Privacy Policy

Last updated: [INSERT DATE ON PUBLISH]

This Privacy Policy explains how GEMA Pathways Foundation ("GEMA Pathways," "we," "us," or "our"), a California nonprofit 501(c)(3) organization, collects, uses, and shares personal information when you visit our website, make a donation, sign up for communications, or otherwise interact with us (collectively, the "Site").

By using the Site, you agree to the practices described in this Policy. If you do not agree, please do not use the Site.

1. Who We Are

GEMA Pathways Foundation is the philanthropic arm of the Global Entertainment Marketing Academy of Arts & Sciences (GEMA). We are a 501(c)(3) charitable organization, EIN 84-4694228, and we are the entity responsible for ("controller" of) the personal information collected through the Site.

2. Information We Collect

Information you provide to us

• Donations. When you make a donation, our payment processor collects your name, email address, billing address, and payment card details, and shares transaction confirmation information with us. We use this to process your gift and issue receipts.
• Inquiries and forms. If you contact us or complete a form (for example, to volunteer, express interest in a program, or ask a question), we collect the information you provide, such as your name, email address, and message.
• Email subscriptions. If you sign up to receive updates, we collect your email address and any preferences you share.

Information collected automatically

When you visit the Site, we and our hosting and analytics providers may automatically collect technical and usage information, including your IP address, device and browser type, operating system, referring pages, the pages you view, and the dates and times of your visits. We collect this through cookies and similar technologies (see Section 5).

Payment information

Donations are processed by Stripe. Your full payment card number is collected and handled directly by Stripe and is not stored on our servers. Stripe's handling of your information is governed by its own privacy policy, available at stripe.com/privacy.

3. How We Use Your Information

• To process donations and provide tax receipts and acknowledgments;
• To respond to your inquiries and provide requested information;
• To send communications you have requested, such as newsletters and updates (you can opt out at any time);
• To operate, maintain, and improve the Site;
• To comply with our legal, tax, and charitable-reporting obligations, including donation substantiation and recordkeeping required by the IRS and the California Attorney General; and
• To detect, prevent, and address fraud, security issues, and misuse.

4. How We Share Your Information

We do not sell your personal information. We share it only as follows:

• Service providers. With vendors that perform services on our behalf, such as our payment processor (Stripe), website host (Webflow), and email/communications and analytics providers. These providers may use your information only to perform services for us.
• Our affiliate. With the Global Entertainment Marketing Academy (GEMA), which provides shared operational and administrative support to the foundation, subject to appropriate safeguards.
• Legal and safety. When required by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of GEMA Pathways, our donors, or others.
• Business and organizational changes. In connection with a merger, reorganization, or transfer of assets, consistent with this Policy.

5. Cookies and Tracking Technologies

We use cookies and similar technologies to operate the Site, remember your preferences, and understand how the Site is used. Strictly necessary cookies are required for the Site to function. Analytics and other optional cookies are used to measure and improve performance. You can control cookies through your browser settings; disabling some cookies may affect how the Site works. We do not respond to "Do Not Track" browser signals.

6. Your Privacy Rights

California residents

Under the California Consumer Privacy Act, as amended (CCPA/CPRA), California residents have the right to request access to, correction of, and deletion of personal information we have collected, and to know how we have used and shared it, subject to legal exceptions. We do not sell or "share" personal information for cross-context behavioral advertising. You will not be discriminated against for exercising these rights. Under California's "Shine the Light" law, you may also request information about disclosures, if any, to third parties for their direct marketing purposes. To exercise these rights, contact us using the details in Section 11.

EEA, UK, and Swiss residents

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we process your personal information on the following legal bases: performance of a transaction you request (such as processing a donation); your consent (such as email subscriptions); and our legitimate interests in operating and improving the Site and the foundation. You have the rights to access, rectify, erase, restrict, and port your personal information, to object to processing, and to withdraw consent at any time. You also have the right to lodge a complaint with your local data protection authority. To exercise these rights, contact us using the details in Section 11.

7. Data Retention

We keep personal information for as long as needed to fulfill the purposes described in this Policy, including the period required to meet our legal, tax, and charitable-reporting obligations. Donation records are retained as required by applicable IRS and California recordkeeping rules. When information is no longer needed, we take reasonable steps to delete or de-identify it.

8. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against loss, misuse, and unauthorized access. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security.

9. International Visitors

We are based in the United States, and the Site is operated from the United States. If you access the Site from outside the United States, your information will be transferred to, stored, and processed in the United States, where data-protection laws may differ from those of your country. By using the Site, you consent to this transfer.

10. Children's Privacy

The Site is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided us personal information, please contact us and we will take steps to delete it.

11. Changes to This Policy

We may update this Policy from time to time. When we do, we will revise the "Last updated" date above. Your continued use of the Site after changes are posted constitutes acceptance of the updated Policy.

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Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, contact us: