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.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://sdys.org

Definitions

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 Controller. Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

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;
Through our Service Providers, as described in this Privacy Policy;
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 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 is not limited to: your child’s email address, 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, 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;
Through the use of cookies, Usage Data, including without limitation button clicks, pages visits, the length of time using the Service or any portion thereof, your interactions with the Service and the frequency of your use of the Service or any portion thereof;
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 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;
Creating a customized experience as you use our Service through the use of cookies.

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:

To enforce any of our rights under our Terms and Conditions, this Privacy Policy, any Service specific terms and conditions, or any other rights we may have;
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 Data:

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 (i) only process such Personal Data for the limited and specified purposes consistent with the consent you provide; and (ii) provide the same level of protection to your Personal Data as required under this Privacy Policy; and (iii) notify us if the third-party controller makes a determination that it can no longer meet the foregoing obligations.

In addition, when we transfer your Personal Data to a third party processor acting as our agent, we will: (i) transfer such Personal Data only for the limited and specified purposes consistent with the request or consent you provide; (ii) contractually require the processor to provide at least the same level of privacy protection as is required by this Privacy Policy; (iii) require the processor to notify us if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the this Privacy Policy. Should we receive any such notice, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.

We shall remain liable should our processors process Personal Data in a manner inconsistent with this Privacy Policy, unless we can prove we are not responsible for the event giving rise to the damage. We acknowledge our liability for such data transfers to third parties in violation of this Privacy Policy.

Retention of Data:

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to perform a contract with you, comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

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 aims 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 follow submittal instructions here or 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.

Service Providers

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.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose and must comply with the requirements for third party processors set forth in this Privacy Policy.

Analytics

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.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Behavioral Remarketing

We uses remarketing Service to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

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

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

Payments

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).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

Authorize.net

Their Privacy Policy can be viewed at https://www.authorize.net/company/privacy/

Square

Their Privacy Policy can be viewed at https://squareup.com/legal/privacy-no-account

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or Service.

Children’s Privacy and international considerations:

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers. We will collect Personal Date relating to your Children which you enter when you register them for music learning opportunities. All such Personal Date shall be subject to this Privacy Policy.

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.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Changes to This Privacy Policy:

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

If you have any questions about this Privacy Policy, or any concerns regarding the collection, use and disclosure of your Personal Data, or to instruct us regarding your choices regarding your Personal Data, please contact us: 1) By email: website@sdys.org; 2) By visiting this page on our website: https://sdys.org/contact-us/; 3) By phone number: (619) 233-3232; or 4) By mail: 1650 El Prado #207A, San Diego, CA 92101, United States. We will attend to your questions, concerns or instructions promptly.