PRIVACY POLICY FOR THE CREATIVEGROUND WEBSITE

Welcome to the CreativeGround website ("site") administered and operated by the New England Foundation for the Arts ("NEFA," "We," "Us," "Our"), and developed in conjunction with the New England state arts agencies ("SAAs"): the Connecticut Department of Economic and Community Development, the Maine Arts Commission, the Massachusetts Cultural Council, the New Hampshire State Council on the Arts, the Rhode Island State Council on the Arts, and the Vermont Arts Council. This Privacy Policy ("Policy") covers how We use and treat information collected and received through use of this site by users ("You"). Upon reading this Policy, You will know this site's privacy practices, including:

  1. What personally identifiable information is collected from You through Your use of this site and how this is done;
  2. How Your information will be used;
  3. With whom the information may be shared or disseminated, under what circumstances this can occur, and what type of information is shared;
  4. The type of security measures that are in place, if any, to protect against the loss, misuse, alteration, or unintentional destruction of Your information;
  5. How You can access and correct any inaccuracies in the information provided by You, when appropriate; and
  6. Who to contact if You have any questions regarding this Policy and the collection and use of Your information.
  1. General Privacy Considerations
    Based upon this Policy, You can, in some cases, make an informed choice as to the information You wish to share with Us. As a general matter, We take reasonable precautions to protect Your privacy, when appropriate, depending upon the nature of the information to be protected. We cannot and do not, however, guarantee absolute privacy. As detailed herein, certain information that You provide to Us, including personally identifiable information (as defined below), is provided to SAAs in conjunction with their public responsibilities to promote and foster their citizens' interest in the arts, humanities, interpretive sciences, and cultural fields. In addition, certain information that You provide to Us will be displayed publicly on the site for users and other third parties to use as they see fit. For example, one of the principal functions of CreativeGround is to create an online directory whereby artists, presenters, performers, and venues will be able to collaborate professionally with each other and with other resources. Collaboration would be difficult, if not impossible, unless users openly disclosed enough information about themselves to allow other interested parties to contact them in order to facilitate productive interactions.

    This Policy does not apply to the privacy practices of any SAAs. We make no representations and are not responsible for the privacy, information collection, disclosure, and data correlation and aggregation practices, if any, of a SAA. For example, some states may have laws, regulations, and/or directives in effect which govern the use and disclosure of public information or how personally identifiable information is to be collected, stored, treated, accessed, and disseminated by a state agency. Any questions or concerns that You have regarding privacy and the use of Your information should be directed to the appropriate party at each SAA or to Your legal counsel. Also, this Policy does not apply to any other websites or databases for which We or other users may use or provide links. Please consult the appropriate policy of that site or database if You have any questions or concerns about its privacy practices.

  2. What Information We Collect and How We Do It.
    Information can generally be collected in two ways: (1) Information that is knowingly and voluntarily input into Our system directly by You in response to particular prompts or fields; and (2) information that is collected automatically. Mere use and viewing of this site does not require You to input any "personally identifiable information" in response to particular prompts or fields. If, however, You decide to use the many functions on the site, You will be required to input certain "personally identifiable information" at various times. In addition, as described below, this site automatically collects some information when You use it.

    We use the term "personally identifiable information" to mean any type of information that could be utilized to identify or be readily associated with You, the user of this site. Examples of personally identifiable information may include, but are not limited to, Your name, address, telephone number, and e-mail address, or any combination thereof.  This information disclosed by You will be publicly available to any user who uses the site to search the database.   You may also be required to disclose specific information about Yourself and/or Your organization in order to use this site's many features effectively. This would be a voluntary disclosure by You of personally identifiable information. Some of this information would be disclosed to other users or third parties who use the site, while other information would only be disclosed to Us for Our own use or to a SAA.

    The transmission of an e-mail voluntarily initiated by You to Us or to another user can also transmit personally identifiable information about You. Your e-mail address can also be considered personally identifiable information in some instances. Moreover, if You include Your name, telephone number, and other information in the body of the e-mail or transmission, this information is personally identifiable. You should not send personally identifiable information via unencrypted e-mail, particularly information which You deem to be sensitive or confidential. This information could also be disclosed to others outside of Your intended recipient in certain circumstances.

    The automatic collection of information refers to information collected from You that does not require You to intentionally provide information in response to particular prompts or fields. For example, a site can use "cookies." A cookie is a small text file placed automatically on Your computer's web browser that is used to recognize users who have previously visited the site. In general, these cookies are either persistent and may reside on Your computer after You last accessed the site (or until You delete or otherwise dispose of them) or on a temporary basis. For example, a site may use temporary cookies called "session cookies," which are stored for a single user session with the site and are deleted as soon as the user's browser is shut down. Presently, We use persistent cookies on Our site to store Your e-mail address, but only when You choose to have the site remember Your log-in information when You first visit the site.
    We automatically collect Your "internet protocol" ("IP") address.  An IP address is a unique series of numbers that identifies each computer connected to the internet. An IP address can be used to provide information such as the date and time of a user's visit, the availability of certain requested files, the popularity of various site functions, and the amount of information transmitted to each user from a site. Presently, We use Your IP address to address the frequency of Your visits to this site and to determine the frequency with which certain pages and functions of the site are accessed. This will allow Us to improve the site's functionality and determine which features generate the most interest. As a particular computer is identified, rather than identifying a particular user, no personally identifiable information is disclosed. We will not routinely attempt to match Your particular IP address to any personally identifiable information that You may provide to Us on Your own, except in certain situations. For example, in instances where We, in Our sole discretion, suspect or determine that the site is being used for any unacceptable, inappropriate, or illegal purposes, information relating to Your use of this site may be disclosed to other parties as We deem appropriate. Such information may also be disclosed pursuant to any authorized law enforcement investigation, regardless of whether it was initiated by Us or by another party, or through other authorized legal process or procedure.

