Gray Local Media, Inc. Privacy Policy

Updated and Effective 7/1/2024

Table of Contents

Introduction

We at Gray Local Media, Inc. (“GLM”), along with our television stations (“Stations”), respect your privacy. Our Privacy Policy explains what information we may collect from and about you and how we may use and share your information. We provide a link to this Privacy Policy wherever it applies, such as on our Station websites, our mobile apps, our social networking presence, and other offline or online services that we provide and control (“Services”). By using our Services, you accept our practices as described in this Privacy Policy.

Information We Collect

When you use our Services, we may access or collect personal information about and from you. We may collect this information from you directly when you provide it to us for a specific purpose, such as when you enter a contest or send us information about a news story. We may collect information about you from third party sources, such as ad networks. We also may automatically collect certain information, such as through the use of analytics tools that evaluate how you interact with our online content.

We may collect the following categories of personal information:

• Identification information, including: account information, name, user credentials;
• Contact information, such as your email address, street address and phone number;
• Financial information needed to complete a transaction;
• Demographic information, such as your age or gender;
• Professional or employment information, including information you may include on your resume or include in a job application;
• Sensitive information, such as your race or ethnicity, if you choose to share that with us, or precise geolocation information when you enable certain features of our apps and Services;

• Analytics data, such as what links you click, the pages you visit, features used, the dates and times you use our Services;
• Device or system information, such as Mobile Device Identifier, e.g., UDID, Android ID, type of device, operating System (OS), and IP address; and
• Social Network information, such as your social media handle or your “likes” when you make this information public.

How We Use Your Information

We use the information we collect for a variety of business purposes, including to:

• Provide automated updates concerning news, sports, weather, or emergencies;
• Conduct polls and surveys;
• Administer contests, sweepstakes, and other promotions;
• Provide shopping and e-commerce services;
• Offer chat features, blogs, message boards, comment boards, social networking, and other opportunities for you to submit your content and engage with us; and
• To responses to your comments and questions.

We may also use the information we collect to:

• Perform analytics and improve our products and Services;
• Develop reports regarding usage, activity, and statistics;
• Comply with applicable laws, regulations, and legal process;
• Protect health, safety, or welfare;

• Keep a record of our transactions and communications;
• Facilitate the provision of software updates and product support;
• Improve products and other Services or provide Services or technologies to you;
• Connect non-personal information we automatically collect with personal information you provide to us or connect personal information about you from various sources.

How We May Disclose Your Information

To provide our Services, we may disclose your personal information to certain third parties, including:

• GLM affiliates for business, operational, promotional or marketing purposes;
• Our co-sponsors if you participate in a co-branded, co-sponsored, or jointly presented promotion, contest, or other Service;

• Our Analytics providers;
• Our vendors or service providers, who are generally restricted from using your personal information for any purpose other than that for which we hire them;
• In the event of a merger, sale or change of control of our business;
• With law enforcement or government entities, where reasonably necessary to comply with applicable law, legal process or government request, or to enforce our policies, including to detect, prevent or otherwise address fraud or security issues; and
• To others with your consent or at your direction.

Location Information

If you enable certain features, we may obtain location information from your device to provide location-related services, for example, weather alerts or breaking news alerts. Your location information may be shared with third parties that we have contracted with to perform the location-based features of our Services or collected by and/or shared with our third-party partners who help to provide you personalized advertisements.

We will ask for your permission before collecting this location data. You can withdraw consent to use precise, real-time or network location data at any time by turning off the location-based feature on your mobile device or by opting out of using any location-based features. If you withdraw consent, functionality associated with precise, real-time or network location may be limited.

Advertising and Personalized Content

Advertising is important to our provision of free and low-cost Services to you. We may share your personal information with our advertisers, advertising networks, or other third parties for direct marketing and promotional purposes. Additionally, GLM and its Stations, our advertisers, certain outside network advertising services, and other third parties may place cookies, web beacons, and other similar technology on your device to personalize your experience, collect information about your preferences, collect location information, and/or deliver customized advertising content.

Advertisers and other third parties involved in the delivery of ads to you may offer you opportunities to choose what type of information about you is collected, used, and shared, and how that is done. We do not control outside parties or the choices they may offer you – please contact them directly to learn about your choices.

