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EAGLE FINANCIAL PUBLICATIONS PRIVACY POLICY

(Effective and Last Modified June 22, 2020)

This privacy policy is for Eagle Financial Publications, a business unit of
Salem Media Group, Inc. together with its subsidiaries, affiliates, agents and
licensees (collectively “we,” “us,” or “our”). We have adopted this privacy
policy (“Privacy Policy”) to explain what information may be collected when you
access this website or app or any other website on which we place this Privacy
Policy (“Website”), use our online or other services, or use any of our mobile
or other applications (each, an “App”), how we and others use this information,
under what circumstances we may disclose the information to third parties, and
the instances in which we may allow third parties to collect information
directly.  Depending on your activities when using or accessing our Website or
App (collectively, the “Services”), you may from time-to-time be required to
agree to additional terms and conditions. For clarity, our Services include any
promotion which refers to this Privacy Policy for terms regarding the collection
and use of your information.

Please note that this Privacy Policy applies only to information we collect from
you through our Services and information you voluntarily provide to us in person
at our events and does not apply to our collection of information through other
methods (e.g., over the telephone, etc.), information provided to us by third
parties, or information you provide to third parties.

Modifications to this Privacy Policy

We generally keep this Privacy Policy posted on our Website and in our App.  You
should review this Privacy Policy frequently, as it may change from time to time
without notice. Any changes will be effective immediately upon the posting of
the revised Privacy Policy.  WHEN YOU USE OUR SERVICES, YOU AGREE TO THIS
PRIVACY POLICY.  IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES
WE MAY SUBSEQUENTLY MAKE, IMMEDIATELY STOP USING OUR SERVICES.  Please note,
however, that if we decide to use your personally identifiable information in a
manner materially different than what is provided in this Privacy Policy or what
we advised at the time it was collected, we will notify you of this change by
e-mail to the last e-mail address provided to us or through our Applications.
You will have a choice (by means of an “opt out” opportunity) as to whether we
use their information in this different manner.  In such case, we will use your
personally identifiable information in accordance with the terms in place when
the information was collected. 


A. INFORMATION WE COLLECT

We typically collect two kinds of information about you when you use our
Services: (1) information that you provide that personally identifies you; and
(2) information that does not personally identify you that we automatically
collect or that you provide us.  We also collect information if you voluntarily
provide it to us at one of our events, which may personally identify you.

(1)  Personally Identifiable Information:  Our definition of personally
identifiable information includes any information that may be used to
specifically identify or contact you, such as your name, mail address, phone
number, etc.  As a general policy, we do not automatically collect your
personally identifiable information when you use our Services.  In certain
circumstances, we may request, allow or otherwise provide you an opportunity to
submit your personally identifiable information in connection with a feature,
program, promotion or some other aspect of our Services.  For instance, you may:
(a) provide your name, mail/shipping address, email address, credit card number
and phone number when registering with our App or Website, or in connection with
your participation in a promotion; (b) provide certain demographic information
about you (e.g., age, gender, purchase preference, usage frequency, etc.) when
using our App, or participating in a survey or poll; or (c) post a general
comment and/or recommendation through our Services.  Certain information may not
be personally identifiable when standing alone (e.g., your age), but may become
so when combined with other information (e.g., your age and name).  Whether you
provide this information is your choice; however, in many instances this type of
information is required to participate in the particular activity, purchase a
product or service, or gain access to certain content or features available
through our Services.  

(2)  Non-Personally Identifiable Information:  Our definition of non-personally
identifiable information is any information that does not personally identify
you.  Non-personally identifiable information can include certain personally
identifiable information that has been de-identified; that is, information that
has been rendered anonymous.  We obtain non-personally identifiable information
about you from information that you provide us, either separately or together
with your personally identifiable information.  We also automatically collect
certain non-personally identifiable information from you when you access use our
Services.  This information can include, among other things, the computer,
mobile device or equipment (“Device”) you are using, other applications or
software you are using, your mobile carrier and mobile network information, your
IP addresses or Device identifier, the type of browser (e.g., Safari, Opera,
etc.) and operating system you are using (e.g. Android, iOS, etc.), your search
queries, and how much you use our Services. 

