PRIVACY POLICY

Effective Date: Jun 21, 2024

When you use our Services, you’re trusting us to handle your personal information with care. We take that trust seriously. This Privacy Policy describes how Four Elephants Media, Inc. (“Four Elephants” or the “Company”) and its affiliates collect, use, disclose, and protect your personal information in connection with the Company’s owned and operated website, currently available at samharris.org (the “Site”), the Making Sense podcast (the “Podcast”), any other products, services, or events provided by Four Elephants, and all associated Four Elephants features, applications, widgets, and their respective contents branded as Four Elephants, or offered through the Site, including without limitation, any new features and applications (collectively, the “Services” or the “Four Elephants Services”). The Four Elephants Services do not include—and this Privacy Policy does not cover—the Waking Up app, website and related offerings, or anything else governed by the Waking Up Privacy Policy.

KEY PRIVACY POINTS

We hope you read this entire Privacy Policy for full detail, but here are some key points:

  • Our money comes from you, not ads. As a consumer-focused subscription business, our Podcast relies on your subscriptions.
  • Other platforms may sell your sensitive personal information for targeted advertising, but we don’t.
  • We have a wide catalogue of podcast episodes and content on current affairs, including content specific to areas like politics, religion, and innovations in alternative medicine. We only ever process data about your use of our content so that we can learn more about what you’re most interested in, serve you the best possible experience, and communicate with you.
  • We use a small number of trusted online software platforms, like Google Analytics, to help deliver and optimize our website and podcast.
  • We honor all valid requests to exercise privacy rights.

If you have any questions or concerns about this policy, email us at info@samharris.org.

TABLE OF CONTENTS

  1. Information We Collect
  2. Use of Information
  3. Disclosure of Information
  4. Your Rights and Choices
  5. Details for Californians
  6. International Data Transfer
  7. Data Retention
  8. Protection of Information
  9. Children Under 13
  10. Updates and Changes to This Policy
  11. Contacting Us

1. INFORMATION WE COLLECT

a. Information You Provide to Us:

You may provide the following types of information to us:

  • Identifiers, such as name and contact details;
  • Payment information, such as credit card number, for your purchase (which is stored and processed by our third-party payment processor);
  • Commercial information, such as:
    • a record of the content on our Site that you experience;
    • details about your purchases and other business interactions with us, responses to surveys, and participation in our events;
  • Information about your interests and preferences;
  • Audio or visual information, such as recordings of calls with us or events;
  • Rough geolocation (inferred from your IP address);
  • Internet or other electronic network activity information, as described in the Cookies and Other Technology section below; and
  • Inferences based on any of the above.

b. Cookies and Other Technology

Through our online properties, we and third parties may collect information from your computer or other device by automated means such as cookies, web beacons, local storage, JavaScript, mobile-device functionality and other computer code. This information may include unique browser identifiers, IP address, browser and operating system information, device identifiers (such as advertising identifiers), other device information, Internet connection information, as well as details about your interactions with the relevant website, email or other online property (for example, the URL of the third-party website from which you came, the pages on our website that you visit, and the links you click on in a website). In some cases (such as cookies), the tools described here involve storing unique identifiers or other information on your device for later use.

c. Information From Third Parties

We may also receive personal information from third parties, including our service providers, affiliates, and partners such as analytics and advertising partners, payment processors, other users of the Services, and publicly available sources, such as social media websites. We may also receive information about you from a third party such as Google when you use your account with them to create an account with us.

We may combine the information we collect about you from these various sources. If a combination of information that we collect identifies you as an individual, we will treat the combined information as Personal Information.

When you use a private RSS feed to listen to the Podcast through a third-party app, we don’t receive information about what you listen to or download. Some of these third parties, like Apple, may provide us with general statistics about our Podcast’s performance, but these don’t give us identifiable, individual-level information about our users.

2. USE OF INFORMATION

We and our service providers use the information described above for the following purposes:

  1. Manage and improve the Services generally;
  2. Process your registration and verify your information;
  3. Customize content, preferences, and advertising on our Site, across the Internet and elsewhere;
  4. Send you confirmations, updates, security alerts, and support and administrative messages;
  5. Conduct sales and marketing;
  6. Conduct business operations such as auditing, security, fraud prevention, invoicing and accounting, analytics, and research and development;
  7. Protect against, identify, investigate, and respond to misuse of the Services or other unlawful behavior;
  8. Address legal requirements;
  9. Establish, exercise, or defend our legal rights; and
  10. Create aggregated or de-identified information.

