PLEASE READ THIS PRIVACY POLICY AND THE 270 Media TERMS OF SERVICE PRIOR TO USING, ACCESSING, OR DOWNLOADING ANY 270 Media LLC WEBSITE, APPLICATION, OR SOFTWARE.

270 Media LLC develops and publishes digital services for web and mobile devices. “270 Media LLC,” or “we” or “our” or “us” refers to 270 Media LLC., and any of its affiliates, and subsidiaries (collectively, “270 Media”).

This Privacy Policy applies to each 270 Media web app and mobile application that links to this Privacy Policy (collectively, the “Products”). This includes, for example the Hello Marin mobile app, the Local Getaways mobile app, and the Marin Magazine Curated Itineraries web app. All of these are referred to collectively as our 'Products."

CATEGORIES OF PERSONAL INFORMATION WE COLLECT

‍Passive Information

Passive information refers to information that is automatically collected from your device(s) when you access the App and use the Services. 270 Media may collect passive information such as your mobile device type or geographic location (if you've granted permission). Your device typically sends passive information to our servers without your intervention whenever you visit our Apps and use the Services. For example, your device may tell the type device you are using. When you use our apps, the app’s server may also tell us information such as the page or link that led you to Apps and the pages you visit inside of the app.

Personal Information

Personal information means information that is specific to you and can be used to contact or identify you. By accessing the Product through a social network, mobile device or other third party platform or service or by connecting to such a third party network, platform or service via a Product, you are authorizing 270 Media to collect, store, and use in accordance with this Privacy Policy any and all information that you agreed the social network, mobile device or other third party platform could provide to 270 Media through the social network/mobile device/third party platform Application Programming Interface (API) based on your settings on the third party social network, mobile device or platform. Your agreement takes place when you connect with the third party network, platform or service via the Service, and/or when you connect with a Product, or “accept” or “allow” (or similar terms) a Service to access your information through a social network, mobile device or other third party platform or service. If you choose to access the Service by using your Facebook account as your login, we may receive from Facebook certain categories of personal information about you that you authorize Facebook to disclose, such as your user name, date of birth, friend list, email address and profile picture, or you may voluntarily disclose information such as your gender or your play preferences to us through your use of the Products. Any information directly collected through your Facebook account and shared with us will be imported, used and stored in a manner consistent with the Facebook Platform Policy applicable to developers in effect at the time of collection (see https://developers.facebook.com/policy/) and in compliance with any specific privacy settings set by you of which we are aware.

Use of Personal Information

270 Media will use personal information collected in our mobile and web app Products in the following ways:

• To fulfill your requests for our Products;

• To process and respond to your inquiries;

• To improve the Products, including diagnosis or problems with the Products;

• To help us better understand characteristics of our users;

• To present content that is tailored to your interests;

• To offer you other opportunities that we think may be of interest to you. If you enter a sweepstakes, contest, or similar promotion, 270 Media  may use the information you provide to administer those programs. Your participation in online game events is conditional upon you granting 270 Media permission to collect, use, store, transmit and display publicly statistical data, such as your scores, rankings and achievements, generated through your participation.

Email and Text Messaging Marketing

In addition, 270 Media may use personal information to communicate with you through email regarding new products, new features, product updates, enhancements, special offers, or promotions for the application services. These communications may also include offers from 270 Media's marketing partners. Emails we send you may include a web beacon that tells us whether and at what time you have received or opened the email or clicked a link within the email. If you do not want us to use your personal information in this way, or to provide your personal information to third parties for their marketing purposes, please uncheck the appropriate box when you register or you can opt out by contacting us at connect@localgetaways.com. You can also opt out by clicking on the “unsubscribe” button on the emails or turning off the Local Getaways application push notifications in the Account Settings in the App or in the Settings on your smartphone.

Usage Information We Collect

In our Products, you can take photos, like and save business listings, check in at businesses, and much more. We call all of the things you can do in the app "activity" and these activities show up in a public activity feed in our mobile apps if you have made your profile on that particular app public. We collect your activity across our Products like:

• Content you create, like trips, and the information you add to your profile.
• Content you provide through our camera feature or your camera roll settings
• Interactions with the app's content. For example, you like, save, share, and check in at listings in the app
• Types of content you view or interact with, and how you interact with it.
• The time, frequency and duration of your activities on our Products.
• Your profile photo if you provide it.

If you use our Products as a guest, your information will still be collected, but may not be personally identifiable.

App, browser and device information

Device information we collect and receive includes:

• The device you’re using, and other device characteristics.
• Identifiers that tell your device apart from other users’, including Family Device IDs..
• Information you’ve shared with us through device settings, like GPS location, and camera access, and only the photos that you have added to our Products.
• Location-related information, if Location Services is turned on in your device settings.
• Information about the Product's performance on your device.

