may include personal information we collect from other public sources, including, but not limited to, websites that enable social sharing, social media sites, and websites from our service providers, vendors, our affiliates, or other individuals and businesses.
  • From devices you use when you interact with us online. This may include information collected through our Platforms and automatically from devices you use to connect to our Platforms. For more information about this, please see our “Cookies and similar technologies” section below.
  • From you in person.

The Types of Personal Information We May Collect From You

Depending on how you use our Platforms, we may collect:

  • User Information. If you create an account with us, then we need certain information to create and manage any account you make on our Platforms, like your phone number, email address, and password.
  • Contact Information and Preferences. Such as name, email address, mailing address, phone number, and listening preferences.
  • Biographical and Demographic Information. Such as date of birth, age, other preferences.
  • Listening and Subscription Information. Such as listening time, listening occasions, last logged in visit, contest entries, notifications subscriptions, notification views, notification clicks, email subscriptions, liked songs, favorite artists, messages sent to the platform, and registration source.
  • Internet Activity. Such as your Internet Protocol (“IP”) address, what advertisements aired while logged in to our Platforms, and information on your interaction with our Platforms.
  • Device Information. Along with the information you give us directly, we collect a variety of information automatically as you use our Platforms. Like other websites and apps, we collect data about the browsers and devices you use to access our Platforms. The data we collect includes browser or device model and settings, device ad ID, operating system, unique identifiers, and the version of the app you’re using.
  • Usage Data. We also collect data about how your browsers and devices interact with our Platforms, including IP address, crash reports, system activity, and the date, and time. If you access our Platforms from a mobile or other device, we may also collect a unique device identifier assigned to that device, geolocation data (including your precise location), or other usage information for that device.
  • Other Personal Information. Other information collected online or offline to help us better identify and offer services and information that we believe may be of interest to you, or help us better understand your experience with our Platforms.
  • Communications with us. Such as interactions with us on our Platforms and social media channels, including chatbot and live chat. By accessing or using any of these communications features, you agree that we may record and retain a transcript of all communications with you. We may also work with trusted service providers to analyze, store, and use this data on our behalf.
  • Fraud Prevention Information. Data used to help identify and prevent fraud.
  • Inferences. Inferences may be used to improve our Platforms and make them more useful to you. We may use data about your activity to understand and infer your preferences.
  • Aggregate Data. We may collect your personal information in an aggregated or non-identifying form or otherwise in a form that cannot reasonably be used to identify you, including the URL of the site you visited before our Platforms.

How We Use Your Personal Information

We may use your information for the following reasons, depending on your relationship with us:

  • To allow us to make personalized recommendations of content you may be interested in.
  • To offer you other programs, services or products that we believe may be of interest to you.
  • To fulfill your requests for our products and services.
  • To communicate with you, such as when we respond to your inquiries, send you communications, and contact you about your account with us.
  • To notify you when we make changes to our subscriber agreements.
  • To provide, market, and develop our products and services, including to maintain our Platforms, troubleshoot, provide customer and technical support, conduct data analysis, test and research, and better understand the interests of our customers, listeners, and Platform visitors who use our services and products.
  • To serve you targeted advertising or content.
  • To conduct marketing research.
  • To understand how you interact with our Platforms and to provide you with an interactive online experience, including through personalized or localized Platform experiences.
  • To maintain the safety, security, and integrity of our Platforms, for example, by authenticating users and providing account security and fraud detection. We may also use your information to monitor, detect, and prevent fraud and improper or illegal activity.
  • To debug our systems, to secure our online services, including our network and websites, and to debug our online services.
  • To send you news and/or marketing communications (by email, phone, or text) subject to your marketing preferences and choices, including information about us or third-party offerings we think may be of interest to you.
  • To conduct market research and develop quality assurance, including to study, develop, and improve our products and services. We may also aggregate, anonymize, and/or de-identify personal information we collect and use it for any purpose, including product development and improvement activities.
  • To comply with legal requirements and/or to investigate or address claims or disputes relating to your use of the Platforms. This would include the use of your information to comply with our legal and regulatory obligations, to defend ourselves in litigation and investigations, and to prosecute litigations.
  • To combine information we receive online from you with records from other sources.

How We Disclose Personal Information

We may collect, use, retain, disclose, and store personal information collected from or about you with any of the following entities and for any of the following purposes:

  • Service Providers and Advertising Partners. We may provide personal information to vendors, customer support vendors, payment processors, contractors, business and service partners, or other third parties, such as advertising partners or other marketing partners who provide services to us, including analysis firms, advertisers, and others.
  • Collaborators. We may share personal information with collaborators with whom we jointly develop or promote our services, including sponsorships and co-branded opportunities, contests, and promotions.
  • Government, regulatory, or law enforcement agencies. We reserve the right to disclose your information to respond to valid information requests from government authorities and judicial requests, to investigate potential fraud, or where otherwise required by law. We may disclose your personal information where we believe the disclosure is necessary or appropriate to comply with regulatory or legal requirements, or to protect the safety, rights, or property of ourselves and others and to exercise, establish, or defend our legal rights.
  • In connection with a merger, acquisition, or business transfer. If we sell all or a part of our company, are part of a merger, consolidation, restructuring, and/or sale of assets or other corporate change, your information may be transferred as part of that transaction.
  • At your direction. We may disclose your personal information at your direction or with your consent.
  • The General Public. We may share personal information with the general public that you choose to share when publicly contributing content to our Platforms through a public forum, blog, social feature, or the like;
  • Device Sharers. We may share personal information with others who share your device if you make your account available to them through that device.
  • Aggregate Data. We may disclose your personal information in an aggregated or non-identifying form or otherwise in a form that cannot reasonably be used to identify you.

Your U.S. State Privacy Rights 

You have the following rights, where provided under applicable state law, regarding your personal information (each of which are subject to various exceptions and limitations):

  • Access. You have the right to request, up to two times every 12 months, that we disclose to you the categories of personal information collected about you, the categories of sources from which the personal information is collected, the categories of personal information sold or shared, the business or commercial purpose for collecting, selling, or sharing the personal information, the categories of third parties with whom personal information was shared (or a list of these third parties, if you are an Oregon resident), and the specific pieces of personal information collected about you.
  • Correction. You have the right to request that we correct inaccurate personal information collected from you.
  • Deletion. You have the right to request that we delete your personal information that we maintain about you.
  • Opt Out (Do Not Sell or Share My Personal Information). You have the right to opt-out of the “sale” of your personal information and the “sharing” of personal information in connection with the display of “targeted advertising” across third party websites, as these terms are defined under applicable US state privacy laws. These terms are defined broadly to include situations where we provide personal information to partners who provide advertising services to us. If you would like to opt-out of the sale or sharing, please visit our “Your Privacy Choices” page. We also honor the Global Privacy Control, a browser-based opt-out signal. We do not respond to other browser-based signals that do not meet applicable state law requirements, which may include older Do Not Track signals.
  • No Discrimination. You have the right not to be discriminated against for exercising these rights.
  • Appeals. You have a right to appeal decisions concerning your ability to exercise your consumer rights.


How to Submit a Request for Your Privacy Rights

In order to exercise your right to opt out of the sale or sharing of your personal information, please visit our “Your Privacy Choices” page.

In order to exercise your other rights described above, please submit a request through the linked form at hubbardradio.com/data-request. You may also submit a request via email at datarequests@hubbardradio.com or by calling us at 877-646-8255. Additionally, we may need to obtain information about you or your specific request in order to verify your identity and respond.

  • Authorized Agent. You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent identifies himself/herself/itself as an authorized agent and can show written permission from you to represent you. We may contact you directly to confirm that you have authorized the agent to act on your behalf and confirm your identity.
  • Verification. We are required by law to verify your identity in connection with any request in order to prevent unauthorized access of your data. Failure to verify your identity may result in your request not being processed. Where required by applicable law, we will notify you if we deny your request and notify you of the reasons we are unable to honor your request.

Links to Third Party Websites

We may provide links to websites and other third-party content (e.g., social media platforms) that are not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of these websites.

