Effective date: December 18, 2018
San Diego Youth Symphony and Conservatory (“us”, “we”, or “our”) operates the https://sdys.org website (the “Service”).
This page informs you of our policies regarding the collection, use, and disclosure of Personal Data when you use our Service and the choices you have associated with that data.
· Personal Data. Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
· Usage Data. Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
· Cookies. Cookies are small pieces of data stored on your device (computer or mobile device).
· Data Processors (or Service Providers). Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the Service of various Service Providers in order to process your data more effectively.
· Data Subject (or User). Data Subject is any living individual who is using our Service and is the subject of Personal Data.
How we collect your personal information:
We collect information in different ways from individuals who access the various parts of our Service. We collect information from you, and about you from third parties, in the following ways:
· Your submission of Personal Data when you use our Service, when you create an account to use our Student Management System or when you communicate with us by telephone, email or via the Service;
· Through third-party tools used to collect user behavior, such as through cookies. A “cookie” is a small data file that can be placed on your hard drive when you visit certain Internet sites;
· Information submitted by or obtainable from your internet service provider, software, computer, mobile device, or other method of accessing the Service (which you may be able to control through the settings of your software and devices) which we collect in our server logs.
What types of personal information we collect:
We collect several different types of information through use of our Service:
· While generally using our Service, we may ask you to provide us with certain Personal Data, including, but is not limited to: email address, first name and last name;
· When you create an account on our Student Management System, we may ask you to provide us with your Personal Data, including, but is not limited to: email address, first name and last name, phone number and address contact information, household demographic information;
· When you register your child for one of our programs through the Student Management System, we may ask you to provide us with additional Personal Data, including, but not limited to: your child’s first name and last name, phone number and musical background information;
· When you donate on our Site, contribute to our Annual Scholarship Fund, to one of our endowment funds or join our Angels’ Angels membership group, we may ask you to provide us with additional Personal Data but will not collect any financial information – all of your payment information will be processed by our Service Provider;
· Device and connection information, including without limitation details regarding your IP address, browser, operating system, screen display.
How we process and use your personal information:
We may process and use your personal information primarily to perform a contract with you, and to otherwise deliver the Service that you request, including:
· To provide and maintain our Service;
· For payment processing purposes through our Service Provider;
· To allow you to participate in interactive features of our Service when you choose to do so;
· To provide musical learning opportunities and experiences to the children you register;
We may also process your Personal Data because it is necessary for our or a third party’s legitimate interests and it’s not overridden by your rights. In this respect, we may use your Personal Data to:
· To provide customer support;
· To notify you about changes to our Service;
· To gather analysis or valuable information so that we can improve our Service;
· To monitor the usage of our Service;
· To detect, prevent and address technical issues;
· To provide you with news, special offers and general information about other goods, Service and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
We may also process your personal information for our compliance with our legal obligations. In this respect, we may use your personal information for the following:
· To satisfy laws or governmental or legal requests for such information or otherwise meet our compliance and regulatory obligations, both in the US and the EU, including with respect to any EU Member State where we are providing our Service;
· To prevent or investigate possible wrongdoing in connection with the Service;
· To protect the personal safety of users of the Service or the public;
· To protect against legal liability;
· For fraud prevention via third-party Service.
In addition, we may also process your Personal Data:
· When we have your specific or, where necessary, explicit consent to do so.
With whom will we share your Personal Data:
We generally do not share your Personal Data with third parties. However, we may share your Personal
· If we have received your permission beforehand;
· With our employees, if necessary for the development, improvement, and provision of our Service;
· With Service Providers, as processors when they meet the requirements of this Privacy
Policy, and when necessary for the purposes of providing the Service;
· Under certain circumstances, if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency);
· If in good faith, we believe that such action is necessary to comply with a legal obligation or to protect and defend the rights or property of San Diego Youth Symphony and Conservatory.
When do we transfer your Personal Data outside of the EU:
If your Personal Data is subject to GDPR, in the course of providing the Service to you, we may transfer your Personal Data outside of the EU, principally to our servers in the United States; this means that your Personal Data will not have the automatic protection of European data protection laws (including the GDPR) which apply in the EU. In these circumstances, in order to ensure that your Personal Data continues to have adequate protection when it is transferred outside the EU, your Personal Data will only be transferred on one of the following bases:
1. Where the transfer is subject to one or more of the appropriate safeguards for international transfers prescribed by applicable law (for example, standard data protection clauses adopted by the European Commission);
2. a European Commission decision provides that the country or territory to which the transfer is made ensures an adequate level of protection; or
3. there exists another situation where the transfer is permitted under applicable law (for example, where we have your explicit consent).
You can obtain more details of the protection given to your Personal Data when it is transferred outside the EU by contacting us using the details set out below.
Our liability for transfers of your Personal Data:
We require third-party controllers to whom we disclose your Personal Data to contractually agree to
(iii) notify us if the third-party controller makes a determination that it can no longer meet the foregoing obligations.
Retention of Data:
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Security of Data:
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
“Do Not Track” Signals Under California Online Privacy Protection Act (CalOPPA):
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
California residents — Your California privacy rights:
California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the business’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We require you to expressly opt-in to any disclosure of your Personal Data to third parties for the third parties’ direct marketing purposes which is stricter than required under California law.
Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the EU, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at https://sdys.or/contact-us.
In certain circumstances, you have the following data protection rights. Please note that these rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
· The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
· The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
· The right to object. You have the right to object to our processing of your Personal Data.
· The right of restriction. You have the right to request that we restrict the processing of your personal information.
· The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
· The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EU.
We may employ third party processors to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related Service or to assist us in analyzing how our Service is used.
We may use third-party Service Providers to monitor and analyze the use of our Service.
· Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google Service. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
· Google AdWords
Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
We may provide paid products and/or Service within the Service. In that case, we use third-party Service for payment processing (e.g. payment processors).
The payment processors we work with are:
Links to Other Sites
Children’s Privacy and international considerations:
Our Service does not address anyone under the age of 18 (“Children”).
We are headquartered in the United States and any information that you submit or we otherwise obtain will be transferred to, collected, and held in the United States. We may subsequently transfer such information to any other country or jurisdiction in connection with the authorized uses and disclosures of information set forth herein. Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.
- By email:email@example.com;
- By visiting this page on our website: https://sdys.org/contact-us/;
- By phone number: (619) 233-3232; or
- By mail: 1650 El Prado #207A, San Diego, CA 92101, United States.
- We will attend to your questions, concerns or instructions promptly.