Here are some of the ways we use your usage information:

• We personalize your experience, like prioritizing content types based on interests or activities in the app
• We improve Hello Marin by applying information about what you use it to do, and what else is happening on your device when our app crashes
• We work to prevent harmful behavior and keep people safe on our Products
• We send you messages about Hello Marin if you let us

To use less information that’s connected to individual users, in some cases we de-identify or aggregate information or anonymize it so that it no longer identifies you. We use this information in the same ways we use your information as described in this section.

How we use information to improve our Products

We’re always trying to make our Products better and create new ones with the features you want. Information we collect from you helps us learn how.

We use information we collect to:

• See if a product is working correctly
• Troubleshoot and fix it when it’s not

How we use location-related information

We use location-related information that you allow us to receive if you turn on the Location Services device setting. This includes your GPS location.

• Your and others' activity on our Products, like check-ins.
• Information you give us directly, like if you enter your "homebase" on your profile.

We use location-related information to

• Provide, personalize and improve our Products.
• Detect suspicious activity and help keep your account secure. 

How can you manage or delete your information and exercise your rights?

We offer you a variety of tools to view, manage, and delete your information below. 

You can manage your information by visiting the settings of the Products you use. You may also have other privacy rights under applicable laws.

To exercise your rights, visit your account page in the Product you use, where you can edit or delete all of your information, and/or visit your device-based settings to change settings related to push notifications, and location permissions.

Delete your information or account

To delete your information, you can:

Find and delete specific information. We offer tools you can use to delete certain information. For example, you can use Delete buttons to delete trips you've created or photos you've uploaded. When you delete content, it’s no longer visible to other users.

Permanently delete your account. If you delete your account, we delete your information, including the things you’ve posted, such as your photos and trips, unless we need to keep it to comply with applicable laws. Once your account is deleted, you won’t be able to retrieve information, including content you’ve posted.

How long does it take to delete your information?

If you request that we delete your account or content, by emailing us at connect@270media.com, it may take up to 90 days to delete your information after we begin the account deletion process or receive a content deletion request. After the information is deleted, it may take us up to another 90 days to remove it from backups and disaster recovery.

Or you can start the deletion process right away by choosing "Delete account" from the Edit Profile screen in our Products.

We keep information as long as we need it to provide our Products, comply with legal obligations or protect our or other’s interests. We decide how long we need information on a case-by-case basis. Here’s what we consider when we decide:

• If we need it to operate or provide our Products. For example, we need to keep some of your information to maintain your account.
• How long we need to retain the information to comply with certain legal obligations. .
• If we need it for other legitimate purposes, such as to prevent harm; investigate possible violations of our terms or policies; promote safety, security and integrity; or protect ourselves, including our rights, property or products.

Security

270 Media has made reasonable technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, or disclosure. However, 270 Media cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your personal information for improper purposes. Also please note that email and messaging systems are not considered secure, so 270 Media discourages you from sending 270 Media personal information through these media.

For California Consumers California “Shine The Light”

If you are a California resident, California Civil Code Section 1798.83 (“Shine-The-Light” law) permits you to request information regarding the disclosure of your personal information by us, or our subsidiaries or affiliates, to a third party for the third party’s direct marketing purposes. To make such a request, please contact us as provided below. Except as may be provided in this Privacy Policy, we do not trade, sell, lease or otherwise provide any personal information regarding our users to any third parties for their direct marketing purposes.

‍California Consumer Privacy Act (“CCPA”)

The California Consumer Privacy Act (CCPA) gives California consumers enhanced rights with respect to their personal information that is collected by businesses.

First, California consumers may opt out of having their personal information sold to other persons or parties.

Second, they can request to know:

What specific pieces of information a business has collected about the consumer;

Categories of personal information it has collected about the consumer;

Categories of sources from which the personal information is collected;

Categories of personal information that the business sold or disclosed for a business purpose about the consumer;

Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and

The business or commercial purpose for collecting or selling personal information.

Third, California consumers can request that a business delete personal information about the consumer that a business has collected from the consumer.

270 Media may be considered a covered business under the CCPA as it collects and processes the personal information of California consumers. This Privacy Policy provides the required notices to California consumers. The CCPA also prohibits covered businesses from providing discriminatory treatment to California consumers if they exercise their rights under the Act.

For EU and EEA Residents

For our users residing within the EU or EEA, please review the following:

Data controller.

With respect to the data we collect about you through your use of our Services, we are the data controller.

Lawful bases.

When collecting, using, sharing, or otherwise processing data about you, we do so on the basis of your explicit consent, our need to fulfill this or a related agreement we have with you, including our Terms of Use, our or a third-party partner’s legitimate business interests, or to comply with our legal obligations, as applicable.

Cross-border transfers. 

As a California-based company, we store and use data outside the EU. To ensure adequate protection of personal data in cross-border transfer and/or processing, we use appropriate safeguards as allowed under applicable law or regulation.

Remedies. 

If you feel you haven’t received a timely or satisfactory response from us in connection to a question or complaint related to this Policy, you can raise the issue with your local supervisory authority without prejudice to any other rights you may have.

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