Privacy Policy

Interlochen Center for the Arts Privacy Policy

Interlochen Center for the Arts (“Interlochen”) and its subsidiaries has adopted the following privacy practices (“Privacy Policy”) to inform you of its collection and use of your personal or personally identifiable information. Interlochen values your privacy and has adopted this Privacy Policy in an effort to remain transparent with respect to its collection and use of this information. Interlochen reserves the right to suspend, replace, modify, amend, or terminate this Privacy Policy at any time and within its sole and absolute discretion. By using the Interlochen’s website, applications, and/or online programs, you consent to the data practices described in this Privacy Policy. Your continued use of Interlochen’s website, applications, and/or online programs after a change in this Privacy Policy will constitute your manifestation of assent to and agreement with any replacement, modification, or amendment herein.

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Interlochen public message boards, this information may be collected and used by others. Interlochen encourages you to review the privacy statements of all websites you use, so that you can understand how those websites collect, use and share your information.

Interlochen does not provide to third parties personally identifying information if that dissemination is not authorized by you. We may share general, non-identifying information with our service providers if necessary for them to perform a business, professional, or technology support function for us. Interlochen may also disclose personal information if required by law, for example, in response to a court order or a subpoena.

Information Gathering on our Website

Interlochen may use your IP (Internet Protocol) address to help diagnose problems with our server, and to administer our website by identifying which parts of our site are most heavily used and which portion of our audience comes from within our network. We do not link IP addresses to anything personally identifiable. This means that user sessions may be tracked, but the users will remain anonymous. We occasionally monitor search terms that users enter into the Interlochen Search Engine, but this tracking is never associated with individual users.

Use of Information

Interlochen uses the information gathered above to tailor site content to user needs, and to generate aggregate statistical reports. We may provide aggregate information to third parties.

We may request your e-mail address or mailing address on some of the forms contained on the site (Admission, Box Office, etc.). Whenever we request the identity of a visitor, we will clearly indicate the purpose of the inquiry before the information is requested. If you choose to email us with your personal information, we will use this information to respond to your inquiry or request. There are times when your email will be forwarded within Interlochen to employees who are better able to assist you.

Children’s Privacy Policy

The Federal Trade Commission's Children's Online Privacy Protection Act ("COPPA") requires us to inform parents about how we collect, use, and disclose Personal Information from children under 13 years of age.

Children who are registered for online programs can create and view associated content and view other's content. During the registration process, we may ask the child to provide certain information for notification and security purposes, including a parent or guardian's email address, the child's account username, and password. Interlochen will not require a child to provide more information than is reasonably necessary in order to participate in the online activity.

Some online programming options allow children to create or manipulate content and save it with Interlochen through an associated learning management system. None of these activities require children to provide any personal information and therefore do not result in notice to the parent or require parental consent. We strongly advise children to never insert personal information in their created content.

Certain activities may allow users to communicate directly with other users by means of a discussion board or internal messaging system. These boards and messaging systems are limited to users who are registered for our programs and are monitored by Interlochen employees. We strongly encourage children who use any interactive features on our website or in our learning management system never to provide personal information about themselves or any third party. However, it is the responsibility of parents to carefully supervise their children when their children participate in online activities.

When children interact with us, certain information may automatically be collected for purposes of statistical analysis and system improvements. Examples include the type of computer operating system, the user's IP address or mobile device identifier, the web browser, the frequency with which the user visits various parts of our site, and information regarding the online or mobile service provider. This information may be collected by Interlochen or by a third party. In order to determine usage patterns, customize content, and/or conduct research and analysis to address the performance of our website, applications, or online programming.

Interlochen may disclose personal information if required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency's (including schools or children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) to enable us to take precautions against liability.

Parents and guardians may, at any time, prevent Interlochen from collecting further personal or personally identifiable information from their child. Parents and guardians may also request that Interlochen delete from its records the personal or personally identifiable information that it has collected from their child. To cease the further collection and use of personal or personally identifiable information, parents and guardians are directed to delete their child’s User Account. To delete any personal or personally identifiable information that Interlochen has collected, parents and guardians may contact Interlochen at privacy@interlochen.org to request the deletion of this information. For further information, see the section “Ceasing the Collection and Use of Personal or Personally Identifiable Information” below.

Student Privacy & FERPA

The Family Educational Rights and Privacy Act (FERPA) is a federal law regarding the privacy of student records and the obligations of the institution, primarily in the areas of release of the records and the access provided to these records.