In some cases (B and some situations described by D, F, and G in the list above), our processing of personal information is necessary for us to comply with a contract with you (typically our Terms of Service) or to take steps in anticipation of entering into a contract with you. In other cases (some situations described under H in the list above), we process personal information because we are required to do so by laws in jurisdictions such as the United Kingdom and countries in the European Economic Area. In certain cases, we process personal information based on your consent, such as certain situations covered by A, C, E, and F in the list above, though those situations do not always require consent. When we process personal information on the basis of consent, it may be express consent or implied consent, depending on the situation and on which laws apply. In the remaining situations in A and C–J in the list above, we process personal information because we believe it is necessary for purposes of our legitimate interests (primarily growing and protecting our business) or the legitimate interests of others. And in some countries outside the UK and European Economic Area, we process personal information on additional or other grounds.

3. DISCLOSURE OF INFORMATION

We may disclose your information as follows:

  • To vendors and service providers: We disclose information to companies that provide services to us, such as providers that analyze data or provide customer service, data storage, marketing, analytics, security, or fraud prevention. We may engage a third party to host or operate any aspect of the Services, including any mechanism through which we send or receive communications, such as our email systems and our Site.
  • To affiliates: We may disclose information to current or future parents, subsidiaries, affiliates, and other companies under common control or ownership with Four Elephants.
  • In connection with legal matters: We may disclose information when we believe disclosure is appropriate due to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or government agency; or as otherwise required by law.
  • For the protection of Four Elephants and others: We may disclose information when we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our employees, our customers, or others; and to enforce our contracts.
  • In connection with corporate transactions: We may disclose your information as part of, or to take steps in anticipation of, a sale of all or a portion of our business, a divestiture, merger, consolidation, asset sale, bankruptcy, or other significant corporate event.
  • In other situations: We may also disclose your information in other situations where legally permitted.

We may use and disclose appropriately aggregated or de-identified information for any purpose.

4. YOUR RIGHTS AND CHOICES

a. Marketing Communications

You can unsubscribe from Four Elephants marketing emails by clicking the unsubscribe link in a marketing email or contacting us at info@samharris.org.

b. Cookies and Other Similar Technologies

You can make certain choices regarding the use of cookies and similar technologies. We recommend doing so by clicking the “Cookie Preferences” link in the footer of our website, adjusting your preferences, and clicking “Save Settings. If you replace, change, upgrade or reset your browser or device, or delete your cookies, or if you use a browser that automatically clears your cookies, you may need to use this opt-out tool again.

As mentioned above, you may be able to set your browser to refuse certain types of cookies, or to alert you when certain types of cookies are being used. Some browsers offer similar settings for HTML5 local storage and other technologies too. However, if you block or otherwise reject all cookies, local storage, JavaScript or other technologies, certain websites may not function as expected.

We do not respond to browser-based do-not-track signals.

c. Rights Regarding Your Information

Depending on your jurisdiction, you may have the right to make certain requests related to your personal information. For example, you may have the right to ask us to:

  • Provide you access to or a copy of certain personal information.
  • Correct or update personal information.
  • Delete certain personal information.
  • Restrict or opt you out of certain uses of your information (right to object).
  • Withdraw any consent that you previously provided (without affecting the lawfulness of processing based on consent before the withdrawal takes effect);
  • Provide you with certain details regarding the processing of your information.

Please note that certain information may be exempt from such requests under applicable law. For example, we need certain information in order to provide the website and podcast to you, so we can’t delete it while still providing you with the website and podcast.

We may take reasonable steps to verify your identity before responding to certain requests, which may require verifying your name and email address. If we are unable to verify your identity, we may be unable to respond to your requests.

If you wish to exercise any privacy rights, or raise a complaint about our handling of your personal information, please contact us as described at the end of this Privacy Policy. You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request as permitted by applicable law.

Depending on applicable law, you may have the right to appeal our decision to deny your request. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority.

Residents of California and some other jurisdictions have a right to opt out of what the laws in those jurisdictions call a “sale” of personal information, as well as to opt out of certain uses and disclosures of personal information for certain targeted advertising purposes. To exercise those rights, they can visit our Your Privacy Choices page and follow the instructions there.

5. DETAILS FOR CALIFORNIANS

This section applies only to California residents, and it deals only with information that is subject to the California Consumer Protection Act (CCPA). Data about individuals who live outside California may be handled differently.

