Privacy Policy

Effective Date: 5 July 2020

Northern Ohio Youth Orchestra, Inc. (“NOYO,” “we,” “us,” or “our”) prioritizes the protection of the privacy of individuals and children who use our http://www.noyo.org/ website and affiliated pages from which this Privacy Policy is posted (the “Website”), including, but not limited to, our social collaboration portal (the “Greenroom”). The Website and Greenroom may each be referred to herein as a “Site” or collectively as the “Sites.” The Sites are controlled and operated by NOYO in the United States.

This Privacy Policy (“Policy”) is adopted in compliance with the U.S. Children’s Online Privacy Protection Act (“COPPA”) and outlines our information collection, disclosure, and parental consent practices with respect to personal information regarding and/or provided by children under the age of thirteen (“Child” or “Children”), as well as our general policies applicable to the collection and processing of personal information of all other visitors over the age of thirteen, collected via the Sites within the United States. Personal information is information or data that can either directly or indirectly identify an individual. None of our sites are intended for users outside the Continental U.S. or its territories.

Please read this Policy carefully before using our Sites. By using a Site in any manner (whether in an automated fashion, including, without limitation, through a software tool, spider, bot, agent or otherwise), your actions constitute an act of acceptance of, and agreement to be bound by, this Policy.

If you have questions or concerns about our privacy practices, please contact us at (440) 775-3059 or noyo@noyo.org.

PART I: INFORMATION REGARDING CHILDREN

How We Collect and Use Information Regarding Children

In any instance that we collect personal information from or regarding a Child, we will retain that information only so long as reasonably necessary to fulfill the activity requested or allow the Child to continue to participate in the requested activity, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a Child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection. NOYO’s processing of Children’s information is limited to: (1) information disclosed by parents or guardians for registration purposes via our Website; (2) Content (as defined below) shared by Children participating in the Greenroom; and (3) persistent identifiers generated for functionality purposes which may contain personally identifiable information.

(1) Through our Website

Children under thirteen years of age are not permitted to explore or browse our Website. Our email newsletters are for adults only – they are not designed for, or targeted at, Children. Children are not permitted, and should not attempt to sign up for our email newsletters. We encourage parents to discuss with their Children the importance of not signing up to receive our email newsletters.

However, participation in our Greenroom as well as our Youth Orchestra Auditions requires an initial registration by a parent or guarding via an online form accessible on our Website. Registration requires the Child’s parent or guardian to voluntarily disclose certain personal information regarding their child, including their first and last name, school and grade, and an email address. As a parent or guardian of a Child, submitting your Child’s information for registration in a NOYO musical program or audition, you expressly indicate to NOYO that you understand the nature of the registration and consent to NOYO’s collection of your Child’s information in that manner.

(2) Through the Greenroom

Children approved for the Greenroom are permitted to participate after the creation of a unique username and password. Access to the Greenroom allows children to view and share their content, text, images, photographs, videos, messages, comments, links or any other kind of content permitted by the Greenroom Terms of Service (collectively, “Content”), some of which may contain personal information disclosed by your Child. As a parent or guardian of a Child, submitting your Child’s registration for the Greenroom expressly indicates to NOYO that you understand the nature of the Greenroom, and consent to your Child’s participation therein. All members of the Greenroom, including Children, have the ability to remove or delete Content previously shared from within their account. NOYO also reserves the right to remove any Content at any time at its sole discretion.

Please note, NOYO strictly limits adult and non-participant access to the Greenroom and as such, cannot commit to monitoring or moderating your Child’s activity or Content in the Greenroom 100% of the time. NOYO does, however, allow a limited number of authorized adults (typically one or two educators or volunteers) to serve as “Community Managers,” whose function is to monitor and flag inappropriate content or conduct found in the Greenroom for internal review by NOYO executives and/or removal. NOYO cannot guarantee that Content containing sensitive personal information published by your Child will be removed before another Greenroom participant is able to view such Content. Therefore, NOYO requires You, as parents and guardians to supervise your Child’s use of the internet and all NOYO Sites. We urge parents to instruct their Children to never give out the real names, addresses, phone numbers, or other personal information without a parent or guardian’s permission when using the internet. As a parent or guardian of a Child participating in the Greenroom, you may revoke your consent to our processing of your Child’s information at any time. Please refer to the section below on Parental Consent & Revocation for more information.

