Privacy Policy

ST Digital Solutions Privacy Policy

Last modified: June 24, 2024

Sarkes Tarzian, Inc. d/b/a ST Radio (“ST Radio,” “us,” “we,” or “our”) values your privacy and wants you to be familiar with how we collect, use and disclose information in relation to the Services that we provide.

This Privacy Policy describes the types of Personal Information we may collect through:

• Your use of our website, https://stradio.com/ (“Website”);
• Our social media pages, including, but not limited to, our LinkedIn, Facebook and Instagram account (collectively, our “Social Media Pages”); and
• Offline business interactions with you.

Collectively, we refer to the Website, Social Media Pages, emails and offline business interactions as the “Services.”

This Privacy Policy does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Sarkes Tarzian, Inc. or any third-party (including our affiliates and licensees) that does not link to this Privacy Policy; or
• Any third party, including our affiliates and licensees, through any application or content (including advertising) that may link to or be accessible from or through the Website.

By using ST Radio’s Services, you consent to the data practices described in this Privacy Policy regarding the collection, use, disclosure and disposal of your Personal Information. This Website and ST Radio’s Services are designed and targeted to United States audiences and are governed by and operated in accordance with the laws of the U.S. If you are not a

U.S. citizen or do not reside in the U.S., you voluntarily consent to the collection, transfer, use, disclosure and retention of your information in the U.S. You agree to waive any claims that may arise under your own national laws.

ST Radio customers’ use of the Personal Information that we collect through the Services is subject to their own privacy practices. This privacy policy only governs our collection and use of your Personal Information while you use our Services and the features and functionality made available to you on or through our Services

Your California Privacy Rights

Generally, California residents are entitled by law to ask ST Radio for free information twice a year identifying the categories of Personal Information which ST Radio shares with its affiliates and/or third parties for their marketing purposes the preceding year, and to provide contact information for such affiliates and/or third parties unless ST Radio meets certain exceptions in the law. This Privacy Policy qualifies for the exception to those requirements. Therefore, if you reside in California and you have an established business relationship with ST Radio, you may request information about ST Radio’s opt-out and opt-in policies of sharing your Personal Information with other companies (including our affiliates) for their marketing purposes. Please send your written request via email or postal mail following the instructions below.

ST Digital will not accept requests via the telephone or facsimile or respond to requests that are not labeled or sent properly, or do not have complete information.

• • For all requests, include your full name, street address, city, state and zip code.
  • If sent via email request, You must state “Re: Your California Privacy Rights” in the subject line and send your email to pteague@sarkestarzian.com
  • If sent via postal request, You must send a letter or post card to:

ST Radio c/o WRCB 900 Whitehall Road

Chattanooga, TN 37405

ATTN: P Teague-Your California Privacy Rights

1. General Information

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices do not use our Services. By accessing or using our Services, you agree to this Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

2. Information We Collect About You and How We Use This Information

Personal Information is information You provide to ST Radio voluntarily or passively through use of the Services, that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer. For the purposes of this Privacy Policy, we also define Personal Information to include such information related to our commercial/business customers and their customers.

We collect several types of information from and about users of our Services, including information:

1. • By which you may be personally identified, such as name, postal address, email address, telephone number (wireless and wireline), or any other identifier by which you may be contacted online or offline;
   • That is about you but individually does not identify you, such as any comments or reviews submitted by you and/or posted to ST Radio’s Website; and/or
   • About your internet connection, the equipment you use to access our Services, and usage details.

We collect this information:

1. • Directly from you when you provide it to us.
   • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies (e.g., Google Analytics).
   • From third parties, for example, our affiliates and licensees.

Information You Provide to Us

The information we and our service providers collect on or through our Services may include:

1. • Information that you provide through the Services, for example, when you register an account to access the Services, contact customer service, fill in an online form on our Website, post a comment or upload images.

The information we collect from other sources may include:

1. • Personal Information from other sources, for example
     • Publicly available databases;
   • Personal Information shared through a social media account that is connected to your Services account, such as your name, email address, list of social media contacts, and any other information that you may be or you make accessible to us when you connect your social media account to your Services account.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

•TopresentourServicesanditscontents to you.

• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with ST Radio’s Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

1. • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
   • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

1. • Estimate our audience size and usage patterns.
   • Store information about your preferences, allowing us to customize our Website according to your individual interests.
   • Speed up your searches.
   • Recognize you when you return to our Website.

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

1. • 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 Website. 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 Website. For information about managing your privacy and security settings for cookies, see Choices About How We Use and Disclose Your Information.

1. • • We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, to analyze trends, to administer the site and to personalize your experience. We also gather statistical information about use of the Services to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them.
     • Cookies further allow us, and third parties we partner with, to select which advertisements or offers are most likely to appeal to you and display them to you. We may also use cookies or other technologies in online advertising to track responses to our ads. We partner with one or more third parties either to display advertising on our Web site or to manage our advertising on other sites. Our third- party partners may use technologies such as cookies to gather information about your activities on this site and other sites to provide you advertising based upon your browsing activities and interests. We do not currently respond to browser do-not-track signals.
     • If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage- cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.
   • Pixel tags and other similar technologies.
     • Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
     • Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and

exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

1. • • Invisible reCAPTCHA. We use Google’s invisible reCAPTCHA application on our Services to protect against spam and other automated abuse. The reCAPTCHA tool may make use of cookies, as well as other information like IP address, date, time, language, screen size and resolution, and mouse movements. The use of the reCAPTCHA tool and any information collected through the tool are subject to Google’s privacy policy, available at https://policies.google.com/privacy, and Google’s terms of service, available at https://policies.google.com/terms?hl=en.
   • Physical Location.
     • We may collect general, region-level information on the location of your device through Google Analytics.

3. Use of Personal Information for Marketing and Advertising Purposes

ST Radio may use your Personal Information to send marketing and advertising messages related to our own Services and Website that may be of interest using your email address, postal address, or telephone number (for voice, texts, automated and pre-recorded calls). We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. For more information, see Choices About How We Use and Disclose Your Information.

ST Radio may deliver a marketing or advertising message based on your visits to ST Radio’s Website, which will be general advertising or “Contextual Advertising,” which is advertising based on the subject matter or the content of the specific website page or subject matter.

ST Radio may also send you “First Party Advertising,” which is advertising or marketing that is customized or personalized based on a history of your use of our Services (possibly combined with information from our Facebook page or other social network platforms). First Party Advertising is based solely on a combination of information ST Radio collects from you – not from your visits to other websites across the Internet. You may opt-out of First Party Advertising but not Contextual Advertising. No Personal Information is used to deliver Contextual Advertising; it automatically will appear based on the content or webpage you are viewing. And You may continue to receive general advertising if You opt-out of First Party Advertising, it will not be customized or personalized for you.

ST Radio does not provide third party “Network Advertising,” which is advertising based on your overall Internet usage across different third-party websites or online services. Multiple third-party websites and online services are involved in this tailored or personalized advertising process, in essence a “network” of advertising providers. Because ST Radio does not provide network ads, ST Radio does not recognize the “Do Not Track” settings on various Internet browsers. ST Radio does not engage or allow third parties to track you across the Internet and across time for advertising purposes.

4. Links to Third Party Websites and Services

The ST Radio Website and Social Media Pages may contain a variety of content and functionality and provide links to other third-party websites or online services. Despite such links, this Privacy Policy applies only to ST Radio and our affiliates. The presence of a link does not constitute or imply ST Radio’s endorsement, recommendation, or sponsorship of the content, goods, services, business or privacy practices on such websites or online services. ST Radio encourages you to be aware and informed when you leave ST Radio’s Website and ST Radio’s social media pages, or any other social networking platforms.

Some content or applications, including advertisements, on the Website are served by third- parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

5. Disclosure of Your Personal Information to Third Parties

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

ST Radio may disclose personal information that we collect, or you provide, as described in this Privacy Policy:

•To our affiliates and licensees. ST Radio relies on various affiliates and subsidiaries licensees in order to provide marketing services to you. ST Radio may share Personal Information and non-Personal Information with any of our affiliates and licensees for business, operational, promotional and/or marketing and advertising purposes related to our Services.

