1.   PERSONAL INFORMATION

Personal information means any information or an opinion about an identified individual, whether that information is true or not, and whether it is recorded in a material form or not.

Sensitive information is a subset of personal information that includes information about your race or ethnic origins, political opinions, religious or philosophical beliefs, memberships, or details of health, disability, or sexual activity or orientation, etc.  We generally do not ask for sensitive information but may do so where it is reasonably necessary for our functions and activities and permitted or required by law.

Generally, we will only collect sensitive information where you have consented to us collecting that information, including where you voluntarily submit such information to us.

2.   WHAT INFORMATION WE COLLECT

Identifiers: We may collect your name, e-mail address, telephone number, mobile phone number, mailing address, date of birth, social media account handles or usernames, and Ad Libs account usernames and passwords. We may collect your digital signature in certain circumstances.

Demographic and Protected Classification Information: We may collect your age, gender, geographical area, language preferences, marital status, and political affiliation. Some of this is considered sensitive personal information, as described more fully below.

Purchase and Preference Information: We may collect information about the artists, programs, podcasts, playlists, and genres you are interested in; content you purchase, access, or download; records of your transactions and subscription purchases; and records of contests you enter.

Audio, Electronic, and Visual Information: If you choose to submit voice recordings, photos, or videos to the Digital Assets or Radio Station, we will collect that information. Photos, videos, and/or audio recordings of you where you attend an Ad Libs affiliated event, visit our premises, call into our radio shows, or otherwise participate on air or in an interview, information will be collected as well.

Radio Interaction Information: When you interact with our Radio Station, we may collect information about your response to Call-to-Actions. We collect your phone number, mode of interaction, date, and time.

Internet Browser, Usage, and Device Information: We use tracking tools like cookies and pixels to automatically collect information about your interactions with our Digital Assets, such as your IP address and other unique identifiers for the computer, mobile device, tablet, or other device you use to connect (“Device”), including the hardware model and mobile network information. We collect information about your use of the Digital Assets, including your browser type; operating system; activations; listening times; what areas of the Digital Assets you access and for how long; search terms you enter; how long you stay on a page; which hyperlinks and content or advertisements you click on; which songs, playlists, audiovisual content and other Ad Libs users you interact with; and the page served and preceding page views. If you use our Apps, we may also look at how often you use the Apps and where you downloaded them. We may collect information about your views, clicks, and interactions with our digital content and advertisements (both on and off the Digital Assets), as well as our promotional emails. If you create an account using your credentials from a third-party social media site, we will have access to certain information from that site, as described further below. 

Professional Information: If you interact with us on behalf of business customers, vendors, or other companies, in addition to other information described in this notice, we may also collect items like your job title, office location, compensation or payments, and engagement history with us.

Sensitive Personal Information: We may collect your Ghana Card number or Identification number if you are the winner of a promotion or contest. We will collect your payment details when you make a purchase. In addition to the above, if you interact with us on behalf of business customers, vendors, or other companies, we may also collect your driver’s license number, background check information, and Ghana Card number if relevant to our relationship with you. 

Inferences: Using the other pieces of personal information collected about you, we draw inferences about you, reflecting what we believe to be your interests, characteristics, predispositions, and attitudes.

3.   HOW WE USE INFORMATION

We may use personal information (including sensitive personal information) for the following purposes: 

• To provide and personalize our products and services offerings.
• To provide you with access to certain areas and features of the Digital Assets, such as your favorite shows, your musical preferences, songs you have listened to, shared playlists, and your interaction with other users; 
• To provide and administer contests, games, events, newsletters, and other promotions; 
• To allow you to participate in interactive features on our Digital Assets;
• To provide customer service; 
• To communicate with you about your account and activities on the Digital Assets, such as changes to any Ad Libs Multimedia policy; 
• To estimate our audience size and usage patterns.
• To administer the Digital Assets; help diagnose problems with our servers; and facilitate site navigation; 
• To conduct customer satisfaction and quality assurance surveys and market research;
• To conduct Digital Asset analytics and operations and to analyze trends; 
• To compile listener databases and profiles to enable us to market and serve products and services more accurately;
• To improve the Digital Assets and keep our Digital Assets fresh and interesting to our visitors; 
• To track the effectiveness of our advertising (such as measuring how many people view or click an ad) and for advertising attribution, analytics, and reporting; 
• To deliver reports to artists and record labels for tracks you hear; 
• To comply with our license obligations and enforce our Terms of Use and other contractual obligations; 
• To personalize your Ad Libs experience, such as: 
• To curate and suggest songs and other content that match your interests; this may include suggesting personalized radio shows, or providing specific features on the Digital Assets; and 
• To serve or display ads and offers (both on and off the Digital Assets) that are more likely to be relevant to you; these may be for our own products and services, or for products and services offered by our partners and other brands or advertisers (who may pay us to show you such content); 
• To send you (either directly or through one of our partners) marketing and promotional messages; 
• To associate you with your account or activities on social networking sites and, if you so choose, to enable interaction and data sharing between your activities on the Digital Assets and your activities on such social networking sites; 
• For security and safety purposes, such as protecting against cyber threats; protecting our rights and the rights of our customers and subscribers; detecting, investigating, or preventing fraud and other illegal activities; and responding to legal and regulatory compliance obligations; 
• To manage our relationship with you and verify your identity.