(3) Persistent Identifiers

When a Child interacts with the Greenroom, certain persistent identifiers may be automatically collected, which are necessary for the Greenroom to function. Examples of information collected include: the device’s IP address, or mobile device identifier (UDID), the Open Device Identification Number (ODIN), date/time stamps for each visit, the web browser type, operating system, internet service provider, referring/exit pages, clickstream data, and domain name, and the frequency with which the user visits various parts of the Greenroom. NOYO will not utilize any third-party cookies or any persistent identifiers for any purpose other than to allow the Greenroom to function.

NOYO’s Use of Children’s Information; Retention & Deletion.

All information collected regarding Children is processed solely for the purposes of facilitating NOYO’s educational programming and administering and improving the Greenroom. Such uses may include, but are not limited to: ensuring that the Greenroom function properly; enabling us to conduct research and analysis to understand, address and improve the use and performance of the Greenroom; and to diagnose and respond to problems. The Greenroom also offers participants the option to receive push notifications or alerts, which utilizes the email address associate with the account. All participants have the option to turn this feature off at any time from within their account. NOYO uses, retains Children’s information only as long as necessary to fulfill its initial purpose. After the intended use of Children’s information is fulfilled, it is deleted. See Parental Consent and Revocation below for more information deletion.

Information Sharing Practices

NOYO does not share your Child’s personal information with anyone who is not necessary for the provision of the program for which the information was offered. We do not sell your Children’s information to third parties, nor do we use their information to target them in any way for marketing or advertisement purposes. We also do not display any advertisements whatsoever within the Greenroom, though our teachers and educators may share or discussion upcoming NOYO’s music program opportunities.

NOYO will only disclose personal information to the extent permitted or required by applicable law, in the following circumstances: (i) in response to a subpoena, court order, or other legal process, (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of another individual using our Sites, consistent with applicable law; (iii) to protect the security or integrity of our Sites, applications, and other technology, as well as the technology of our service providers; (iv) enable us to take precautions against liability implicating such information, or (v) when disclosure is directed or consent to by the parent or guardian who has inputted the personal information.

Third Party Processing and Storage

NOYO makes use of certain third-party technologies and services that allow us to provide our Sites. This means that your use of the Sites may also be subject to additional privacy policies administered by said third parties.

For example, NOYO makes use of Google’s Suite of office administration tools to process registration and participation of Children in our programs and the Greenroom. The Greenroom itself is hosted by the social networking portal provider, Tribe.io. These service providers are prohibited from selling or processing information in ways that are inconsistent with their policies, which are accessible online for your review. NOYO cannot be held liable for breaches of privacy committed by third party providers.

Parental Consent & Revocation

Verifiable parental consent is obtained directly from each parent or guardian prior to their submission of any given NOYO registration form. Children’s information is never shared publicly, and all Content shared in the Greenroom is limited to viewers who have been approved for access as set forth herein. Aside from the information gathered automatically from technical services, and the Content shared by Children in the Greenroom, all personal information regarding Children is collected by way of voluntary disclosure by the parents or guardian directing the registration of their Child in a NOYO musical programs or in the Greenroom.

At any time, a parent or guardian can refuse to permit NOYO’s further processing of their Child’s personal information and submit a request that we delete said personal information from our records. Please keep in mind that a request to delete records may lead to a termination of an account, participation, or access to another service which may require such processing.

Parents can contact NOYO to request access to, change, or delete their child’s personal information by sending an email to us at noyo@noyo.org. NOYO will promptly act to ensure all valid requests to delete a Child’s personal information will be accommodated within a reasonable time.

You are also welcome to contact us by the following additional means:

Northern Ohio Youth Orchestra

Attn: Privacy Concerns

39 S. Main St., Ste 244

(440) 775-3059

noyo@noyo.org

Please note, we may require additional information in order to process such requests. In any correspondence such as e-mail or mail, please include the Child’s username and the parent’s email address and telephone number. To protect Children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any personal information.

