Privacy Policy

Introduction

Lotus Communications Corp., a California corporation (“Lotus” and collectively with its Affiliates who holds broadcast licenses from the Federal Communications Commission, the “Company” or “We”), respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit our Websites listed under Websites below (our “Websites”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On our Websites.
• In email, text, and other electronic messages between you and our Websites.
• Through mobile and desktop applications you download from our Websites, which provide dedicated non-browser-based interaction between you and our Websites.
• When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.It does not apply to information collected by:
• Us offline or through any other means, including on any websites operated by any third party; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or through any of our Websites.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, your choice is not to use our Websites. By accessing or using any of our Websites, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of any of our Websites after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.Children Under the Age of 18

  Our Websites are not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on our Websites. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on our Websites or through any of its features, register on our Websites, make any purchases through our Websites, use any of the interactive or public comment features of our Websites, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at Privacy@LotusCorp.com.

Information We Collect About You and How We Collect It

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

• by which you may be personally identified, such as name, postal address, email address, telephone number, social security number and date of birth, or any other identifier by which you may be contacted online or offline (“personal information”);
• that is about you but individually does not identify you, such as location; and
• about your internet connection, the equipment you use to access our Websites, and usagedetails.
  We collect this information:

• directly from you when you provide it to us;
• automatically as you navigate through one of our Websites, such as usage details, intellectual property addresses, and information collected through cookies, web beacons, and other tracking technologies; and
• from third parties, such as our business partners. Information You Provide to Us
  The information we collect on or through our Websites may include:

• information that you provide by filling in forms on our Websites, such as information provided at the time of registering to use one of our Websites, subscribing to a service, posting material, or requesting further services, and information we ask you for when you enter a contest or promotion we sponsor, or report a problem with our Websites;
• records and copies of your correspondence (including email addresses) if you contact us;
• your responses to surveys;
• details of transactions you carry out through our Websites and of the fulfillment of your orders, such as financial information you provide in connection with orders you place through our Websites; and
• your search queries on our Websites.You also may provide information to be published or displayed (“posted”) on public areas of one of our Websites or transmitted to other users of our Websites or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of our Websites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.Information We Collect Through Automatic Data Collection Technologies

  As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • details of your visits to our Websites, including traffic data, location data, logs, and other communication data and the resources that you access and use on our Websites; and

• Information about your computer and internet connection, including your intellectual property address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Click here [ad link to Do Not Track Disclosures] for information on how you can opt out of behavioral tracking on our Websites and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

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

• estimate our audience size and usage patterns;
• store information about your preferences, allowing us to customize our Websites according toyour individual interests;
• speed up your searches; and
• recognize you when you return to our Websites.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 Websites. 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 Websites. For information about managing your privacy and security settings for cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of our Websites and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Websites statistics (for example, recording the popularity of certain Websites content and verifying system and server integrity).We do not collect personal information automatically, but we may tie non-personal information collected automatically to personal information about you that we collect from other sources or that you provide to us.Third-Party Use of Cookies and Other Tracking Technologies

  Some content or applications, including advertisements, on our Websites 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 Websites. 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 third parties use this technology. 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.

How We Use Your Information

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

• to present our Websites and its contents 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 carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to notify you about changes to our Websites or any products or services we offer or provide though one or more of them;
• to allow you to participate in interactive features on our Websites;
• In any other way we may describe when you provide the information; and
• for any other purpose with your consent.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.Disclosure of Your Information

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

  We may disclose personal information that we collect or you provide as described in this privacy policy:

• to our subsidiaries and affiliates.
• to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Websites users is among the assets transferred;
• to fulfill the purpose for which you provide it;
• for any other purpose disclosed by us when you provide the information; and
• with your consent.

We also may disclose your personal information:

• 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 [INSERT AS LINK TO WEBSITES’S TERMS OF USE] and other agreements, including for billing and collection purposes; and
• If we believe disclosure is necessary or appropriate to protect the Company’s rights, property, or safety, or that of our customers, or others.Choices About How We Use and Disclose Your InformationWe strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information.
  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always opt-out by logging into our Websites and adjusting your user preferences in your account profile, checking, or unchecking the relevant boxes.
  • Promotional Offers from the Company. If you do not wish to have contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or at any other time by logging into our Websites and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
  • Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by logging into our Websites and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes. For this opt-out to function, you must have your browser set to accept all browser cookies.We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s Websites.Accessing and Correcting Your Information

    You can review and change your personal information by logging into our Websites and visiting your account profile page.

    You may also send us an email at Privacy@LotusCorp.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We 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.

If you delete your User Contributions from our Websites, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Websites users. Proper access and use of information provided on our Websites, including User Contributions, is governed by our Terms of Use [URL LINK TO WEBSITES’S TERMS OF USE.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

To learn more about California residents’ privacy rights, please see “Additional California Privacy Disclosures” below. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Websites that 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 send an email to Privacy@LotusCorp.com or write us at Lotus Privacy, 3301 Barham Boulevard, Los Angeles, California 90068.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to Privacy@LotusCorp.com.

Additional California Privacy Disclosures

For purposes of California law, please note the following.

We collect and use the following categories of personal information for the business and commercial purposes described in this Privacy Policy: identifiers; personal information categories listed in Cal. Civ. Code § 1798.80(e); characteristics of protected classifications under California or federal law; commercial information; audio (voice) information and visual information; internet or other electronic network activity information; geolocation data; professional information; sensitive personal information; and inferences. We use the above-described categories of personal information for our business and commercial purposes described above.

We may collect these categories of personal information from the following categories of sources, as more fully described above: directly from you; automatically from your devices; from our service providers; from our business partners; from other users; and from our corporate affiliates, subsidiaries, and parents.

We disclose each of the foregoing categories of personal information to our affiliates, service providers, advertisers, data analytics providers, with entities for legal compliance purposes, and with potential acquirers of parts of our business.

We may “sell” or “share” the following categories of personal information: identifiers; personal information categories listed in Cal. Civ. Code § 1798.80(e); commercial information; internet or other electronic network activity; geolocation data; and inferences. We may sell and share this personal

information with advertisers, advertising networks, and social networks. We do not knowingly sell or share the personal information of consumers under 18 years of age.

We do not use or disclose sensitive personal information for purposes other than those specified under applicable California privacy regulations.

During 2023, the Company received no (0) California rights requests.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted [using SSL technology].

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of our Websites like message boards. The information you share in public areas may be viewed by any user of our Websites.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Websites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Websites.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify through a notice on our Websites home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Websites and this privacy policy to check for any changes.

Privacy Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Lotus Privacy
3301 Barham Boulevard
Los Angeles, California 90068

or at Privacy@LotusCorp.com.