  3. How We Use and/or Disseminate Your Personally Identifiable Information
    We may, in Our sole discretion, sell, license, or allow access to certain personally identifiable or other information We collect from You when using this site to certain third parties.  Also, once personally identifiable information is collected through Your use of this site, regardless of how often You use it, We will make certain uses of it for Our own internal purposes consistent with Our responsibilities to administer and operate the site.
       
    Each SAA will have access to certain personally identifiable information of users based upon Your home residence. For example, the Massachusetts Cultural Council will have access to certain information about artists who reside in Massachusetts, but not those who reside in other New England states. A SAA may need this information about You in order to fulfill its responsibility to its legislature for funding or public reporting purposes. Your information may then be disseminated publicly pursuant to Your state's particular information collection and disclosure practices.

    Your information may also be combined, aggregated, or correlated with other information that the SAA may have in its possession about You. If You have any questions about how a SAA is going to use Your personally identifiable information, You must contact the appropriate party at the SAA for the state in which You are a resident. In addition, as stated above, We may also use and process Your personally identifiable information for Our own purposes independent of a SAA's purpose. For example, We may also combine Your personally identifiable information with other information that would not otherwise be available to a SAA.

    Each SAA will also have access to certain aggregate data about all users. "Aggregate data" is statistical data comprised of many pieces of information from other users with all personally identifiable characteristics removed. For example, each SAA may want to know the total number of users in each of the New England states who use the site. Or a SAA may want to know the total number of venues or performers that are listed on the site. There are any number of ways in which aggregate data may be compiled and disseminated to a particular SAA. While this aggregate data may become publicly available, it will not be personally identifiable to any particular user. Aggregate data will help Us and each SAA better understand how the site is being used, Your needs while on the site, and to increase and improve the site's features and functionality for all users.

    As the site administrator, We have a broad array of responsibilities with respect to operating this site and are charged with ensuring that it is used properly and appropriately by all users. As stated in more detail in the Terms and Conditions of Use ("TCU"), it is Your responsibility to ensure that You use this site responsibly and in accordance with Our Unacceptable Use and Content Policy ("Use and Content Policy") in the TCU. If We or a SAA receive a complaint from another user or other third party, or otherwise learn that You are using the site inappropriately or posting content in violation of the Use and Content Policy, whether intentionally or not, We or the appropriate SAA may access Your personally identifiable and other information to determine, in Our sole discretion, the validity and substance of such a complaint. If We, in Our sole discretion, deem the complaint to have merit or if it requires further investigation, personally identifiable information relating to Your use of this site may be disclosed to other parties as We deem appropriate. Such information may also be disclosed pursuant to any authorized law enforcement investigation or other judicial process, regardless of whether it was initiated by Us or another party. We or the appropriate SAA may also take other remedial actions with respect to Your use or content, as described in the TCU. We may also access Your information if You contact Us and give Us permission to do so.

    If You contact Us via e-mail or letter (collectively, "communication") regarding the site, and We are not the appropriate party regarding the subject of Your inquiry, We may, in Our sole discretion, forward and disclose Your communication to the appropriate party for the matters referred to therein. 

  4. Web Site Security
    We do not use encryption in any area of this site. Certain areas of this site, however, are only accessible by password and are not available to the general public. You are responsible for selecting and maintaining the confidentiality of Your password and account information. Sharing of Your password and account information is at Your own risk. We will also make back-up copies of the site and user data at regular intervals.
  5. Accessing and Correcting Your Information
    If You provide personally identifiable information to Us, We will, in most instances, provide access to You to correct any information that You deem to be inaccurate, incomplete, or out-of-date (collectively "outdated information"), as long as Your account remains active. Also, even if You correct or update Your personally identifiable information (in Your profile, for example), Your outdated information may still remain in the possession of other users or third parties, such as Your respective SAA. This may also occur even if You no longer use the site and Your profile becomes inactive or if You delete Your personally identifiable information in its entirety.
  6. Children's Information
    We do not actively market, target, or direct Our efforts to, or knowingly collect personally identifiable information from, children under the age of thirteen (13) years.
  7. Third Party Service Providers
    NEFA contracts with a third party service provider, Last Call Media and Pantheon.io to host this site. We only provide third party service providers with Our information so that it may perform its services. We do not purposely or knowingly disclose Your personally identifiable information to third party service providers unless We are required to do so. Last Call Media and Pantheon.io, however, may also have access to Your personally identifiable information and may disclose it to other parties in certain circumstances. We do not control and are not responsible for Last Call Media and Pantheon.io conduct and for any disclosures that it may make. If You have any questions about Last Call Media and Pantheon.io privacy policy or other business practices, You may review this information or contact the companies at their websites: www.lastcallmedia.com and www.pantheon.io. Please note that by visiting the Echoditto site, a persistent or temporary cookie may be placed on Your web browser which could be used to analyze Your usage of that particular site.
  8. Policy Revisions
    You will be notified via e-mail by Us if this Policy is amended or modified. Any use of the site after the date of notification shall be deemed acceptance of the amended or modified Policy. 
  9. Contact Information
    For any questions about this Privacy Policy or Our information collection and dissemination practices, please contact CreativeGround via mail at: New England Foundation for the Arts, 145 Tremont Street, 7th Floor, Boston, MA 02111-1214; or via e-mail at: creativeground@nefa.org.