In the case of business contacts, to administer and manage our relationship with you and your employer (such as record keeping, payments, communicating with you, tracking outcomes, and verifying your eligibility and suitability). 

For other lawful purposes disclosed at the time we collect your information or otherwise with your consent. 

4.   HOW WE COLLECT INFORMATION

We collect personal information directly from you when you interact with us, for example, when:

• you participate in our radio programs;
• you submit an entry into a competition or promotion;
• you subscribe to a member database or email newsletter;
• you send us an email, contact us through any of our websites, or post on any of our websites (including any of our social media pages);
• you purchase products or services from us;
• you participate in a research survey;
• you download one of our mobile Apps or stream our products from a website or via a mobile App;
• you call us;
• you participate or interact with us in an interview (one on one or outdoor interviews); or
• you attend an event or activity that we organize, sponsor, or are otherwise affiliated with.

In some circumstances, we may obtain personal information about you from third parties such as:

• marketing databases or other sources that are publicly available such as websites, journals, legal directories, and phone books;
• friends or relatives who have provided us with your details as part of a promotion, competition, or event, including where they have nominated you as an emergency contact; and
• referees or previous employers where you have applied for a job with Ad Libs.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies).A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser Cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Digital Assets. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Digital Assets.
• Flash Cookies.Certain features of our Digital Assets may use locally stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Digital Assets. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons.Pages of our Digital Assets may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit Ad Libs, for example, to count users who have visited those pages or/and for other related website statistics (for example, recording the popularity of certain Digital Asset content and verifying system and server integrity).

Some advertisements on the Website may be served by third-party advertisers, ad networks, and ad servers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about our users. This may include information about users’ behavior on this and other websites to serve them interested-based (behavioral) advertising. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement, you should contact the responsible advertiser directly.

5.   DISCLOSURE OF INFORMATION

We may disclose aggregated information about you and information that does not identify any individual, without restriction.

Unless otherwise prohibited by law, we may share Personal Information about you with the following types of third parties and for the following purposes:

Affiliated Companies: We may share your Personal Information with our parent, subsidiaries, affiliated companies, and other controlled affiliates who may use Personal Information for any of the purposes disclosed in or consistent with the terms of this Privacy Policy.

Vendors and service providers: We may share personal information with vendors and service providers we hire to help us run our business, including those companies that operate our Digital Assets; analyze data; provide customer service, send emails for us; audit; process payments; conduct surveys; fulfill orders; run our promotional activities and contests; or provide marketing, analytics, and advertising services.

Business partners, rights holders, advertisers, and advertising companies: We may share or make available personal information with or to our sponsors, partners, advertisers, advertising networks, and analytics companies or other third parties in connection with our and their marketing, promotional, and other offers, as well as product information. These third parties may use your personal information for their own advertising, analytics, planning, market research, or other business purposes. We may also share your information with the rights holders that license content to Ad Libs to stream on the Digital Assets (e.g., artists or record labels). If you connect your Ad Libs account to a third-party application or social media platform, Ad Libs may automatically share your personal information with that service, and such information may be attributed to your account on the third-party platform and published on such service.

Business transfers: As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all or substantially all of our assets, or assets related to the Digital Assets, your information may be disclosed to such an entity as part of the due diligence process and may be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

For legal compliance: We may share personal information with third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities such as the Data Protection Commission,conducting an investigation; to verify or enforce our Terms of Use or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of other parties, visitors to our Digital Assets, or the public. 

Other Purposes: We may share your Personal Information to fulfill the purpose for which you provided it and, with your consent, for any other purpose.

6.   HOW LONG WE KEEP INFORMATION FOR 

We will only retain your personal information (including your sensitive personal information) for as long as is reasonably necessary for the purpose for which the information was collected, or as legally required.  We will not hold or process your personal information for any longer than we are legally permitted to. The criteria used to determine the appropriate retention period include: 

• Regulatory requirements that we are subject to, including laws and regulations related to tax, employment, accounting, and securities 
• Whether a legal claim might be brought against us, for which the information would be relevant 
• The necessity of the information to provide our services to our customers 
• The types and sensitivity of personal information being processed 

7.   YOUR PRIVACY RIGHTS & CHOICES

Where provided for by applicable privacy laws, you may be entitled to exercise some or all of the rights described below concerning your personal information: 

Access / Right to Know: You have the right to confirm whether we process personal information about you and to request that we disclose to you the following:

• the categories of personal information that we have collected about you (including sensitive personal information);
• the categories of sources from which we have collected personal information about you;
• the business or commercial purpose for collecting or selling your personal information;
• the categories of personal information that we have sold about you and the categories of outside parties to whom the personal information was sold;
• the categories of personal information that we have disclosed about you for our business purposes and the categories of suppliers to whom the personal information was disclosed;
• a portable copy of the specific pieces of personal information that we have collected about you; and
• information about the logic involved in any automated decision-making processes used by Ad Libs (if applicable), as well as a description of the likely outcome of the process with respect to you. 