Cookies and Similar Technologies

A “cookie” is a small text file stored on your device that helps us recognize repeat visitors, personalize your experience, deliver Services efficiently, monitor how our Services are used, deliver customized advertising, and for other purposes.

We also use other digital technologies, including web beacons, pixel tags, or clear GIFs. These are small, transparent graphic images that are placed on a web page or in an email and used to monitor the activity of the user accessing that web page or email. These digital technologies are used for website traffic reporting, measuring advertising effectiveness, customizing users’ online experiences, and for other purposes.

Like most online operators, we use these technologies to collect information about our website and app users automatically, deliver Services, tailor your experience, monitor how our Services are used, improve them, and deliver customized advertising, as well as for other related purposes.

You may configure your browser to reject cookies. But if certain cookies are disabled, you may not be able to use all features of our Services. We do not currently respond to a web browser’s “do not track” signals.

Social Media

Our Services may use social media plug-ins (e.g., the Facebook “Like” button, “Share to Twitter” button) to enable you to easily interact with certain social media websites (e.g., Facebook, Twitter, Instagram) and share information with others. When you visit our online Services and engage with these plug-ins, the social media platforms can place a cookie or pixel on your device enabling such operators to recognize individuals who have previously visited our online Services. If you are logged into these social media websites while visiting our online Services, the social media plugins allow the relevant social media websites to receive information that you have visited our online Services or other information. The social media plugins also allow the applicable social media websites to share information about your activities on our online services with other users of the social media website. We do not control any of the content from the social media plugins. We may also interact with you on social media platforms. If you contact us on one of our social media platforms, request services, or otherwise communicate directly with us on social media, we may contact you to interact with you. For more information about social media advertising and social media plugins from other social media websites, please refer to those websites’ privacy and data sharing statements.

Safeguarding Children’s Privacy

Our Services are not directed to children. We do not knowingly collect personal information online from children under 16 years of age.

Accessing Account Information

Certain Stations and Services may allow you to register for an account. If these functions are available, you may view your user profile and related information, update that information or delete that information or account. If you delete your account, we will delete information associated with your account, except as prohibited by applicable law or as needed to protect the rights and property of GLM and its users. Changes you make to account information may not occur in all copies or back-ups held by us or others, or if we determine that the change would be unduly expensive or burdensome. We may deny a request to access, change or delete account information if we believe there is a question about the identity or authority of the requester.

Retention Policy

Unless otherwise required by law, it is our policy not to retain Personal Information or Sensitive Personal Information for longer than is reasonably necessary to achieve the purpose for which it was collected. The criteria we use to determine specific retention periods include whether you have provided your consent and have not withdrawn it; whether there are other legal grounds for the continued processing; whether you have objected to the processing and there are no overriding legitimate grounds for the processing; and whether retention or deletion is necessary to comply with legal obligations.

Information Security

We take steps to protect the security of the information you provide us. Yet, no security is perfect, and transmissions over the Internet are potentially vulnerable. Please use caution when disclosing your personal information.

Third Party Websites

If you choose to use any of the links we provide to third parties, you will be leaving our Services and going to a new site or platform. Our Privacy Policy does not apply to services offered by other companies or individuals, even if a product or site is linked to our Services and even if a relationship exists between GLM and a third party. Protection of your privacy at those other sites or platforms will be governed by the privacy policy at that site or platform. GLM and our Stations have no responsibility for the privacy policies or business practices of a third party we neither own nor control. Please take the time to read the privacy policies at these third-party sites or platforms. It is your choice whether or not to leave our Services and go to third-party sites or platforms.

Changes to the Privacy Policy

We may change this Privacy Policy from time to time. When we change our Privacy Policy, we will update the date at the top of the policy. If the changes are significant, we will provide a more prominent notice. By using our Services following a change to this Privacy Policy, you accept our practices as described.

Contact Us

If you have questions or comments regarding this Privacy Policy, please e-mail us at privacyrights@graymedia.com or via postal mail to:

Gray Local Media, Inc.