In accordance with FERPA, Interlochen reserves the right to publish directory information about students who are enrolled or were previously enrolled in their programs. FERPA defines "directory information" as information contained in the education records of a student that would not generally be considered harmful or an invasion of privacy if disclosed. At Interlochen, directory information includes:

• Name
• Hometown (city, state)
• Class Standing (freshman, sophomore, junior, senior, etc.)
• Major Field of Study
• Dates of Attendance
• Activities
• Admission or Enrollment Status
• Degrees and Awards

Parents or students may opt out of having directory information published. For further information, see the section “Ceasing the Collection and Use of Personal or Personally Identifiable Information” below.

G Suite for Education Notice to Parents and Guardians

This notice describes the personal information we provide to Google for these accounts and how Google collects, uses, and discloses personal information from students in connection with these accounts.

Using their G Suite for Education accounts, students may access and use the following “Core Services” offered by Google:

• Gmail
• Google+
• Calendar
• Chrome Sync
• Classroom
• Cloud Search
• Contacts
• Docs, Sheets, Slides, Forms
• Drive
• Groups
• Google Hangouts, Google Chat, Google Meet, Google Talk
• Keep
• Sites
• Vault

In addition, we also allow students to access certain other Google services with their G Suite for Education accounts. Specifically, your child may have access to the following “Additional Services”: YouTube, Blogger, Chrome Web Store, FeedBurner, Google Alerts, Google Analytics, Google Bookmarks, Google Books, Google Cloud Platform, Google Cloud Print, Google Custom Search, Google Data Studio, Google Earth, Google Maps, Google My Maps, Google Photos, Google Play, Google Play Console, Google Public Data, Google Search Console, Google Takeout, Google Translator Toolkit, Google Voice, Individual Storage.

Google provides information about the information it collects, as well as how it uses and discloses the information it collects from G Suite for Education accounts in its G Suite for Education Privacy Notice.

You should review this information in its entirety, but below are answers to some common questions:

What personal information does Google collect?

When creating a student account, Interlochen Center for the Arts may provide Google with certain personal information about the student, including, for example, a name, email address, and password. Google may also collect personal information directly from students, such as telephone number for account recovery or a profile photo added to the G Suite for Education account.

When a student uses Google services, Google also collects information based on the use of those services. This includes: device information, such as the hardware model, operating system version, unique device identifiers, and mobile network information including phone number; log information, including details of how a user used Google services, device event information, and the user's Internet protocol (IP) address; location information, as determined by various technologies including IP address, GPS, and other sensors; unique application numbers, such as application version number; and cookies or similar technologies which are used to collect and store information about a browser or device, such as preferred language and other settings.

How does Google use this information?

In G Suite for Education Core Services, Google uses student personal information to provide, maintain, and protect the services. Google does not serve ads in the Core Services or use personal information collected in the Core Services for advertising purposes.

In Google Additional Services, Google uses the information collected from all Additional Services to provide, maintain, protect and improve them, to develop new ones, and to protect Google and its users. Google may also use this information to offer tailored content, such as more relevant search results. Google may combine personal information from one service with information, including personal information, from other Google services.

Does Google use student personal information for users in K-12 schools to target advertising?

No. For G Suite for Education users in primary and secondary (K-12) schools, Google does not use any user personal information (or any information associated with an G Suite for Education Account) to target ads, whether in Core Services or in other Additional Services accessed while using an G Suite for Education account.

Can my child share information with others using the G Suite for Education account?

We allow students to access Google services such as Google Docs and Sites, which include features where users can share information with others or publicly. When users share information publicly, it may be indexable by search engines, including Google.

Will Google disclose my child’s personal information?

Google will not share personal information with companies, organizations and individuals outside of Google unless one of the following circumstances applies:
With parental or guardian consent. Google will share personal information with companies, organizations or individuals outside of Google when it has parents’ consent (for users below the age of consent), which may be obtained through G Suite for Education schools.

With Interlochen Center for the Arts. G Suite for Education accounts, because they are school-managed accounts, give administrators access to information stored in them.

For external processing. Google may provide personal information to affiliates or other trusted businesses or persons to process it for Google, based on Google’s instructions and in compliance with the G Suite for Education privacy notice and any other appropriate confidentiality and security measures.

For legal reasons. Google will share personal information with companies, organizations or individuals outside of Google if it has a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to: meet any applicable law, regulation, legal process or enforceable governmental request; enforce applicable Terms of Service, including investigation of potential violations; detect, prevent, or otherwise address fraud, security or technical issues; protect against harm to the rights, property or safety of Google, Google users or the public as required or permitted by law.

Google also shares non-personal information—such as trends about the use of its services—publicly and with its partners.

