The Longy School of Music of Bard College (“Longy” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.
This policy applies to information we collect:
- On our Website[s].
- In email, text, and other electronic messages between you and our Website[s].
- In Constant Contact and other email services.
It does not apply to information collected by:
- us offline or through any other means, including on any other website operated by Longy School of Music or any third party; or
- any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website[s]
- Google Analytics
Longy uses Google Analytics 4, a web analytics service provided by Google, Inc. to gather statistics on website usage, such as how often each page has been visited.
Longy uses Google Analytics 4, a web analytics service provided by Google, Inc. to gather statistics on website usage, such as how often each page has been visited. Many websites use these statistics to monitor and improve their services. Information collected and processed by Google Analytics includes the user’s IP address, network location, and geographic location. Google Analytics acquires this information by installing a cookie on your computer. NEC does not share any information it collects with Google, and Google Analytics does not collect any personal information such as names, contact information, social security numbers or financial information. If you choose, you can opt out by turning off cookies in the preferences settings in your web browser. For more information on Google Analytics, please visit Google’s “How Google uses data when you use our partners’ sites or apps” site, located at: www.google.com/policies/privacy/partners/
- Data Controller, Data Protection Officer, and Representative
Longy is the data controller of the Personal Data you provide on the Website[s]. Longy will not appoint a Data Protection Officer.
Longy School of Music is the data controller of your Personal Data. At this time, Longy School of Music is not required to appoint a Data Protection Officer or a representative in the EU, and has elected not to do so.
- Children Under the Age of 13
Our Website[s] are not intended for children under the age of 13 and children under the age of 13 are not permitted to use our Website[s]. We will remove any information about a child under the age of 13 if we become aware of it.
Our Websites are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Websites. We do not knowingly collect Personal Data from children under 13. If you are under 13, do not use or provide any information on our Websites or on or through any of its features/register on the 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 Data from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected].
- Information We Collect About You and How We Collect It
We collect information different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.
We collect several types of information from and about users of our Websites, specifically information:
- by which you may be personally identified, such as name, postal address, e-mail address, telephone number, social security number, or any other identifier by which you may be contacted online or offline] (“Personal Data”);
- that is about you but individually does not identify you, such as the links on our Website[s] you visit; and/or
- about your internet connection, the equipment you use to access our Website[s] and usage details.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
Information You Provide to Us
The information we collect on or through our Websites are:
- information that you provide by filling in forms on our Websites. We may also ask you for information when you report a problem with our Websites;
- records and copies of your correspondence (including email addresses), if you contact us;
- your search queries on the Website; and
- Any subscriptions to email updates.
The Personal Data we collect from you is required to provide you with our products and services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, then in some cases we may not be able to fulfill our obligations to you.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website[s] or transmitted to other users of the Website[s] or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although [we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile], please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website[s] 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 Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:
- details of your visits to our Website, specifically traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, specifically your IP address, operating system, and browser type.
The information we collect automatically is statistical data and does not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website[s] and to deliver a better and more personalized service by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize our Website[s] according to your individual interests;
- speed up your searches; and
- recognize you when you return to our Website.
- Lawful Basis for Processing Your Personal Data
We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, and required by law, and with your consent.
If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):
- Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Data if your rights and freedoms outweigh our legitimate interests. Specifically, our legitimate interests are to: facilitate communication between Longy School of Music and you; detect and correct bugs and to improve our Websites; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote and market our business; and develop our product and services;
- As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspection, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.
- Special Categories of Information
We generally do not request visitors to our Website[s] provide any speci al categories of Personal Data. We may process some Personal Data considered sensitive when necessary to carry out our obligations under the law or to protect our legitimate interests.
Some Personal Data processed by Longy School of Music may be considered sensitive, including personal data that reveals your racial or ethnic origin, political opinions, religious, philosophical beliefs, or the processing of data concerning your health or data concerning your sex life or sexual orientation or history of criminal convictions. Longy School of Music processes this information only to the extent necessary to carry out its obligations under the law or to the extent necessary to protect Longy School of Music’s legitimate interests.
- Automated Decisions Making
We generally do not use your Personal Data with any automated decision making processes.
Longy School of Music does not use your Personal Data with any automated decision making process.
- How We Use Your Information
We use your Personal Data for various purposes described below, including to:
- provide our Website[s] to you;
- provide you with information you request from us;
- enforce our rights arising from contracts;
- notify you about changes; and
- provide you with notices about your account
We use information that we collect about you or that you provide to us, including any Personal Data:
- To present our Website[s] and their 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 notify you about changes to our Websites.