Location Information:  As noted, when you use our Services, particularly our
App, we may automatically collect certain Device-specific information.  This
includes the general or specific location of your Device through GPS, Bluetooth
or WiFi signals.  Before we collect or send location-specific information, it is
our practice to ask for your consent.  In some instances, your operating system
may not allow you to install our App unless you provide consent. In all
instances, you may withdraw your consent by disabling location features for your
Device – the App will still work though certain location features (e.g., Store
Locator) may not function and certain other Services may be limited.

B. HOW WE USE & SHARE THE INFORMATION COLLECTED 

(1)  Personally Identifiable Information: The personally identifiable
information you submit to us is generally used to carry out your requests,
respond to your inquiries, better serve you, or in other ways naturally
associated with the circumstances in which you provided the information.  We may
also use this information to later contact you for a variety of reasons, such as
customer service, providing you promotional information for our products or
those of our parent company, subsidiaries or other affiliated companies
(“affiliated companies”), or to communicate with you about content or other
information you have posted or shared with us via use of our Services. You may
opt-out from receiving future promotional information from us or our affiliated
companies, or direct that we not share your information with any affiliated
companies, as set forth below. However, the use of certain Services may be
conditioned on your ongoing consent to provide you promotional information.

In certain instances, we may also share your personally identifiable information
as follows:

 * With our third-party vendors performing functions on our behalf (or on behalf
   of our affiliated companies) – e.g., vendors that operate the Website or App,
   process credit card orders, administer our promotions, provide us marketing
   or promotional assistance, analyze our data, assist us with customer service,
   etc.  Our vendors agree to use this information, and we share information
   with them, only to carry out our requests; and
 * With participating third-party sponsors to a program or promotion (e.g., a
   sweepstakes or contest) you enter via our Services and certain third-party
   co-promotional partners and others with whom we have marketing or other
   relationships. 

Except as provided in this Privacy Policy, your personally identifiable
information will not be shared or sold to any third parties without your prior
approval.  

(2)  Non-Personally Identifiable Information: We use non-personally identifiable
information in a variety of ways.  For example, we may use non-personally
identifiable information to evaluate use of our Services, track the types of
products being purchased, gauge coupon or offer redemption rates, understand
customer needs and trends, carry out targeted promotional activities, and to
improve our Services. We may use your non-personally identifiable information by
itself or aggregate it with information we have obtained from other customers or
other sources. We may, among other things, share your non-personally
identifiable information with our affiliated companies, allow third parties to
collect such information directly from you, and/or sell the non-personally
identifiable information to third parties to achieve these and any other
business objectives (e.g., generate revenue, form relationships, etc.). 
However, it is important to remember that your non-personally identifiable
information (whether standing alone or combined with other non-personally
identifiable information) is anonymous information that does not personally
identify you. 

C. TRACKING TECHNOLOGIES 

(1)  Cookies/Web Beacons. We automatically receive and store certain types of
non-personally identifiable information whenever you interact with us. For
example, like many websites, we use “cookies,” “web beacons” (also called “clear
gifs” or “pixel tags”) and embedded scripts to obtain certain types of
information when you use or access our Services. “Cookies” are small files that
we transfer to your computer’s hard drive or your web browser memory to enable
our systems to recognize your browser and to provide convenience and other
features to you. “Web beacons” are tiny graphics with a unique identifier,
similar in function to cookies, and may be used to track the online movements of
users, when an email has been opened, and to provide other information.

Examples of the information we collect and analyze in this manner include the
Internet Protocol (IP) address used to connect your Device to the Internet;
computer and connection information such as browser type and version, operating
system, and platform; your activities our Website, including the products you
view or searched for, as well as the URL you come from and go to next (whether
this URL is on our Website or not); and cookie number. It is important to note
that the cookies and web beacons that we use do not contain and are not tied to
personally identifiable information about you.

