Destined For Victory - Paul Sheppard
Last updated: May 25, 2018
KDRY Radio, Inc. (hereafter as “KDRY” or “we”) recognizes that your privacy is very
important and we take it seriously. This Privacy Policy (“Privacy Policy”) describes our policies
and procedures on the collection, use, disclosure, and sharing of your personal information or
personal data when you use the KDRY website and mobile/tablet applications (the “Platform”).
This Privacy Policy applies to activities by KDRY and its affiliates and subsidiaries (collectively
“KDRY,” “we” or “us”).
When a user (hereinafter referred to as “you” or the “user”) browses any KDRY Platform,
the user does so anonymously. At the KDRY website, you can contact us for support. If you do
request support, we may request that you voluntarily supply us with personally identifiable
information. The types of personally identifiable information that may be collected at these pages
include: name, e-mail address, telephone number, and information about you provide regarding
our products and services. In addition, the KDRY site offers the ability to integrate with third-
party social media sites, in which case you may have an opportunity to voluntarily provide
additional identifiable information, such as your third-party social network profile name. If you
have any questions concerning the personally identifiable information KDRY has collected, please
contact us at our contact information found below.
We also may collect certain non-personally identifiable information when you visit our
site, such as the type of browser you are using (e.g., Firefox or Internet Explorer), the type of
operating system you are using, (e.g., Windows XP or Mac OS), the type of mobile device you are
using, the domain name of your Internet service provider (e.g., AT&T or Comcast) and the search
engine from which you were directed (e.g., Google or Yahoo).
Integrated Service Provider and Linked Networks. You can elect to sign in or sign up
to the KDRY Platform through a linked network (i.e., Facebook or Google), and you can connect
your existing KDRY account with certain third-party networks like Facebook, Twitter and
LinkedIn (each a “Linked Network”). If you elect to sign up through or connect with a Linked
Network, we receive certain profile and account information about you from the Linked Network.
The specific information provided to us by Linked Networks is determined by these third parties
and may vary by network. In all cases, the permissions page for the Linked Network will describe
the information being shared. You should consult their respective privacy policies for information
about their practices. You may elect to use information from the Linked Network to populate your
profile on the KDRY Platform and help you find and follow your contacts on the KDRY Platform.
For information on your choices, including how to disconnect a Linked Network from your KDRY
profile, see the “Your Choices” section below. You may also elect to connect and make and receive
payments to and from use through third party networks (“Integrated Service Provider”); if you do
so, you will be allowing us to pass to and receive from the Integrated Service Provider your login
information and other user data for payment purposes.
Automatically Collected Information About Your Activity. We use cookies, log files,
pixel tags, local storage objects, and other tracking technologies to automatically collect
information about your activities, such as your searches, page views, date and time of your visit,
and other information about your use of the KDRY Platform. We also collect and may store
information that your computer or mobile device provides to us in connection with your use of the
KDRY Platform such as your browser type, type of computer or mobile device, browser language,
IP address, mobile carrier, unique device identifier, location, and requested and referring URLs.
We also receive information when you view content on or otherwise interact with the KDRY
Platform, even if you have not created an account. For more information, see the “Cookies, Pixels
and Tracking” section below and our Cookie Policy.
NOTWITHSTANDING ANY PROVISION OF THIS PRIVACY POLICY TO THE
CONTRARY, TO THE EXTENT YOU PROVIDE YOUR INFORMATION, WE WILL NOT
SELL OR RENT SUCH INFORMATION TO ANY THIRD PARTY UNLESS YOU
OTHERWISE SPECIFICALLY CONSENT. KDRY uses the information we collect for the
following purposes:
Provide our Services. To provide you the services we offer on the KDRY Platform,
communicate with you about your use of the KDRY Platform, respond to your inquiries, provide
troubleshooting, and for other customer service purposes. We may use information generally to
compile statistical and user profile data, and to perform research using the compiled data including
disclosure of user information to research firms retained by KDRY to keep in contact with users
and provide them with a better interactive experience. We may use your information specifically
for the following purposes: to provide customer support; to meet legal requirements; to provide
Internet security; and/or to analyze the collected information and use this data for contacts by
research firms.
Personalization. To tailor the content and information that we may send or display to you
in the KDRY Platform, to suggest content, to offer location customization, and personalized help
and instructions, and to otherwise personalize your experiences while using the KDRY Platform.
Advertising. To display interest-based advertising to you in the KDRY Platform, to
improve our advertising and measurement systems so we can show you relevant ads, and to
measure the effectiveness and reach of ads and services. For more information, see the Ad Services
section below about KDRY Ads and Personalization.
Marketing and Promotions. For marketing and promotional purposes, such as to send
you news and newsletters, special offers, and promotions, or to otherwise contact you about
products or information we think may interest you, including information about third party
products and services.
Analytics. To gather metrics to better understand how users access and use the KDRY
Platform; to evaluate and improve the KDRY Platform, including the Ad Services and
personalization, and to develop new products and services.
Comply with Law. To comply with legal obligations, as part of our general business
operations, and for other business administration purposes.
