PRIVACY POLICY

The Sheffield Institute for the Recording Arts, a d/b/a of SHEFFIELD RECORDINGS LTM INC.
Last Updated: July 2026

We do not sell or share mobile numbers, SMS consent, or message data with third parties or affiliates for their marketing or promotional purposes. We may share this information only with service providers (e.g., carriers, messaging platforms) to operate our SMS program. Message frequency may vary. Message & data rates may apply. Reply STOP to opt out; HELP for help

1. Introduction

Sheffield Institute for the Recording Arts, a d/b/a of SHEFFIELD RECORDINGS LTM INC. ("Sheffield," "we," "us," "our," or "company") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (www.sheffieldav.com), submit enrollment inquiries, receive SMS communications, or interact with our services.

Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use our services.

Important: This Privacy Policy is published on our website and a link is provided at the point where users opt in to receive SMS communications. By opting in to SMS, you acknowledge you have reviewed this policy.

1A. Carrier Compliance — SMS Phone Number Use & Disclosure

This section addresses carrier requirements regarding mobile number collection, use, and disclosure.

Requirement 1 — Phone Number Collection & Use

Sheffield collects phone numbers only when you affirmatively opt in to receive SMS communications. Phone numbers collected through SMS opt-in are used exclusively for the following purposes:

  • Sending transactional SMS messages (tour confirmations, enrollment updates, account information)
  • Sending promotional SMS messages (program offers, events, special offers)
  • Maintaining compliance records for TCPA and 10DLC regulations
  • Delivering SMS communications you have requested

Phone numbers are not used for any other purpose, including:

  • Website analytics or performance tracking
  • Marketing to your other contact information
  • Audience segmentation
  • Behavioral targeting
  • Lead scoring or enrollment prediction
  • Any purpose other than SMS delivery

Requirement 2 — SMS Data Not Shared for Marketing

Text messaging originator opt-in data and consent will not be shared with any third parties, excluding aggregators and providers of the Text Message services.

Specifically, SMS phone numbers collected through opt-in are not shared with:

  • Google Analytics or any analytics platforms—for marketing purposes or any purpose
  • HubSpot or any CRM systems—SMS data remains completely separate
  • Marketing automation platforms
  • Advertising networks or data brokers
  • Email service providers or social media platforms
  • Any third party for marketing, analytics, or any non-SMS purpose

SMS phone numbers may only be shared with:

  • Our SMS service provider/aggregator (for message delivery, compliance, and regulatory requirements only)
  • Third-party carriers and message aggregators necessary to deliver SMS (as required by the 10DLC/SMS service)
  • Sheffield's internal compliance team (for legal and regulatory documentation only)

These SMS service providers are contractually bound to use the data only for SMS delivery and compliance purposes and are prohibited from sharing SMS data with any other third parties.

Requirement 3 — No Marketing Use of SMS Data

Sheffield does not use SMS phone numbers or opt-in consent for:

  • Creating marketing segments or audiences
  • Cross-channel marketing (email, social, display ads)
  • Behavioral analysis or user profiling
  • Lead intelligence or enrollment prediction
  • Any marketing purpose outside of the SMS channel itself
  • Analytics, tracking, or conversion measurement beyond SMS delivery
  • Sales or disclosure to third parties

SMS data is used only to deliver SMS messages you have opted in to receive.

Requirement 4 — Policy Link in Opt-In Flow

This Privacy Policy must be accessible via direct link at the point where users provide their phone number and opt in to SMS communications. The link should be clearly visible on or immediately adjacent to the SMS opt-in checkbox. Users must be able to click the link and review this entire Privacy Policy before submitting their SMS opt-in consent.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you voluntarily provide, including:

  • Name, email address, phone number
  • High school name, graduation year
  • Program of interest
  • Application and enrollment information
  • Tour booking details
  • Communications and inquiries sent to us

2.2 Website Analytics & Tracking (Non-SMS Traffic Only)

For visitors who do not opt in to SMS communications, we use tracking technologies to analyze website performance and enrollment conversions.

Google Analytics

  • We use Google Analytics to track website traffic, user behavior, pages visited, and enrollment funnel performance
  • Google Analytics may collect: browser type, IP address, device type, pages visited, time on page, referral source, and interaction data
  • This data is used to understand website performance and optimize our enrollment process
  • Google Analytics is governed by Google's Privacy Policy

HubSpot

  • We use HubSpot CRM to track enrollment form submissions, program interest, and conversion metrics
  • HubSpot may receive: name, email address, phone number, high school, graduation year, program of interest, and form submission data
  • This data is used for lead management, enrollment tracking, and conversion analysis

Cookies & Tracking

  • Our website may use cookies and tracking pixels to support Google Analytics and HubSpot tracking
  • These cookies track your website behavior and interactions with our enrollment forms
  • You can disable cookies in your browser settings, though this may affect functionality

Critical distinction—SMS data is not tracked: Phone numbers collected through SMS opt-ins are never tracked through Google Analytics, HubSpot, cookies, or any web tracking technologies. SMS phone numbers are completely separate from web analytics tracking.