If you provide any personal information through a third-party site, your interaction and your personal information will be collected by and controlled by the privacy policy of that third party site. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this Privacy Policy.

Advertising and Opt-Out Disclosures

When you use our Platforms our third-party advertising partners, social media providers, and analytics providers may collect personal information about your online activity on our Platforms and on third party websites.

One of the third-party partners we use is Google Analytics. Please see www.google.com/policies/privacy/partners to find out more about how Google uses your information.

These providers may set web tracking tools (e.g., cookies and web beacons, as discussed further below) to collect information regarding your online activity. In addition, our advertising partners may use this information to deliver advertisements to you when you visit third party websites within their networks. If you would like more information about this practice, and to know your choices with respect to it, please either visit the Digital Advertising Alliance’s opt-out page (currently available at http://www.aboutads.info/choices/) or the Network Advertising Initiative’s opt-out page (currently available at http://www.networkadvertising.org/choices/). Please note that you may continue to receive generic ads that are not based on your preferences.

Information Security

We use commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in our possession against loss, theft, unauthorized use, disclosure, or modification. However, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the internet. We cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to us, you do so at your own risk.

Cookies and Similar Technology

We and our partners use various tools to collect data when you visit our Platforms, including cookies, pixels, localStorage, and other similar technologies. Some of these technologies store data in the browser or on your device. Other technologies may use network-related or other information to recognize your device (e.g., IP address). Our Platforms use these technologies, for example, when you first request a web page and data is then stored on your computer or other device so the website or mobile application can access personal information when you make subsequent requests for pages from that Platform. These technologies may also be used to collect and store information about your usage of the Platforms, such as pages you have visited, other content you viewed, and search history.

We and our partners may also use these technologies to gather personal information about how you view and use our Platforms and content and to connect your activity with other data we store about you. We and our partners may collect your personally identifiable information about your online activities over time and across different websites when you use the Platforms. The use of these technologies helps us serve you better by understanding what you are interested in, tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis. Our partners may collect data from your browser or device for advertising and measurement purposes using their own similar tools.

Your web browser can be set to allow you to control these technologies, such as whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting these technologies, such as cookies. To find out more about cookies, visit www.aboutcookies.org. Depending on the make and model of your phone, you may be able to use device settings to opt out of the use of certain device IDs for targeted advertising.

Some browsers permit the user to send a “Do Not Track” (“DNT”) preference to websites that the user visits indicating that the user does not wish to be tracked over time and across websites. Because there is not yet a common understanding of how to interpret DNT, we do not currently respond to the DNT signal on our websites.

In addition, if you give your email address to us, we may use a scrambled form (called a “hashed” version) of your email address to deliver tailored ads to you on our Platforms or on other websites, including via Custom Audience Feature or other similar tools.

Your Marketing Preferences

We may periodically send promotional materials or notifications related to our Platforms. If you no longer wish to receive promotional marketing materials from us, you may opt out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from us by following the instructions included in the email. Please allow time for your request to be implemented.

You may unsubscribe from text messages you previously consented to by following the prompt provided on our messages. We will work to comply with your request promptly.

There are certain service notifications and other non-promotional emails that you may not opt out of, such as notifications of changes to our Platforms or policies.

Additional Information for Residents of California

What We Collected, Disclosed, and/or Shared/Sold

In the past 12 months, we have disclosed (or have enabled you to disclose) and have collected the following categories of Personal Information. Additionally, we do not knowingly “share” or “sell” Personal Information of minors under 16 years of age.

Identifiers, such as name, IP address, email address, and online and device identifiers. Vendors, such as cloud service providers (including cloud-based customer service and survey tools we use), payment processors, and business partners.

Affiliates for purposes of business operations and support.

Ad partners and advertising technology companies. Yes
Demographic information, including your gender, age, date of birth. Vendors, such as cloud service providers (including cloud-based customer service and survey tools we use), payment processors, and business partners.

Affiliates for purposes of business operations and support.

Ad partners and advertising technology companies. Yes
Audio, electronic, visual information, and other similar information. Vendors, such as cloud service providers (including cloud-based customer service and survey tools we use), promotional and sweepstakes partners, and business partners.