Prevent Misuse. Where we believe necessary to investigate, prevent or take action
regarding illegal activities, suspected fraud, situations involving potential threats to the safety of
any person or violations of our Terms of Service or this Privacy Policy.
We share information as set forth below, and where individuals have otherwise consented:
Service Providers. We may share your information with third party service providers who
use this information to perform services for us, such as payment processors, hosting providers,
auditors, advisors, consultants, customer service and support providers, as well as those who assist
us in providing the Ad Services.
Affiliates. The information collected about you may be accessed by or shared with
subsidiaries and affiliates of KDRY, Inc., whose use and disclosure of your personal information
is subject to this Privacy Policy.
Business Transfers. We may disclose or transfer information, including personal
information, as part of any merger, sale, and transfer of our assets, acquisition or restructuring of
all or part of our business, bankruptcy, or similar event.
Legally Required. We may disclose your information if we are required to do so by law.
Protection of Rights. We may disclose information where we believe it necessary to
respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants),
enforce or administer our agreements and terms, for fraud prevention, risk assessment,
investigation, and protect the rights, property or safety of KDRY, its users, or others.
Metrics. We may share with users of our advertisers or publishers aggregate statistics,
metrics and other reports about the performance of their ads or content in the KDRY Platform such
as the number of unique user views, demographics about the users who saw their ads or content,
conversion rates, and date and time information. We do not share IP addresses or personal
information. We may also allow our advertisers or publishers to use Pixels on the KDRY Platform
in order to collect information about the performance of their ads or content.
Anonymized and Aggregated Data. We may share aggregated or de-identified
information with third parties for research, marketing, analytics and other purposes, provided such
information does not identify a particular individual.
We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local
storage, log files, and other mechanisms to automatically collect and record information about
your usage and browsing activities on the KDRY Platform and across third party sites or online
services. We may combine this information with other information we collect about users. Below,
we provide a brief summary these activities. For more detailed information about these
mechanisms and how we collect activity information, see our Cookie Policy.
Cookies. These are small files with a unique identifier that are transferred to your browser
through our websites. They allow us to remember users who are logged in, to understand how
users navigate through and use the KDRY Platform, and to display personalized content and
targeted ads (including on third party sites and applications).
Pixels, web beacons, clear GIFs. These are tiny graphics with a unique identifier, similar
in function to cookies, which we use to track the online movements of users of the KDRY Platform
and the web pages of users of our Ad Services, and to personalize content. We also use these in
our emails to let us know when they have been opened or forwarded, so we can gauge the
effectiveness of our communications.
Analytics Tools. We may use internal and third party analytics tools, including GoogleAnalytics. The
third party analytics companies we work with may combine the information collected with other
information they have independently collected from other websites and/or other online products and
services. Their collection and use of information is subject to their own privacy policies.
Do-Not-Track Signals. Please note we do not change system behavior within the KDRY
Platform in response to browser requests not to be tracked. You may, however, disable certain
tracking by third-parties as discussed in the KDRY Ads and Personalization section below. You
may also opt out of tracking by KDRY Pixels, as described below in KDRY Ads and
Personalization.KDRY Ads and PersonalizationWe may display personalized content (including
from third party publishers) andpersonalized ads (including sponsored content), based on information
that we have collected viathe KDRY Platform, and through our Pixels, widgets, and buttons embedded on
third party sites. We also may report aggregated or de-identified information about the number of users that saw a
particular ad or content and related audience engagement information to users of our Ad Services
and to publishers of content on the KDRY Platform. See KDRY’s Pixel Privacy Terms for more
information about how our Pixels are used, and also see the “Your Choices” section below for
information about opting out of tracking by our Pixels.
Users of our Ad Services may also provide us with information as part of their ad
campaigns, including customer list information (e.g., email addresses and demographic or interest
data) with us in order to create customized audiences for their ad campaigns; we only use this
information to facilitate the particular user’s campaign (including ad metrics and reporting to that
user) or for fraud detection and security purposes; and we do not disclose this information to third
parties (other than our service providers) unless required by law. We also do not disclose to the
users of our Ad Services the names or identities of their customers that were successfully reached
as part of such campaigns.
As described in our Cookie Policy, we may also work with third parties such as network
advertisers to serve ads on the KDRY Platform and on third-party websites or other media (e.g.,
social networking platforms). These third parties may use cookies, JavaScript, web beacons
(including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness
of their ads and to personalize advertising content to you.
In addition to opting out of tracking across sites by our Pixels (see “Your Choices” section
below), you also may opt out of much interest-based advertising on third party sites and through
third party ad networks (including Facebook Audience Network and Google AdSense). See “Your
Choices” section below for more information about opting out of third-party ad networks.
The security of your information is important to us. KDRY has implemented safeguards to
protect the information we collect. However, no website or Internet transmission is completely
secure. We urge you to take steps to keep your personal information safe, such as choosing a strong
password and keeping it private, as well as logging out of your user account, and closing your web
browser when finished using the KDRY Platform on a shared or unsecured device.\
Access and Amend Your Information. You may update or correct your account
information at any time by logging in to your account. You may also make a number of other
adjustments to settings or the display of information about you as described in more detail in the
following section about Your Choices.