• To our contractors, service providers, and other third parties (“Operational Service Providers”). ST Radio contracts with other companies and people to perform tasks or services on ST Radio’s behalf and need to share your Personal Information to provide products or services to you. For example, ST Radio may use a payment processing company to receive and process your ACH or credit card transactions. ST Radio does not grant its Operational Service Providers any right to use the Personal Information ST Radio shares with them to support our business beyond what is necessary for the purposes for which we disclose it to them.
• For Business Transfers/Restructuring. Sarkes Tarzian, Inc. may choose to buy or sell assets, or Sarkes Tarzian, Inc. may sell assets or be sold. In these types of transactions, your Personal Information is typically one of the business assets that would be disclosed and transferred. If Sarkes Tarzian, Inc., or Sarkes Tarzian, Inc.’s assets are acquired, or Sarkes Tarzian, Inc. goes out of business, enters bankruptcy, or goes through some other change of control, including restructuring, re- organization or financing arrangements, Personal Information could be one of the assets disclosed, transferred to or acquired by a third party.
• To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

1. • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
   • To enforce or apply our Terms of Use Agreement and other agreements, including for billing and collection purposes.

•Ifwebelievedisclosureisnecessaryorappropriatetoprotecttherights,property,or safety of ST Radio, you, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

6. Choices About How We Use and Disclose Your Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:

1. Receiving marketing-related emails from us. If you no longer want to receive marketing-related emails on a going-forward basis, you may opt out by following the unsubscribe instructions included in these emails. Please note that even if you opt out of marketing e-mails, we may continue to send you certain account-related e- mails, such as notices about your account and confirmations of transactions you have requested.
2. Receiving marketing-related text messages from us. If you no longer want to receive marketing-related text messages on a going-forward basis, you may opt out by responding to the text messages with the words “STOP,” “QUIT,” “END,” “REVOKE,” “OPT-OUT,” “CANCEL” OR “UNSUBSCRIBE.”
3. Our sharing of your Personal Information with affiliates for their direct marketing purposes. If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt out of this sharing by emailing pteague@sarkestarzian.com

7. Accessing, Modifying, Correcting and/or Deleting Your Information

You can review and change your Personal Information by logging into the Website and visiting your account profile page. Generally, you may access the following Personal Information in your account:

1. • Full name
   • Email address
   • Telephone number
   • Billing address

You may also send us an email at pteague@sarkestarzian.com to request access to, correct, or delete any Personal Information that you have provided to us. You may not delete any Personal Information that is necessary to provide and bill for Services. ST Radio may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

ST Radio may use any aggregated data derived from your Personal Information but not in a manner that would identify you personally. ST Radio may also maintain Personal Information regarding you and your Services after you are no longer an ST Radio customer as required by ST Radio’s business practices, by law, and/or tax reporting purposes. The information you can view, update, and delete may also change if required by law. If you have any questions about viewing or updating information ST Radio has on file about you, please contact ST Radio at pteague@sarkestarzian.com

8. Retention Period

We retain Personal Information for as long as needed or permitted given the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

1. • The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
   • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them); or
   • Whether retention is advisable given our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

9. Changes to Our Privacy Policy

ST Radio is constantly working to improve our Services and will need to update this Privacy Policy from time to time as ST Radio’s business practices change and service offerings increase, and/or there are changes in local, state or federal laws. ST Radio will also make stylistic, organizational and/or grammatical changes to present ST Radio privacy practices in a user friendly easy to read manner. ST Radio will alert you to any such changes by placing a notice on ST Radio’s Website with the effective date of the revised Privacy Policy, or by some other means to the extent required by law. Please note that if you have not provided ST Radio with your email address or you have not updated your contact information, those legal notices will still govern your use of the Service, and you are still responsible for reading and understanding all notices posted on ST Radio’s Website. Your continued use of the Services

after notice of any changes that have been provided will indicate your acceptance of such changes, except where further steps are required by applicable law.

Use of your Personal Information is primarily governed by the Privacy Policy in effect at the time you visit the Website. If ST Radio elects to use or to disclose Personal Information that identifies you as an individual in a manner that is materially different than that stated in the Privacy Policy in effect at the time you purchased the Service or visited the Website, ST Radio will provide you with an opportunity to consent to such use or disclosure. Depending on the circumstances, that consent may include an opt-out.

10. Use of Services by Minors

The Services are not direct to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.

11. Contact Information

If you have any questions or concerns regarding ST Radio’s privacy practices and policies, or to register a complaint or concern, please contact ST Radio c/o pteague@sarkestarzian.com.