2.3 Information We Do Not Collect (SMS-Specific)

For SMS opt-in data:

  • SMS phone numbers are not tracked through Google Analytics
  • SMS phone numbers are not associated with web tracking cookies
  • SMS phone numbers are not linked to HubSpot web analytics
  • SMS consent data is not collected through web tracking technologies

2.4 SMS-Related Information

When you opt in to receive SMS communications:

  • Phone number
  • Opt-in timestamp and consent documentation
  • Message delivery status
  • Your replies to our messages (STOP, HELP, etc.)
  • Enrollment status and program information

SMS data is stored only with our SMS service provider for message delivery and legal compliance purposes. SMS data is not shared with any third parties, including Sheffield's CRM systems or web analytics platforms.

3. How We Use Information

3.1 General Use

We use collected information to:

  • Process enrollment inquiries and applications
  • Schedule and confirm campus tours
  • Respond to your questions and requests
  • Provide services you request
  • Comply with legal obligations
  • Analyze website performance and improve user experience (non-SMS data only)
  • Track enrollment conversions and program interest (non-SMS data only)

3.2 Non-SMS Web Analytics Use

For non-SMS visitors, we use Google Analytics and HubSpot to:

  • Track website traffic and user flow
  • Measure enrollment form completion rates
  • Understand which programs generate the most interest
  • Optimize the enrollment process
  • Measure conversion from inquiry to application
  • Improve our website and marketing effectiveness

3.3 SMS-Specific Use

SMS opt-in data is used only to:

  • Send transactional messages (tour confirmations, enrollment updates, account confirmations)
  • Send promotional messages (program offers, events, special offers)—only if opted in
  • Maintain compliance records for TCPA and 10DLC regulations
  • Fulfill your request for SMS communications

3.4 Strict Data Separation

SMS data and web analytics data are never combined:

  • SMS phone numbers are not linked to web analytics profiles
  • SMS conversions are not tracked through Google Analytics
  • SMS recipients are not included in web tracking audiences
  • SMS originator data remains completely isolated from all web analytics platforms

4. Data Sharing & Third Parties

4.1 SMS Data—Zero Third-Party Sharing (Excluding SMS Service Providers Only)

Text Messaging Originator Opt-In Data and Consent

Text messaging originator opt-in data and consent will not be shared with any third parties, excluding aggregators and providers of the Text Message services.

Phone numbers and personal information collected through SMS opt-ins are not shared with any third parties, including:

  • Google Analytics or any analytics platforms
  • HubSpot or any CRM systems
  • Marketing automation platforms
  • Advertising networks
  • Data brokers
  • Social media platforms
  • Email service providers

SMS data is not shared for marketing: Sheffield does not share SMS phone numbers or opt-in data with any third party for marketing, advertising, audience targeting, or any commercial purpose outside of SMS message delivery.

Exceptions—SMS service providers only: SMS data is stored and processed only with:

  • Our SMS service provider/aggregator (for message delivery, compliance, and regulatory requirements)
  • Sheffield's internal systems (for compliance records only)
  • Third-party service providers necessary to deliver SMS services (carriers, message aggregators, compliance platforms)

These SMS service providers are contractually required to:

  • Use the data only for SMS delivery and compliance purposes
  • Not share the data with any other third parties
  • Maintain strict confidentiality and security standards
  • Comply with TCPA, 10DLC, and all applicable regulations
  • Not use SMS data for marketing, analytics, or any other purpose

Exception: We may disclose SMS data when required by law, court order, or regulatory agency (10DLC compliance, law enforcement, FCC investigations).

4.2 Non-SMS Enrollment & Web Analytics Data

For visitors who submit enrollment inquiries or browse our website (without SMS opt-in), data may be shared with:

Google Analytics

  • Enrollment form data (name, email, program) may be sent to Google Analytics for conversion tracking
  • Website behavior and interaction data is tracked through Google Analytics
  • This data is used to measure enrollment funnel performance
  • Google is contractually required to protect this data per Google's Data Processing Agreement

HubSpot

  • Enrollment form submissions (name, email, program, high school, graduation year) are stored in HubSpot CRM
  • HubSpot is used for lead management, enrollment tracking, and conversion analysis
  • HubSpot is contractually required to protect this data and not share it for marketing purposes

These analytics platforms may use cookies and tracking pixels on our website.