- To allow you to participate in interactive features on our Website.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
With your opt-in to our email subscription, we may also use your information to contact you about our own [and third-parties’] goods and services that may be of interest to you. If you wish to consent to this use, please check the relevant box located on the form on which we collect your data. If you wish to change your choice, you may do so at any time by logging into the Website[s] and adjusting our user preferences in your account profile by checking or unchecking the relevant boxes, responding to instructions in an email you have received from us or by sending us an email stating your request at [email protected]. For more information, see Choices About How We Use and Disclose Your Information.
- Disclosure of Your Information
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Pr ivacy Policy. We disclose your Personal Data to a few third parties, including:
- our third party service providers that we use to support our business;
- to comply with our legal obligations;
- to enforce our rights; and
- with your consent.
- To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. Specifically, these entities provide IT and infrastructure support services.
- To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your Personal Data:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Longy, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- Choices About How We Use and Disclose Your Information
We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for third parties to advertise to you, our advertising to you, and other targeted advertising.
We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.
You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info). 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 also opt out of receiving targeted ads from members of the NAI on its website.
In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:
- Disclosure of Your Information for Third-Party Advertising. We will only share your Personal Data with unaffiliated or non-agent third parties for promotional purposes with your express consent. If you wish to consent to such use, you can check the relevant box located on the form on which we collect your Personal Data or otherwise seek such consent. If you wish to change your choice, you may do so at any time by sending us an email stating your request to [email protected].
- Targeted Advertising. We will only use information that we collect or you provide to deliver advertisements according to our advertisers’ target-audience preferences with your express consent. If you wish to consent to such use, you can check the relevant box located on the form on which we collect your Personal Data or otherwise seek such consent. If you wish to change your choice, you may do so at any time by logging into the Websites and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to [email protected].
- Your Rights Regarding Your Information and Accessing and Correcting Your Information
You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.
Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.
- Access and Update. You may review your Personal Data and notify us through the contact information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. Please note that if you request access to your Personal Data, you may be charged a fee subject to a maximum set by applicable law. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
- Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing, but we have retained it as permitted by law.
- Portability. To the extent the Personal Data you provide Longy School of Music is processed based on your consent or that we process it through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
- Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
- Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
- Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
- How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements.
- Your California Privacy Rights
Under some circumstances, California law may provide you with the right to obtain a list of third parties (if any) that we provide your Perso nal Data to for their own direct marketing purposes. If you use our Website[s] when you are under the age of 18, you may request that we remove your User Contributions under certain circumstances. We also do not advertise or market any goods and services that are identified as being inappropriate for children under the age of 18.
California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Websites that are California residents and who provide Personal Data in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Data to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Data and the names and addresses of those businesses with which we shared your Personal Data with for the immediately prior calendar year (e.g. requests made in 2018 will receive information regarding such activities in 2017). You may request this information once per calendar year. To make such a request, please send an email to [email protected].
California law permits minors under the age of 18 to request the removal of your User Contributions, subject to certain exceptions. If you are under the age of 18 in California, you may contact us using the contact information below (if you contact us via email, please use the subject “California Eraser Law Request”). We may not remove your User Contributions that we are required to retain under any federal or state law, or that have been provided to a third party. While we will do our best to remove a minor’s information upon a valid request, we cannot ensure the complete or comprehensive removal of your User Contributions from our Websites or any information that has been republished, copied, downloaded, or reposted by any third party, and we cannot guarantee that any such information may not be accessible to users of the Internet in the future.
- Data Security
Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Websites confidential.
We have implemented measures designed to secure your Personal Data 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 Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
- Consent to Processing of Personal Data
We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data.
If you are a resident of the European Economic Area (“EEA”), in order to provide our Websites, products, and services to you, we may send and store your Personal Data outside of the EEA, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an adequate level of protection for your Personal Data.
By using our Website, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data that you provide directly to us on our Website.
- Data Retention Periods
We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you close your account, for example we may keep it:
- on our backup and disaster recovery systems;
- for as long as necessary to protect our legal interests; and
- and to comply with other legal requirements.
Longy School of Music will retain your personal data for the entire time that you keep your account open. After you close your account, we may retain your Personal Data:
- for as long as necessary to comply with any legal requirement;
- on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
- for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
- for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.
You may contact our Data Protection Officer through the contact information below.
To Contact Longy School of Music:
Longy School of Music
27 Garden Street
Cambridge, MA 01238