Affiliates for purposes of business operations and support.

Commercial information, such as purchase history, transaction history, and entry information or activity for sweepstakes, contests, or promotions. Vendors, such as service providers, transaction processors, and law enforcement (if necessary). Promotional partners for our sweepstakes and contests.

Affiliates for purposes of business operations and support.

For entry information only: Ad partners, advertising technology companies, and promotional/sweepstake partners. For entry information only: Yes.
Internet or other electronic network activity information, such as hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, and in some cases, browser type, Internet service provider, referring/exit pages and URLs, and clickstream data. Vendors, such as cloud service providers (including cloud-based customer service and survey tools we use), payment processors, and business partners.

Affiliates for purposes of business operations and support.

Ad partners and advertising technology companies. Yes
Commercial information, including financial information. Vendors, such as cloud service providers (including cloud-based customer service and survey tools we use), payment processors, and business partners.

Affiliates for purposes of business operations and support.

Geolocation, such as non-precise geolocation information, or approximate location as inferred from IP address. Vendors, such as cloud service providers (including cloud-based customer service and survey tools we use), payment processors, and business partners.

Affiliates for purposes of business operations and support.

Ad partners and advertising technology companies. Yes
Other information you may share if you use social features when accessing our Platforms, including the organizations, links, and other information included on your social profile page. Vendors, such as cloud service providers (including cloud-based customer service and survey tools we use), payment processors, and business partners.

Affiliates for purposes of business operations and support.

Ad partners and advertising technology companies. Yes
Inferences, such as those drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics. Vendors, such as cloud service providers (including cloud-based customer service and survey tools we use), payment processors, and business partners.

Affiliates for purposes of business operations and support.

Ad partners and advertising technology companies. Yes


Data Retention. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.

Sensitive Personal Information. We do not process “sensitive” Personal Information for purposes other than those specified in the CCPA (such as to provide the services and for security purposes).

Sources From Which Personal Information Is Collected

We collect this personal information directly from California residents themselves, as well as from social media platforms (e.g., if the individual has connected a social media account to our website); referrals; joint marketing, co-branding, co-promotional, or advertising partners; and sources of demographic and other information, including through devices you used to interact with us through our Platforms. All sources of personal information collected are noted in the “How We Collect Personal Information” and “The Types of Personal Information We May Collect From You” sections above.

Business or Commercial Purposes for Which Personal Information Is Collected

Your Personal Information is used for the following purposes:

  • To operate, manage, and maintain our Platforms;
  • To provide our Platforms;
  • To accomplish our business purposes and objectives, including to:
    • Respond to your requests for services or products;
    • Provide you with customer support and respond to your communications;
    • Maintain our facilities and infrastructure;
    • Develop, improve, repair, and maintain our Platforms;
    • Conduct research, analytics, and data analysis;
    • Send you transactional or administrative communications, as well as certain service-related announcements;
    • Personalize your experience on our Platforms;
    • Advertise and market our Platforms;
    • Run and administer our promotions and contests;
    • 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;
    • Quality and safety assurance measures;
    • Conduct risk and security controls and monitoring;
    • Detect and prevent fraud;
    • Perform identity verification;
    • Perform accounting, audit, and other internal functions;
    • Comply with the law, legal process, and internal policies;
    • Exercise and defend legal claims.

Shine the Light Disclosure

We do not disclose personal information as defined by California Civil Code § 1798.83 (the “Shine the Light Law”) with third parties, other than our affiliates, for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light Law by sending an email to datarequests@hubbardradio.com or by sending a letter to 3415 University Avenue, St. Paul, MN 5514, Attn: Legal. Any such request must include “Request for California Privacy Information” in the subject line and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the email address or mailing address referenced above.

Updates to the Policy

We may update this policy from time to time. To the extent permitted by law, any changes to our privacy policy will be posted to the websites and will become effective upon posting. Any changes will be effective only after the effective date of the change and will not affect any dispute arising prior to the effective date of the change.

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.

Contact Us

We welcome requests, suggestions and questions concerning our use of your Personal Information. All such communication should be directed to datarequests@hubbardradio.com.