If you are concerned about the storage and use of cookies, you may block or
limit the storage of cookies via browser controls or other software (we do not
promise that our Services will recognize or work with any such browser
controls/software – e.g., see below for Do Not Track options).  You may also be
able to delete cookies manually from your Device through your internet browser,
operating system or other programs.  Please note, however, that some portions of
our Services will not function properly or be available if you are able and do
block and/or delete cookies.


(2) Preference Based Advertising: We may work with third parties, including
advertising companies and website analysis firms, who use cookies and web
beacons to collect non-personally identifiable information when you visit our
Website and third party sites. This non-personally identifiable information,
collected through cookies and web beacons, is typically used by these
third-party advertising companies (i.e., advertising networks) to serve you with
advertisements while on third party sites tailored to meet your preferences and
needs.  If you do not wish to participate in this activity, go to
www.aboutads.info and follow the simple opt-out process.

A couple of important notes about this opt-out tool: (1) it includes all the
advertising networks that we may work with, but also many that we do not work
with; and (2) it may rely on cookies to ensure that a given advertising network
does not collect information about you (“Opt-out Cookies”) – an explanation of
how Opt-out Cookies work can be found on www.aboutads.info.  Therefore, if you
use different Device, change web browsers or delete these Opt-out Cookies from
your computer, you will need to perform the opt-out task again. In addition,
third party mobile applications, such as AppChoices (offered by the Digital
Advertising Alliance), may allow you to opt out of preference based advertising
via your Device. 

(3) Do Not Track Features: Certain internet browsers may offer you the option of
providing notice to websites that you do not wish for your online activities to
be tracked for preference based advertising purposes (“DNT Notice”). Some
browsers are, by default, set to provide a DNT Notice, whether that reflects
your preference. Please note that with respect to our Website, we do not take
any action based on browser based DNT Notices. If you do not wish to participate
in preference based advertising activities, you should follow the simple opt-out
process identified above.  

D. OTHER USES & INFORMATION 

(1)  Email Communications:  If you send us an email with questions or comments,
we may use your personally identifiable information to respond to your questions
or comments, and we may save your questions or comments for future reference. 
For security reasons, we do not recommend that you send non-public personal
information, such as passwords, social security numbers, or bank account
information, to us by email.  However, aside from our reply to such an email, it
is not our standard practice to send you email unless you request a particular
service or sign up for a feature that involves email communications, it relates
to purchases you have made with us (e.g., product updates, customer support,
etc.), we are sending you information about our other products and services, or
you consented to being contacted by email for a particular purpose. In certain
instances, we may provide you with the option to set your preferences for
receiving email communications from us; that is, agree to some communications
but not others. You may “opt out” of receiving future commercial email
communications from us by clicking the “unsubscribe” link included at the bottom
of most emails we send, or as provided below; provided, however, we reserve the
right to send you transactional emails such as customer service communications. 

(3) Transfer of Assets:  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, the personally identifiable information and non-personally
identifiable information we have about you will be transferred to and used by
this acquiring entity, though we will take reasonable steps to ensure that your
preferences are followed. 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. 

(4) Other: Regardless of any other provision in this Privacy Policy, we reserve
the right to disclose any personally identifiable or non-personally identifiable
information about you if we are required to do so by law, with respect to
copyright and other intellectual property infringement claims, or if we believe
that such action is necessary to: (a) fulfill a government request; (b) conform
with the requirements of the law or legal process; (c) protect or defend our
legal rights or property, our Services, or other users; or (d) in an emergency
to protect the health and safety of our customers or the general public.

E. PUBLIC FORUMS 

We may offer Services with chat rooms, blogs, message boards, bulletin boards,
the ability to post user generated content or similar public forums where you
and other users of our Services can communicate. The protections described in
this Privacy Policy do not apply when you provide information (including
personal information) in connection with your use of these public forums.  We
may use personally identifiable and non-personally identifiable information
about you to identify you with a posting in a public forum.  Any information you
share in a public forum is public information and may be seen or collected by
anyone, including third parties that do not adhere to our Privacy Policy. We are
not responsible for events arising from the distribution of any information you
choose to publicly post or share through our Services. 