What choices do I have as a parent or guardian?

First, you can consent to the collection and use of your child’s information by Google. If you don’t provide your consent, we will not create a G Suite for Education account for your child, and Google will not collect or use your child’s information as described in this notice.

If you consent to your child’s use of G Suite for Education, you can access or request deletion of your child’s G Suite for Education account by contacting wecanhelp@interlochen.org. If you wish to stop any further collection or use of your child's information, you can request that we use the service controls available to limit your child’s access to features or services, or delete your child’s account entirely. You and your child can also visit https://myaccount.google.com while signed in to the G Suite for Education account to view and manage the personal information and settings of the account.

What if I have more questions or would like to read further?

If you have questions about our use of Google’s G Suite for Education accounts or the choices available to you, please contact wecanhelp@interlochen.org. If you want to learn more about how Google collects, uses, and discloses personal information to provide services to us, please review the G Suite for Education Privacy Center, the G Suite for Education Privacy Notice, and the Google Privacy Policy. The Core G Suite for Education services are provided to us under Google’s Apps for Education agreement and the Data Processing Amendment.

California Privacy Rights

California residents may obtain once a year, and without charge, a list of your personal information that Interlochen has disclosed to third parties for marketing purposes within the previous calendar year. This includes a list of all personal information disclosed to third parties, as well as the names and addresses of the third parties that received your personal information. If you are a California resident and would like to make a request for disclosure under this section, please contact privacy@interlochen.org in writing.

Donor Privacy Policy

All information concerning prospective donors, including names and addresses, names of beneficiaries, nature and value of estates, amounts of provisions, etc., will be kept strictly confidential by staff, volunteers, and members of the Board Trustees and may not be released to any other party without the donor’s permission, except by subpoena or court order. Donors must grant permission for Interlochen to use selective information for purposes of referrals, testimonials, or examples.

Donor requests to remain anonymous, to have their names removed from mailing lists, or to restrict solicitations will be honored.

Interlochen Center for the Arts does not trade, share or sell a donor’s personal information with anyone else, nor send donor mailings on behalf of other organizations. In the unlikely event that Interlochen should ever desire to share donor information it will not do so without first obtaining specific permission from the donor(s) concerned.

Information Security

Interlochen works to protect the security of your personal and personally identifiable information and has implemented industry standard encryption to protect against unauthorized access to or interception of your personal and personally identifiable information. You are responsible for the security of the username and password associated with any user account(s) you may create, and you have an ongoing duty to guard against unauthorized access. In the event you discover unauthorized access to your user account(s), You must immediately inform Interlochen of the details of the unauthorized access.

Interlochen collects and processes your personal and personally identifiable information on servers located within the United States and, through your use of its website, applications, and/or online programs, you hereby expressly agree to the processing of your personal and personally identifiable information within the United States.

Sharing of Personal and Personally Identifiable Information

Interlochen does not sell or rent your personal personal or personally identifiable information to third parties. Interlochen may, however, share your personal or personally identifiable information with third parties that use its website, applications, and/or online programs in order to provide the services offered through those platforms. Interlochen may also share your personal information with third party service providers retained by Interlochen, such as credit card processors and marketing agencies, to provide you with additional information on the products or services of Interlochen or to aid you in the performance of Interlochen’s services. Interlochen may also transfer your personal or personally identifiable information to third parties upon your consent. Interlochen may transfer your personal or personally identifiable information to share information with its parents or subsidiaries or to a third party in a sale of Interlochen. Interlochen may also transfer your personal or personally identifiable information to respond to a duly authorized subpoena or court order, to respond to regulatory requests by government authorities, to protect the safety or security of Interlochen and/or its website, applications, online programs, employees, and users, and, where necessary, to protect against fraud, false advertising, or the violation of any law, statute, ordinance, regulation, or treaty, whether local, state, provincial, national or international.

Ceasing the Collection and Use of Personal or Personally Identifiable Information

You may cease Interlochen’s collection and use of your personal or personally identifiable information by discontinuing your use of Interlochen’s website, applications, and/or online programs and by adjusting your web browser settings to clear any cookies remaining on your computer from your prior use of those platforms.

To review your personal information that Interlochen has collected for you (or your student, if you are the parent of a student) or to cease the use of or request deletion of your information (or your student’s information, if you are the parent of a student), you may submit a request by emailing Interlochen at privacy@interlochen.org, by calling 231.276.6004, or by sending a written request to:

     Interlochen Center for the Arts
     c/o IT Help Desk - Privacy Policy
     P.O. Box 199
     Interlochen, MI 49643