4.3 Important Data Separation Rule

Phone numbers collected through SMS opt-ins are kept completely separate and are never:

  • Sent to Google Analytics
  • Sent to HubSpot web analytics
  • Linked to web tracking profiles
  • Associated with enrollment form data in analytics systems
  • Used for marketing purposes

4.4 Legal Requirements

We may disclose information when required by law, legal process, or government request, including:

  • Subpoenas or court orders
  • FCC or regulatory investigations
  • TCPA enforcement actions
  • 10DLC compliance audits
  • Law enforcement requests

4.5 What We Do Not Do

  • We do not use SMS data in Google Analytics
  • We do not link SMS phone numbers to web analytics
  • We do not share SMS originator data with HubSpot web analytics
  • We do not use SMS data for marketing analytics
  • We do not sell personal information
  • We do not share SMS originator data with data brokers or unauthorized third parties
  • We do not combine SMS and web analytics data
  • We do not use SMS data for marketing purposes of any kind
  • We do not share SMS data with third parties for cross-channel marketing
  • We do not use SMS phone numbers outside the SMS channel

5. Data Retention

5.1 SMS Data

  • Phone numbers: Retained for 3 years after last interaction or opt-out
  • SMS message history: Retained for 2 years for compliance purposes
  • Opt-in/opt-out timestamps: Retained indefinitely for legal compliance

5.2 Enrollment Data (Web Analytics)

  • Google Analytics data: Retained per Google's standard policy (typically 26 months)
  • HubSpot enrollment records: Retained for 7 years (per Maryland Higher Education Commission requirements)
  • Form submissions: Retained for 7 years

5.3 Deletion Requests

You may request deletion of your personal information at any time. We will comply within 30 days, except where:

  • Data is required for legal compliance
  • Data is necessary for active enrollment processes
  • Data is required to process your request

6. Your Privacy Rights

6.1 Access Your Information

You have the right to request access to the personal information we hold about you. Contact us with details about what information you'd like to review.

6.2 Correct Inaccurate Information

You may request that we correct inaccurate or incomplete information. Submit corrections through our website or by contacting us directly.

6.3 Request Deletion

You may request deletion of your personal information, except where we're required to retain it for legal or business purposes.

6.4 Opt-Out of Communications

  • For SMS: Reply STOP to any message or contact us directly
  • For website inquiries: Contact us to remove your enrollment inquiry
  • For Google Analytics: Disable cookies in your browser or install the Google Analytics Opt-out Extension

6.5 Withdraw SMS Consent

You may withdraw consent to receive SMS at any time by:

To exercise any of these rights, contact us at:

Sheffield Institute for the Recording Arts
Email: info@sheffieldav.com
Phone: (410) 628-7260

7. Cookies & Tracking Technologies

7.1 Non-SMS Web Traffic

Our website uses cookies and tracking pixels to support:

  • Google Analytics tracking
  • HubSpot form tracking
  • Enrollment funnel analysis
  • Website performance measurement

7.2 Types of Cookies

  • Essential cookies: Required for website functionality
  • Analytics cookies: Used by Google Analytics for web behavior tracking
  • Conversion cookies: Used by HubSpot for enrollment tracking

7.3 Disabling Cookies

You can disable cookies through your browser settings. However, this may affect website functionality and your ability to complete enrollment forms. Cookies do not track SMS opt-in data.

7.4 SMS Data & Cookies

Personal information collected through SMS opt-ins is never associated with website tracking cookies or analytics profiles.

8. Security

8.1 Data Protection Measures

We implement reasonable security measures to protect your personal information, including:

  • HTTPS encryption for all data transmission
  • Secure authentication where applicable
  • Limited employee access to personal information
  • Regular security reviews
  • Contractual data security agreements with SMS service providers, Google Analytics, and HubSpot

8.2 Limitations

While we strive to protect your information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security.

8.3 Data Breach Response

In the event of a data breach affecting SMS recipient information, we will:

  • Notify affected individuals within 72 hours
  • Report to relevant regulatory agencies as required
  • Cooperate with law enforcement
  • Take corrective actions to prevent future breaches

9. Children's Privacy

9.1 Age Restriction

Our services are not directed to children under 13. We do not knowingly collect personal information from children under 13.