F. SPECIFIC PRIVACY RIGHTS

(1) Children: Neither our App nor any of our other Services are intended for
children under the age of 13.  We do not knowingly collect personally
identifiable information from children under the age of 13.  If you are a parent
or guardian of a child under the age of 13 and believe he or she has disclosed
personally identifiable information to us, please contact us at
childprivacy@salemmedia.com.  A parent or guardian of a child under the age of
13 may review and request deletion of such child’s personally identifiable
information as well as prohibit the use of that information. 

(2) California: Beginning January 1, 2005, California Civil Code Section 1798.83
permits customers who are California residents to request certain information
regarding our disclosure of personal information to third parties for their
direct marketing purposes. To make such a request, please contact us by clicking
the Contact Us link on our Website.

Beginning January 1, 2020, the California Consumer Privacy Act provides certain
additional rights to California consumers with respect to personal information
we obtain about them.  For more information about those rights and how to
exercise them, please read the Eagle Financial Publications CCPA Privacy Notice
for California Residents, at
https://salemmedia.com/eagle-financial-publications-ccpa-privacy-notice-for-california-residents/

G. KEEPING YOUR INFORMATION SECURE 

We have implemented security measures we consider reasonable and appropriate to
protect against the loss, misuse and alteration of the information under our
control.  Please be advised, however, that while we strive to protect your
personally identifiable information and privacy, we cannot guarantee or warrant
the security of any information you disclose or transmit to us online or through
our Services, and are not responsible for the theft, destruction, or inadvertent
disclosure of your personally identifiable information. In the unfortunate event
that your “personally identifiable information” (as the term or similar terms
are defined by any applicable law requiring notice upon a security breach) is
compromised, we may notify you by e-mail (at our sole and absolute discretion)
to the last e-mail address you have provided us in the most expedient time
reasonable under the circumstances; provided, however, delays in notification
may occur while we take necessary measures to determine the scope of the breach
and restore reasonable integrity to the system as well as for the legitimate
needs of law enforcement if notification would impede a criminal investigation. 
You will also receive any notification required by law.  From time to time we
evaluate new technology for protecting information, and when appropriate, we
upgrade our information security systems. 

H. THIRD PARTY DATA/SERVICES

(1)  Social Networks. We may allow you to register for an account with us by
using an account you have with a social network or other third-party, such as
Facebook, Google, Twitter, etc. (“Social Network Account”).  In such instances,
we may receive and you are granting us access to certain information regarding
your Social Network Account (e.g., friends, mutual friends, contacts, etc.). We
may make this information available on or through the Services and to our
users.  You may be able to restrict what information is shared and how it is
used through privacy and other settings.  Also, depending on the privacy
settings you have set in your Social Network Account, personally identifiable
information may be shared with us and made available through the Services, to
our users, and to the third party operating your Social Network Account.

(2)  Third Party Services. Our Services may link to, contain links to or embed
functionality provided by third parties, such as reward programs, surveys, etc.
(“Third Party Services”).  We do not control or maintain Third Party Services,
nor are we are not responsible for the privacy practices employed by any
provider of a Third Party Service. We encourage you to read the privacy
statements applicable to all Third Party Services before submitting any
personally identifiable information through these websites. 

I. CONTACT & OPT-OUT INFORMATION 

You may contact us as via the Contact Us link on the Website if: (a) you have
questions or comments about our Privacy Policy; (b) wish to make corrections to
any personally identifiable information you have provided; (c) want to opt-out
from receiving future commercial correspondence, including emails, from us or
our affiliated companies; or (d) wish to withdraw your consent to sharing your
personally identifiable information with others. 

We will respond to your request and, if applicable and appropriate, make the
requested change in our active databases as soon as reasonably practicable. 
Please note that we may not be able to fulfill certain requests while allowing
you access to certain benefits and features of our Services.  

J. SOLE STATEMENT 

This Privacy Policy as posted is the sole statement of our privacy policy with
respect to our Services, and no summary, modification, restatement or other
version thereof, or other privacy statement or policy, in any form, is valid
unless we post a new or revised policy to the Website and/or App.


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