Attn: Privacy Policy

VP Digital Media

4370 Peachtree Rd. NE Atlanta, GA 30319

Additional Information for California Residents

Information We Collect

We collect certain categories of information directly from you when you provide them to us, from third parties, and automatically when you use our Services. We collect the following categories of personal information listed in the INFORMATION WE COLLECT section of our general privacy policy.

How We Use Your Information

We use the information we collect to for a variety of business purposes, including the purposes listed in the HOW WE USE YOUR INFORMATION in our general privacy policy.

Your California Consumer Rights

As a California resident, you have certain rights to your Personal Information.

• The right to know what Personal Information the business has collected about you;
• The right to delete Personal Information that the business has collected from the consumer, subject to certain exceptions;
• The right to correct inaccurate Personal Information that we have about you;
• The right to opt-out of the sale or sharing of Personal Information or Targeted Advertising by the business;
• If the business uses or discloses sensitive Personal Information for certain reasons, the right to limit the use or disclosure of sensitive Personal Information by the business; and
• The right not to receive discriminatory treatment by the business for exercising your privacy.

How to exercise your rights

You may submit a verifiable consumer request to exercise your California privacy rights described above by:

o Contacting us online,

o calling us toll free at (888) 896-0662

o emailing privacyrights@graymedia.com

You can request to opt-out out of the sale or sharing of your personal information here: Do Not Sell My Personal Information.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

If we are unable to take the action you requested (e.g., because we are required to keep information for legal reporting purposes), our response will explain our reasons.

“Selling” and “Sharing” Personal Information We use digital technologies, including online identifiers, to provide you with personalized marketing and perform online analytics. We may disclose these online identifiers to our analytics and marketing partners. The CCPA considers this to be Selling and Sharing of your personal information. GLM does not have actual knowledge that it Sells or Shares Personal Information about consumers under 16 years of age.

Additionally, we may share your information with co-sponsors of our contests and promotions, which also could be considered a Sale under the CCPA.

California “Shine the Light Act”

If you reside in California and have an established business relationship with us, you may have the right to receive information about how we share your personal information with our affiliates or third parties, such as our advertisers. If you wish to learn about our practices, please send a written request to the contact information identified above. Please identify that your request is pursuant to the California “Shine the Light” Act. GLM is not able to provide information about how companies outside GLM might use or disclose your information.

Additional Information for Residents of Colorado, Connecticut, Oregon, Texas and Virginia

Your Consumer Rights

As a resident of Colorado, Connecticut, Oregon, Texas and Virginia, you may have certain rights to your Personal Information, including.

• The right to know what Personal Information the business has collected about you;
• The right to delete Personal Information that the business has collected from or about you, subject to certain exceptions;
• The right to correct inaccurate Personal Information that we have about you;
• The right to opt-out of the sale or sharing of Personal Information or Targeted Advertising by the business;

How to Exercise Your Rights

You may submit a verifiable consumer request to exercise your privacy rights by:

• Contacting us online,
• calling us toll free at (888) 896-0662
• emailing privacyrights@graymedia.com

Only you, or an authorized agent that you have authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

If we are unable to take the action you requested (e.g., because we are required to keep information for legal reporting purposes), our response will explain our reasons. You may have a right to appeal our decision with regard to your request. To do so, please send an email to privacyrights@graymedia.com with the word “Appeal” in the subject line.

Personal Information used for “Targeted Advertising”

We use digital technologies, including online identifiers, to provide you with personalized marketing and perform online analytics. We may disclose these online identifiers to our analytics and marketing partners. Certain state privacy laws consider this use to be “Targeted Advertising” or the “sale” of personal information.

Additionally, we may share your information with co-sponsors of our contests and promotions, which also could be considered a sale.

Additional Information for Nevada Residents

This section of the Privacy Policy only applies to residents of Nevada. If you are not a resident of Nevada, this section does not apply to you. Terms that are capitalized are defined in the Nevada law.

As defined under Nevada law, we do not sell Covered Information. However, Nevada Consumers may submit a verified request at any time directing that we not make any Sale of any Covered Information that we have collected or will collect about the consumer, as defined under the Nevada law. To submit such a request, you can email privacyrights@graymedia.com.