Your Choices. You may, of course, decline to submit information through the KDRY
Platform, in which case we may not be able to provide certain services to you. You may also
control the types of notifications and communications we send, limit the information shared within
the KDRY Platform about you, and otherwise amend certain privacy settings.
Emails and Communications. You can manage your email and notice preferences in your
account profile settings, under your Emails and Notifications settings. If you opt out of receiving
emails about recommendations or other information we think may interest you, we may still send
you transactional e-mails about your account or any services you have requested or received from
us.
Credentials. You can change your credentials that are displayed in your profile or in
connection with a specific answer.
Destruction of Personal Data. At any time you may request that KDRY destroy all of
your personal information collected through the KDRY Platform, and KDRY shall comply with
your request to the extent allowed by applicable law.
Deleted KDRY Platform. If you choose Delete the KDRY Platform then you will no
longer receive any communications from us.
Security Breach Management and Notification. KDRY maintains security incident
management policies and procedures and shall notify you without undue delay after becoming
aware of the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or
access to your Data, including Personal Data, transmitted, stored or otherwise Processed by KDRY
(a “Customer Data Incident”). KDRY shall make reasonable endeavors to identify the cause of
such Customer Data Incident and take those steps as KDRY deems necessary and reasonable in
order to remediate the cause of such a Customer Data Incident to the extent the remediation is
within KDRY’s reasonable control.
Pixels. To opt out of tracking via the KDRY Pixels, please visit this page. Opting out of
Pixels tracking may impact our ability to personalize ads and content tailored to your interests.
This setting is tied to your cookies, and, unless you are logged in to the KDRY Platform, will only
be effective on the browser for which you have performed the opt-out.
Third Party Ad Networks. For information about and to opt out of interest-based ads
from many ad networks, go to:
U.S.: www.aboutads.info Internet Advertising Bureau
Canada: www.youradchoices.ca
European Union: www.youronlinechoices.eu/
Linked Networks. You may connect or disconnect your Linked Networks, such as
Facebook, through the Account Settings tab in your profile settings, and you may access, amend
and delete much of your profile information through your profile settings. Once you disconnect a
Linked Network, we will not receive information from that Linked Network going forward; unless
you choose to reconnect it. You may also control whether the Linked Network is visible in your
profile.
KDRY is headquartered in the United States, and has operations, entities and service
providers in the United States and throughout the world. As such, we and our service providers
may transfer your personal information to, or access it in, jurisdictions (including the United
States) that may not provide equivalent levels of data protection as your home jurisdiction. We
will take steps to ensure that your personal information receives an adequate level of protection in
the jurisdictions in which we process it.
Europe Specific Provisions
GDPR. As of May 25th, 2018, KDRY will Process Personal Data in accordance with the
GDPR requirements directly applicable to the KDRY Platform.
Transfer Mechanisms for Data Transfers. Subject to the terms of this Privacy Policy
KDRY makes available the transfer mechanisms listed below which shall apply to any online
transfers of personal data under this Privacy Policy from the European Union, the European
Economic Area and/or their member states, Switzerland and the United Kingdom to countries
which do not ensure an adequate level of data protection within the meaning of Data Protection
Laws and Regulations of the foregoing territories, to the extent such transfers are subject to such
Data Protection Laws and Regulations.
Additional Terms for EU-US and Swiss-US Privacy Shield Services. KDRY self-
certifies to and complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, as
administered by the US Department of Commerce, and KDRY shall ensure that it maintains its
self-certification to and compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks
with respect to the Processing of Personal Data that is transferred from the European Economic
Area and/or Switzerland to the United States.
Children’s Privacy
We do not knowingly collect or solicit personal information from anyone under the age of
16 or knowingly allow such persons to register. If we become aware that we have collected
personal information from a child under the relevant age without parental consent, we take steps
to delete that information.
Links to Other Websites
The KDRY Platform may contain links to third party sites or online services. We are not
responsible for the practices of such third parties, whose information practices are subject to their
own policies and procedures, not to this Privacy Policy.
California law permits users who are California residents to request and obtain from us
once a year, free of charge, a list of the third parties to whom we have disclosed their personal
information (if any) for their direct marketing purposes in the prior calendar year, as well as the
types of personal information disclosed to those parties. If you are a California resident and would
like to request this information, please submit your request at our contact information below.
If you have any questions about our practices or this Privacy Policy, please contact us at:
KDRY Radio, Inc.
16414 San Pedro Ave., Ste. 575
San Antonio, Texas 78232
Attn: Management
Or via email at am1100@kdry.com
If we change our privacy policies and procedures, we will post those changes on this page.
If we make any changes to this Privacy Policy that materially change how we treat your personal
information, we will endeavor to provide you with reasonable notice of such changes, such as via
prominent notice in the KDRY Platform or to your email address of record, and where required by
law, we will obtain your consent or give you the opportunity to opt out of such changes.