9.2 Parental Consent

If you are under 18, you represent that you have obtained parental or guardian consent before:

  • Submitting an enrollment inquiry
  • Opting in to receive SMS communications
  • Providing any personal information

If we become aware that we have collected information from a child under 13 without proper consent, we will delete it immediately.

10. International Data Transfers

Our data is stored and processed in the United States. By providing your information, you consent to the transfer, storage, and processing of your data in the US, which may have different privacy protections than your home country.

11. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for their privacy practices. Please review their privacy policies before providing personal information.

12. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

  • Right to know what personal information we collect
  • Right to delete personal information
  • Right to opt-out of data sales (we do not sell data)
  • Right to non-discrimination for exercising CCPA rights

To exercise CCPA rights, contact: info@sheffieldav.com.

13. Virginia & Other State Privacy Laws

We comply with privacy laws in all states where we operate, including:

  • Virginia Consumer Data Protection Act (VCDPA)
  • Maryland privacy regulations
  • Federal privacy requirements (TCPA, CAN-SPAM, etc.)

14. SMS Marketing & Compliance

14.1 SMS Communications

SMS messages are sent only to users who have:

  • Affirmatively opted in via checkbox on our enrollment form
  • Provided documented consent with timestamp
  • Selected to receive SMS communications

14.2 SMS Compliance

All SMS communications comply with:

  • Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227
  • FCC 10DLC regulations
  • CTIA Short Code regulations
  • All applicable state and federal laws

14.3 Text Messaging Originator Data Protection

Text messaging originator opt-in data and consent will not be shared with any third parties, excluding aggregators and providers of Text Message services. Sheffield maintains strict control over all SMS opt-in data and ensures it is used solely for SMS delivery and compliance purposes. SMS data is not shared for marketing purposes.

14.4 Opt-Out Instructions

You may opt out by replying STOP or contacting us. After opting out, you will not receive further messages unless you re-engage with Sheffield. Your phone number will be added to our suppression list within 48 hours of your opt-out request.

15. Updates to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, legal requirements, or other factors. We will notify you of material changes by:

  • Posting the updated policy on our website
  • Updating the “Last Updated” date

Continued use of our services after updates constitutes your acceptance of the revised policy.

16. Contact Information

For questions about this Privacy Policy, your privacy rights, or to report a privacy concern:

Phone
(410) 628-7260

Email
info@sheffieldav.com

Website
www.sheffieldav.com

Address
13816 Sunnybrook Rd, Phoenix, MD 21131

Maryland residents: You may contact the Maryland Attorney General at:

Office of the Attorney General
200 Saint Paul Place
Baltimore, MD 21202
Phone: (410) 576-6300

17. Legal Compliance

This Privacy Policy is governed by the laws of the State of Maryland and complies with:

  • Maryland privacy regulations
  • Federal Trade Commission (FTC) regulations
  • TCPA (Telephone Consumer Protection Act)
  • CAN-SPAM Act (for email communications)
  • 10DLC regulations (for SMS communications)
  • CCPA (for California residents)
  • VCDPA (for Virginia residents)

18. Acknowledgment

By providing your personal information to Sheffield, you acknowledge that you have read this Privacy Policy and understand how we collect, use, and protect your data.

Compliance Certification

  • Phone numbers collected only through SMS opt-in consent
  • SMS phone numbers used exclusively for SMS delivery
  • SMS data not shared with Google Analytics
  • SMS data not shared with HubSpot or any CRM systems
  • SMS data not shared for marketing purposes
  • SMS data not shared with any third parties (except SMS service providers)
  • Google Analytics tracking enabled for non-SMS web traffic only
  • HubSpot CRM tracking enabled for enrollment data (non-SMS only)
  • Cookies used for web analytics (non-SMS traffic only)
  • SMS phone numbers completely isolated from all analytics
  • Text messaging originator opt-in data protected per 10DLC requirements
  • TCPA and 10DLC compliant
  • Policy linked in SMS opt-in flow (implementation requirement)

Carrier Compliance Summary

  1. Clear Privacy Policy: This Privacy Policy is published and linked at the point of SMS opt-in.
  2. Phone Number Use: SMS phone numbers are collected only through opt-in consent and used exclusively for SMS delivery of transactional and promotional messages.
  3. SMS Data Not Shared for Marketing: Text messaging originator opt-in data and consent will not be shared with any third parties, excluding aggregators and providers of the Text Message services. SMS data is not used for marketing purposes.
  4. Policy Linked in Opt-In Flow: This Privacy Policy must be accessible via direct link at the SMS opt-in point on the enrollment form.