Updated December 2018

This privacy notice (“Privacy Notice”) describes how Manhattan School of Music (“MSM”, “we”, “our”, or “us”) collects, uses, shares, processes and retains all personal information that you provide to us, or that we collect, when you: use or visit our website located at www.msmnyc.edu or related mobile applications; use our applications,, services, and tools and complete related forms; participate in mailing lists for periodic newsletters, promotional material, or application updates; or communicate with us (“Personal Data”).

We are committed to protecting your privacy and personal data shared with us or collected by us.

Scope

This privacy notice applies to any MSM website, application, service, or tool (collectively “Services”) where this privacy notice is referenced, regardless of how you access or use them, including through mobile devices.

This privacy notice applies to all personal information we collect or process about you. Personal information is information, or a combination of pieces of information, that could reasonably allow you to be identified.

Personal information we collect

What is personal information?

Personal information is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

We do not consider personal information to include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.

We collect personal information from you when you use our Services.

We collect personal information about you from a variety of sources, including from you directly (e.g. when you contact us or sign up for an account or participate in a MSM program or register for a course), information we generate about you in the course of our relationship with you (e.g. data collected from cookies and other similar technologies which is described in our Cookies and Information Use Policy and information we collect about you from other sources, including commercially available sources, such as public databases (where permitted by law).

We may be required by law to collect certain personal information about you or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfillment of these obligations.

Information we collect directly from you

The categories of information that we may collect directly from you include, but are not limited to, the following:

• personal details (e.g. name, date of birth);
• contact details (e.g. phone number, email address, postal address or mobile number);
• account details (e.g. username and password);
• transaction details;
• communications (e.g. when you contact us with a question, comment, opt-in for application updates, newsletters or request a tour)

Information we collect about your use of services

The following are examples of the other categories of information which we may collect about you:

• Technical information collected from your computer or mobile device (e.g. your browser type, operating system, device (laptop, mobile, tablet));
• Information about your usage of our website (e.g. the pages you visit when using the Services, the search terms you enter on the Services, how often you use the Services, and the pages you access before and after accessing the Services);
• Information which we generate as a result of your use of the Services (e.g. our understanding of your interests as a result of your use of the Services and whether you are a regular or occasional user of the Services).

Information we collect from other sources

The following are examples of the categories of information we may collect from other third parties sources, such as online advertising agencies, fraud prevention agencies, or publicly available information. Please note that this is not an exhaustive list of categories.

• personal details (e.g. name, date of birth);
• contact details (e.g. phone number, email address, postal address or mobile number);
• details about advertising preferences (e.g. products purchased, interaction with advertisements online).

How we use your personal information and basis on which we use it

We may use your personal information for the following purposes:

Identification and authentication

We use your identification information to verify your identity when you access and use our Services and to ensure the security of your personal information. This is so we can comply with our contractual obligations to you.

Operating the Services

We process your personal information to provide the Services you have requested. This is so we can comply with our contractual obligations to you.

Improving our Services

We analyze information about how you use our Services to provide an improved experience for our customers of all our Services, and for website analytics. It is in our legitimate institutional interests to use the information provided to us for this purpose, so we can understand any issues with our Services and improve them.

Communicating with you

We may use your personal information when we communicate with you (for example, if we are providing information about changes to the terms and conditions of our Services, or if you contact us with questions). It is in our legitimate interests that we are able to provide you with appropriate responses and provide you with notices about our Services.

We may use your personal information to build a profile about you and place you into particular marketing segments in order to understand your preferences better and to appropriately personalize the marketing messages we send to you. It is in our legitimate interest to provide more relevant and interesting marketing messages. Where necessary, we will obtain your consent before sending such marketing messages.

Exercising our rights

We may use your personal information to exercise our legal rights where it is necessary to do so, for example, to detect, prevent and respond to fraud claims, intellectual property infringement claims or violations of law or MSM’s Terms of Use.

Complying with our obligations

We may process your personal information to, for example, carry out fraud prevention checks or comply with other legal or regulatory requirements, where this is explicitly required by law.

Customizing your experience

When you use the Services, we may use your personal information to improve your experience of the Services, such as by providing interactive or personalized elements on the Services and providing you with content based on your interests.

We may also anonymize your personal information in such a way that you may not reasonably be re-identified by us or any other organization, and may use this anonymized information for any other purpose.

How and when we share your information

We may share your personal information with third parties under the following circumstances which include but are not limited to:

Service providers and business partners

We may share your personal information with our service providers and business partners that perform marketing services and other business operations for us for the purposes set forth above. For example, we may partner with companies to process secure payments, fulfill orders, optimize services, serve online behavioral advertising, send newsletters and marketing messages, support email and messaging services, and analyze information. These service providers and business partners may include communication agencies and fraud prevention agencies which will use your personal information only in the ways described in this policy.

Phone numbers collected for SMS consent will not be shared with third parties or affiliates for marketing purposes.

Where required by law

We may share your personal information with law enforcement agencies, courts, other government authorities or other third parties where we believe necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.

Your rights over your personal information

You have certain rights regarding the personal information we hold about you, subject to applicable law. These may include the rights to access, correct, delete, restrict or object to our use of, or to receive a portable copy in a usable electronic format, of your personal information. You also may have a right to lodge a complaint with your local data protection or privacy regulator.

We encourage you to contact us at the contact information set forth below to update or correct your information if it changes or if the personal information we hold about you is inaccurate. 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.

Information Security and Storage

We implement physical, technical, and organizational security measures designed to safeguard the personal information we process through the Services. These measures are aimed at providing on-going integrity and confidentiality of your personal information. We evaluate and update these measures on a regular basis.

We retain your personal information for as long as we have a relationship with you. When deciding how long to keep your personal information after our relationship with you has ended, we take into account our legal obligations. We may also retain records to investigate or defend against potential legal claims.

International Data Transfer

Your personal information may be transferred to, stored, and processed in a country that is not regarded as providing the same level of protection for personal information as the laws of your home country, and may be available to the government of those countries under a lawful order made in those countries.

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protections for your personal information.

In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries will be entitled to access your personal data.

Contact Us

For purposes of the European General Data Protection Regulation (GDPR), MSM is the controller responsible for the personal information we collect and process.

If you have questions or concerns regarding the way in which your personal information has been used, please contact privacy@msmnyc.edu.

In addition to that, you may contact us at privacy@msmnyc.edu to inform us of any status updates, consent withdrawal, or request for deletion or return of data.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority of your country of residence.

Changes to Privacy Notice

MSM may amend this privacy notice at any time by posting the amended version on this site including the effective date of the amended version. We will announce any material changes to this privacy notice via email.

MSM Notification of Security Incident (9.9.2020)