Parents are prompted to acknowledge this disclosure and their consent prior to finalizing their Child’s registration. If a Parent voluntarily elects to register their Child for participation in the Greenroom, they are acknowledging the risks inherent in allowing their Child to use the social collaboration platform to share Content at their own risk.

Participation in the Greenroom does not require children to provide any additional personal information and therefore may not result in additional notice to the parent or require parental consent. If an activity potentially allows a Child to insert personal information in their created content, we will either pre-screen the submission to delete any personal information, or we will seek verifiable parental consent by email for the collection.

PART II: INFORMATION REGARDING INDIVIDUALS OVER THE AGE OF 13.

The following terms of this Part II of our Policy expands on the provisions set forth above to cover information collected from individuals over the age of 13 on our Sites. If you are under the age of 18 years of age (or the relevant age of majority in your state), a parent or guardian must review and agree to this Policy on your behalf in order for you to access and use our Sites. The following terms of this Part II apply to all other non-Children visitors, users and others who wish to access or use the Sites, including each parent or guardian entering into this Policy on behalf of a minor under the age of 18 who will be a user of the Sites.

Personal Information

While using our Website, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personal information may include but is not limited to: email address, first and last name, phone number, address, payment or billing information, cookies and usage data.

We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. 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 or by contacting us directly.

Usage Data

We may also automatically collect information that your browser sends whenever you visit our Website or when you access the Website by or through a mobile device ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Website with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Location Data

We may use and store information about your location if you give us permission to do so ("Location Data"). We use this data to provide features of our Website, to improve and customize our Website. You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Website and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Website. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Website.

Examples of Cookies we use:

Session Cookies. We use Session Cookies to operate our Website.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.

Use of Data

NOYO uses the collected data for various purposes:

To provide and maintain our Website;
To process program registration;
To process donations and other payments through our store at your direction;
To notify you about changes to our Website;
To allow you to participate in interactive features of our Website when you choose to do so;
To provide customer support;
To gather analysis or valuable information so that we can improve our Website;
To monitor the usage of our Website;
To detect, prevent and address technical issues;
To comply with the law; and
To provide you with news, special offers and general information about other goods, services 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.

Retention of Data

NOYO will retain your personal information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your personal information to the extent necessary to 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.

NOYO 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 Website, or we are legally obligated to retain this data for longer periods.

Transfer of Data; Third Parties

NOYO utilizes several useful third-party technology services to enable certain features on our Website. Therefore, your personal information may be transferred to - and maintained on – third party service provider systems. Your use of these features, and third-party use of your personal information is subject to that particular entity’s privacy policy, which you are encouraged to access and review via their websites. NOYO is not responsible for breaches of privacy committed by third party service providers.

NOYO uses the following services for the following purposes:

Little Green Light: to process donation payments submitted through the Website.
MySQL: to manage data pertaining to our patrons.
Google Suite: to manage program registration and for general administrative tasks.

Our Sites are specifically geared towards individuals located within the United States in the State of Ohio. If you are located in California, you acknowledge and agree that NOYO is a local website and we do cannot guarantee compliance with the California Consumer Privacy Act (“CCPA”). If you are located outside United States and please note that you are not permitted to utilize our Sites at this time, and we cannot guarantee that our internal privacy measures are compliant with international privacy law and regulations.

NOYO will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place without adequate internal security controls in place.

Disclosure of Data

As noted above in Part I, NOYO will only disclose personal information to the extent permitted or required by applicable law, in the following circumstances: (i) in response to a subpoena, court order, or other legal process, (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of another individual using our Sites, consistent with applicable law; (iii) to protect the security or integrity of our Sites, applications, and other technology, as well as the technology of our service providers; (iv) enable us to take precautions against liability implicating such information, or (v) when disclosure is directed or consent to by individual who has inputted the personal information.

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 information, we cannot guarantee its absolute security.

If you have any questions or concerns, please contact us directly at the address in Part I above.