Deletion: You can request that we delete the personal information that we maintain about you, subject to certain exceptions. 

Correct or Update my Personal Information: You have the right to request that we correct, update, or modify the personal information we maintain about you. If you have an account, you can also update your profile information at any time by visiting the account settings page within your account. 

Do Not Sell or Share My Personal Information: You can opt-out of the sale or sharing of your personal information by submitting a request to us by visiting our website and sending us a message or e-mailing us.

If you would like to opt out of cookie-based tracking for advertising purposes (which could be a “sale” or “sharing” under applicable law), you will need to update your cookie preferences on this webpage. Your cookie selections are specific to the device, website, and browser you are using. Your selections are deleted whenever you clear your cookies or browser’s cache. 

Limit the Use of my Sensitive Personal Information: You may be able to request that we limit our use and sharing of such information to those purposes specified under applicable privacy laws. Note that we only use and share your sensitive personal information for the purpose of providing our goods, subscriptions, and services that you’ve requested or purchased, maintaining the quality of our services and Digital Assets, or protecting our services and Digital Assets against illegal activity. 

Interest-Based Advertising: When you use the Digital Assets,  we, our service providers, and advertising partners may place cookies and similar tracking technologies on your computer or Device in order to collect information about your online web-browsing activities over time and across different websites and online services or mobile applications, to serve you ads or other content personalized to your interests. This form of advertising is referred to as Interest Based Advertising (“IBA”). You can opt out of being tracked online for IBA purposes.

Do Not Track: Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, and our systems are not configured to recognize Do Not Track headers or signals from some or all browsers. 

Marketing Communications: If you don’t want to receive promotional communications from us, such as offers, newsletters, advertising e-mails, or other marketing communications, you can unsubscribe by following the removal instructions in the communication that you receive (such as clicking the “UNSUBSCRIBE” or similar link within the email). Please note that if you opt out of receiving promotional communications, we may still send you non-promotional communications, such as those about your account or our ongoing business relations. 

Location Information: We may infer your general location using your IP address.  We will not collect more precise location information without your prior consent. You can stop the collection of general location information at any time by going to the settings feature on your Device and changing your preferences. If you do so, certain features of our Apps may no longer function as intended. You also may also uninstall or remove our Apps from your Device. 

Push Notifications: If you use our Apps, we may send you push notifications from time to time. If you no longer wish to receive push notifications, you can turn them off at the device level in your App settings. 

You will not be discriminated against for exercising these rights.  We will not deny you any products or services, nor charge you different prices, in retaliation for exercising your privacy rights.  

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record-keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.

8.   OTHER SITES 

The Digital Assets may contain links to other sites that we do not own or operate. This includes links from service providers, advertisers, sponsors and/or partners that may use our logo(s) as part of a co-branding or co-marketing agreement. We do not control, recommend, or endorse, and are not responsible for, these sites or their content, products, services, or privacy policies or practices. These other websites may send their own cookies to your Device, they may independently collect data or solicit Personal Information, and may or may not have their own published privacy policies. You should also independently assess the authenticity of any site that appears or claims that it is one of our Digital Assets (including those linked to through an email or social networking page). 

The Digital Assets may make available comment sections, forums, message boards, and newsgroups. Remember that any information that you disclose in these areas becomes public information and is not subject to the provisions of this Privacy Policy. 

9.   GHANA ONLY 

The Digital Assets are governed by and operated in, and in accordance with the laws of the Republic of Ghana, and are intended only for the enjoyment of residents of Ghana. Ad Libs makes no representation that the Platforms are governed by or operated in accordance with the laws of any other nation.

10.        CHILDREN 

The Digital Assets are not directed to children under thirteen (13) years of age. We do not knowingly collect, use or disclose personal information from anyone under thirteen (13) years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her personal information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personal information from a child under the age of thirteen (13), we will make reasonable efforts to delete such information from our records. 

11.        SECURITY OF YOUR INFORMATION 

We use certain reasonable security measures designed to help protect your personal information. However, no electronic data transmission or information storage can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Platforms and provide us with your information at your own risk. 

12.        CHANGES 

Any changes we may make to our Privacy Policy will be posted on this page and/or communicated to you in other ways if required by law. Please check back frequently to see any updates or changes to our Privacy Policy. If you do not agree or consent to these updates or changes, do not continue to use our Digital Assets or interact with our radio station. 

13.        CONTACT US 

If you have any questions or concerns about this Privacy Policy, the practices of the Digital Assets, or your experiences with the Digital Assets, please contact us at: 

Ad Libs Multimedia Company Limited. 

Attn: Privacy 

29 Kofi Annan Street,

Airport Residential Area,

Accra, Ghana

E-Mail:   adlibsmcl@gmail.com