During the 12 months leading up to the effective date of this Privacy Policy, we collected all of the types of personal information listed below (as further described in the “Information We Collect” section of this Privacy Policy) above. During that period, we made the following disclosures of that information for the purposes described in the “Disclosure of Information” section above:

Category of Personal InformationCategory of Entities to Which It Was Disclosed
Identifiers (e.g., name, mailing address, email address, phone number)Affiliates; vendors and service providers.
Financial information (e.g., credit card numbers, payment information)Vendors and service providers.
Details about user interaction with particular content in our ServicesAffiliates; vendors and service providers.
Audio or visual information (e.g., recordings of calls or meetings)Affiliates; vendors and service providers.
Commercial information (e.g., records of transactions)Affiliates; vendors and service providers.
Internet or other electronic network activity (e.g., device information, IP address, and information about your interaction with the website or app)Affiliates; vendors and service providers.
Geolocation data (inferred from IP address)Affiliates; vendors and service providers.
Inferences drawn from any of the information identified hereinAffiliates; vendors and service providers.

The CCPA defines the “sale” of personal information to include selling user data to random third parties for money, like a data broker does—something we have never done. But it also defines “sale” and “sharing” in a broader sense that includes some more common practices. For example, under the CCPA, these terms include the use of certain advertising services, like when we pay an ad tech company to place a cookie on the browser of a visitor to our website so that the user can see an ad for our Podcast on other websites. We’ve done that over the last year and plan to continue to do so. The ad tech company can see the website visitor’s IP address and other browser/device data as part of that process. The terms “sale” and “sharing” also cover the use of other advertising services, like if we were to pay a third-party website to serve ads for us to individuals that we specify by giving that website a list of those individuals’ email addresses (or hashes of those email address). We’re starting that activity in 2024 (and may have started by the time you read this), and it’s considered a “sale” and “sharing," even though we’re the ones who pay for it.

We do not “sell” or “share” personal information (as those terms are defined under the CCPA) if we have actual knowledge that the consumer is less than 16 years of age.

Californians can opt out of the CCPA “sales” and “sharing” by following the instructions on our Your Privacy Choices page, or they can start their request by emailing us at info@samharris.org and then completing the instructions we send in response. Your browser may also offer a way to activate the Global Privacy Control signal (“GPC”). SamHarris.org treats qualifying browsers for which the user has activated the GPC signal as having opted out of what CCPA calls a “sale” or “sharing” of any California personal information that is collected on that site from that browser using cookies and similar technology. You can override that treatment for a GPC-enabled browser by using the cookie controls available from the website’s footer to opt into particular categories of cookies from that browser. In that case, “sales” and “sharing” via cookies and similar technology in those categories may resume on that browser. Regardless of how you opt out of “sales” and “sharing,” most of the disclosures described in this Privacy Policy will continue, as they don’t qualify as “sales” or “sharing.”

The CCPA also entitles you to receive certain information from us about certain kinds of financial incentives that we may offer (when we offer them), and it prohibits various forms of discrimination against you for exercising your rights.

In certain circumstances, the CCPA allows consumers to request that businesses limit their use of certain sensitive personal information due to its sensitive nature. However, we do not engage in such uses of that information.

6. INTERNATIONAL DATA TRANSFER

We are headquartered in the United States, and recipients of the data disclosures described in this Privacy Policy are located in the United States and elsewhere in the world, including where privacy laws may not provide as much protection as the laws of your country where you live. For this reason, your personal information may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of any of the countries where we (or the recipients of disclosures mentioned in this Privacy Policy) operate, pursuant to the laws of such countries. However, this Privacy Policy applies to Four Elephants’ operations worldwide. To the extent that personal information is transferred from the European Economic Area (“EEA”) and the UK to any non-EEA members of our group or third-party processors who handle the information solely on our behalf, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy. These measures include signing Standard Contractual Clauses in accordance with EEA and UK data protection laws to govern the transfers of such data. For more information about these transfer mechanisms, please contact us as set out below.

7. DATA RETENTION

We keep your information until after we determine it is no longer necessary for the purposes described in this Privacy Policy and we are not legally required to retain it for longer.

8. PROTECTION OF INFORMATION

To help protect personal information, we have put in place physical, technical, and administrative safeguards. However, we cannot assure you that data that we collect under this Privacy Policy will never be used or disclosed in a manner that is inconsistent with this Privacy Policy.

9. CHILDREN UNDER 13

If you are a parent or legal guardian and think your child under 13 (or a higher age threshold where applicable) has given us personal information, please contact us at info@samharris.org so that we can delete it.

10. UPDATES AND CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time, such as to reflect changes in our practices or for legal reasons. We will post those changes here or on a similarly accessible page.

11. CONTACTING US

If you have any questions or comments regarding our privacy policy and practices, or to submit a request or complaint, please email our privacy team at info@samharris.org or use the contact details below:

Four Elephants Media, Inc.
16633 Ventura Blvd., Suite 815
Encino, CA 91436