2. Our Principles
HowlRound has designed this policy to be consistent with the following principles:
- Privacy policies should be human readable and easy to find.
- Data collection, storage, and processing should be simplified as much as possible to enhance security, ensure consistency, and make the practices easy for users to understand.
- Data practices should always meet the reasonable expectations of users.
3. Personal Information We Collect
As used in this policy, “personal information” means any information that can be used to identify you. This information includes, but is not limited to, your name, address, phone number, driver’s license or other state issued ID, birthdate, and email address. Personal information also includes any information we collect about you that is then linked to you or your device.
We collect and use personal information in the following ways:
Information You Provide Directly to Us
We may ask for certain information when you access certain elements of the HowlRound Platform. For instance, parts of the HowlRound Platform allow you to sign up for emails or newsletters or to participate in surveys or other activities that involve providing personal information about yourself. In these circumstances we will have the information you provide such as your name, email, address, and other information. If you contact us on a social media site or “like” us on Facebook, we will have information about you as permitted by that social media platform.
Some of parts of the HowlRound Platform allow you to buy merchandise, order tickets, or to make a donation to HowlRound. If you decide to use any of these services we will collect your payment card information.
Information You Provide To Us Via Our Vendors
In order to provide you with the HowlRound Platform, we sometimes engage third party vendors. For instance, if you make a donation or order merchandise, we may use one vendor to process your payment and ship your order. In this instance we will share the relevant information you have provided to us via the HowlRound Platform with our vendor so we can fulfill your order. We also engage with third party vendors to manage the information resources available on the HowlRound Platform.
Many of these vendors are contractually prohibited from using any personal information we provide them or that they may collect about you via the HowlRound Platform except as necessary to process your requested service. However, other third parties provide HowlRound access to enhanced services which are embedded in the HowlRound Platform such as an enhanced audio and/or video player. In these circumstances, by using the enhanced service you are providing your personal information and other information directly to this third party provider who may share some of this personal information with HowlRound.
Information We Collect Automatically
In addition to the information you provide directly, we may collect certain information automatically, regardless of whether you register or request any services, including the following:
- Your browser type and operating system;
- Your Internet Protocol (IP) address, which is the number automatically assigned to your computer or other device whenever you access the Internet and that can sometimes be used to derive your general geographic area;
- Websites you visited before and after visiting the HowlRound Platform;
- Web pages and advertisements you view and links you click on within the HowlRound Platform;
- Unique identifiers, including mobile device identification numbers, which can identify the physical location of such devices in accordance with applicable law;
- Information collected through cookies, web beacons, and other similar technologies;
- Interactions with audio and video content, such as the type of content listened to (and content viewed);
- Information about your interactions with email messages, such as the links clicked and whether messages were opened or forwarded;
- Upon request, your bandwidth speed and information about the software programs installed on your computer; and
- Standard server log information.
Information We Obtain From Other Sources
Where permitted by applicable law, we collect information about you from other sources, including through interactive applications such as Facebook, Instagram, Pinterest, or Twitter. If we use a third party service to enhance certain features of the HowlRound Platform those third parties may provide us information including personal information they have collected about you as a result of your using these enhanced services.
The following are examples of the type of information we may collect from other sources:
- Name, postal address, and telephone number;
- Demographic data, such as age, gender, and income level;
- If you access our content the HowlRound Platform such as Facebook, Twitter, Instagram, Soundcloud, or YouTube, your username and password for those services and other information available about you on those services such as your online purchasing behavior;
- Publicly-observed data, such as activities on blogs, videos, and other online postings; and
- Other navigation data, such as websites visited and advertisements viewed or clicked on.
4a. Use of Personal Information
We only use payment and identity verification information, such as credit card numbers, driver’s license numbers, Social Security numbers, or comparable national identifiers as necessary for completing a particular transaction or fulfilling a service (e.g., when you make a donation) or as otherwise required by law. Unless otherwise noted, this information is not stored on HowlRound’s servers or maintained in our databases.
Generally, we use other information collected about you to:
- Fulfill your requests for products, services, and information, and to authorize a purchase, send you electronic newsletters, and complete a transaction that you have requested;
- Provide you with special offers and promotional materials;
- Analyze the use of the HowlRound Platform and information about visitors to the HowlRound Platform to understand and improve our offerings and, in accordance with our sharing policies discussed below, to produce anonymous or aggregated data and statistics that might help third parties develop their own products and service offerings;
- Customize the content you see when you visit the HowlRound Platform;
- Develop and provide advertising tailored to your interests;
- Improve our fundraising efforts on behalf of HowlRound or any of the programs we offer or sponsor including programs or events we co-sponsor with other entities; and
- For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
Unless otherwise described above, we will use the information in this way to meet our legitimate interests. We have an interest in improving the functionality of the HowlRound Platform (through tailoring content, and analyzing statistics) to make sure you have the best experience using the HowlRound Platform, and an interest in communicating with you (through marketing, responses to customer service requests and content delivery) in a way that is most useful to you. We also have an interest in protecting our rights and upholding the law.
4b. Retention of Personal Information
We retain your personal information as long as we have a relationship with you. When deciding how long to retain your personal information after our relationship with you has ended we take into account our legal obligations. We may also retain your personal information as needed to investigate or defend against potential legal claims.
5. Your Rights
Depending on applicable law, you may be entitled to access, correct, delete, restrict the processing of, object to the processing of, or receive a portable copy of personal information that we hold, which specifically relates to you. You also may have a right to lodge a complaint with your local data protection or privacy regulator. Where you have provided your consent to any use of your personal information, you can withdraw this consent at any time. Please note that we may require additional information from you in order to honor your requests. If you would like to discuss or exercise any rights you may have under law, please contact us at the contact information set forth below.
If you want to exercise your rights with respect to the Social Media Platform or any third party that independently collects information through the HowlRound Platform you will need to contact those sites directly
6. Disclosure of Your Personal Information
HowlRound does not disclose personal information to third parties except as specified elsewhere in this policy and in the following instances:
- We share your contact information with third party vendors who help us with specialized services, including customer support, payment processing, business analytics, marketing, suppression list management, and data processing. Generally, these third parties use your personal information only to fulfill your request and do not share it with other third parties for those other third parties’ own purposes. Also, authorized third party service providers may collect non-contact information about your use of our services with cookies, web beacons and other similar technologies that may be used to deliver advertisements tailored to your interests.
- We may share your information in connection with a substantial corporate transaction, such as the sale of Emerson or HowlRound, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy. Our third party vendors may also reserve rights to share your data under these same circumstances.
- We also may share aggregated information with third parties to help us develop content and services we hope will interest you, or to help these third parties develop their own product and service offerings, including targeted marketing.
7. Security of Your Personal Information
We are committed to protecting your information. We have adopted commercially reasonable technical, administrative, and physical procedures to help protect your information from loss, misuse, unauthorized access and alteration. Please note that no data transmission or storage can be guaranteed to be 100% secure. We want you to feel confident using the HowlRound Platform, but we cannot ensure or warrant the security of any information you transmit to us.
You can navigate most of the Websites without providing personal information, but sometimes we need additional information about you so we can provide information or services you want to receive from use. When you visit the Websites, we use “cookies” and other device identifying technologies (text files) that will be saved onto your computer and that will allow an analysis of your use of the Websites. Cookies refer to all technologies that store and access information on the device that you use to access the Websites, such as your computer, tablet, or mobile phone.
A cookie is a small text file that can be placed on your computer’s hard drive with your permission. The cookie helps analyze web traffic and lets us know when you visit a particular site. Cookies allow web applications to respond to your individual preferences when online and tailor operations by gathering and remembering information about your preferences.
There are different types of cookies, for example:
- Cookies served directly by HowlRound (“first party cookies”) and cookies served on our behalf, for example, by data analytics companies (“third party cookies”);
- Cookies that endure for different periods of time, including those that only last as long as your browser is open (referred to as “session cookies”). These are deleted automatically once you close your browser. Other cookies are “persistent cookies,” meaning they survive after you browser is closed. For example, they recognize your device when you open your browser and browse the internet again.
Cookies help HowlRound provide a better user experience on our website, by monitoring which pages are most frequently visited. A cookie does not give HowlRound access to your computer.
The Websites use analytics to help improve both user experience and functionality. The Websites use external services including Google Analytics to attain real time statistics on use and navigation of the Websites, including page views, traffic patterns, visit counts, and visit statistics. These are not used to gather, request, record, require, collect, or track personal information.
Third Party Cookies
- Facebook’s data use policy: http://www.facebook.com/about/privacy/your-info-on-other
You have the right to reject the use of some or all of the cookies used on the Websites. Please refer to your browser’s help file for the steps required. Please note that modifying browser settings to reject some or all cookies may impact the user experience on the Websites. Modification may also impact the delivery of personalized content.
As a program operated by a not-for-profit college, HowlRound is not required to comply with the Children’s Online Privacy Protection Act. Nevertheless, HowlRound limits authorized users to those over the age of 13 (or the applicable age of majority in their jurisdiction). We do not knowingly collect information over visitors under the age of 13. If you are aware of any user under the age of 13 from whom we have collected personal identifying information, please contact us at firstname.lastname@example.org so that we may address this issue immediately.
10. User Generated Content
11. Third Party Sites
12. Transferring Data to Other Countries
Personal information collected through the HowlRound Platform is hosted in the United States. If you are accessing or using the HowlRound Platform in regions with laws governing data collection, processing, transfer and use, please note that when we use and share your data as specified in this policy, we may transfer your information to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information.
Personal Information collected through the HowlRound Platform that is transferred to a third party located outside the European Union will be made consistent with applicable data privacy requirements (e.g., on the grounds of a data transfer agreement based on the Standard Contractual Clauses approved of by the European Commission, or a certification to the E.U.-U.S. Privacy Shield regime). For more information on the appropriate safeguards in place and to obtain a copy of such safeguards, please contact us at the contact information set forth below.
14. Contact Information
HowlRound Theatre Commons
Office of the Arts, Emerson College
120 Boylston St
Boston, MA 02116
Effective Date: 1 October 2018