1 Introduction
1.1 The General Data Protection Regulation (GDPR) is European wide data protection legislation that requires organisations working with individuals based in the European Economic Area to meet certain requirements regarding the collection, processing, security and destruction of personal information. We aim to ensure compliance with the General Data Protection Regulation.(GDPR)
1.2 In this policy, “we”, “us” and “our” refer to GEMS.

1.3 We are committed to safeguarding the privacy of our website visitors and service users. This privacy policy will explain how we use the personal data you share with us.


1.4 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.
1.5 We do not sell, share or publish your data to third parties.

2 What data do we collect?
2.1 GEMS registration forms collect the following data:
2.2 Personal identification information first name, last name, email address, contact message, country code, phone number, citizenship, dropdown question form answers, tuition fee payments.

3 How do we collect your data?
3.1 You directly provide us with all of the data we collect. Our website is hosted on the Wix.com platform, who collect data and process data when you:
3.2 Register on the our website for any of our programs, events or competitions.
3.3 Contact us using the contact us form or any other form on the GEMS websites.
3.4 We may process information contained in any enquiry you submit to us regarding services “enquiry data”. The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is consent.
3.5 Make a tuition fee, registration fee, sponsor payment on our website through our secure payment processing services (Stripe and Paypal) which are PCI, and GDPR compliant.
3.6 We may process data about your use of our website “usage data”.
Usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths. This data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is consent and our legitimate interests, namely monitoring and improving our website.

4 How will we use your data?
4.1 We collects your data so that we can:
4.2 Process your summer program entry.
4.3 Communicate with you with about updates, early registrations, application processes, supporting materials submissions, admissions process, scholarship process, codes of conduct, awards notifications, orchestral recordings, photos, videos and audio recording agreements, general information about a summer program.
4.4 Share your data with our faculty, guest speakers, instructors and fellow participants.
4.5 Add and publish your email and phone number to the GEMS Composers Directory page on the GEMS website, summer program classroom materials, the GEMS magazine.

5 Where do we store your data?
5.1 GEMS is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our services to you. Your data you provide may be stored through Wix.com data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.
5.2 Your data is then processed at the our data controller’s (owners) operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller using the contact form on the website to request our email.

6 Retention time

6.1 Your data is kept for the time necessary to provide the service requested by you, or stated by the purposes outlined in this document, and you can always request that the Data Controller suspend or remove your data.

7 Marketing
7.1 We would like to send you information about our existing and new programs and services that we think you might like. You have the right at any time to stop GEMS from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please unsubscribe to any email marketing information sent to you or contact us below.

8 What are your data protection rights?
8.1 We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following
8.2 The right to access – You have the right to request us for copies of your personal data. There is no charge for this service.
8.3 The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.
8.4 The right to erasure – You have the right to request that we erase all your or specific personal data, under certain conditions.
8.5 The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
8.6 The right to object to processing – You have the right to object to us processing your personal data, under certain conditions.
8.7 The right to data portability – You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
8.8 If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us using the contact form on the website to request our email address.

9 Privacy policies of other websites
9.1 The GEMS website contains links to other websites such as Youtube, Facebook, Instagram, X, Soundcloud. Our privacy policy applies only to our our website, so if you click on a link to another website, you should read their privacy policy.

10 About PECR and Cookies
10.1 Under the PECR, as from 26 May 2011, businesses must seek consent before any cookie is set on an individual’s computer.

11 About Cookies
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of websites. They are used by companies to help users navigate websites efficiently and perform certain functions. Cookies are also used to keep computer users logged in and their personal details private or for tracking their activity so that companies can improve the website.
11.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3 Session cookies enable the website to track user movement from page to page so that the user does not get asked for the same information again. Session cookies are never written on the hard drive and they do not collect any information from the user's computer. Session cookies expire at the end of the user's browser session.
11.4 Persistent cookies are stored on the user's computer and are not deleted when the browser is closed. Such cookies can retain user identities and preferences, allowing those preferences to be used in future browsing sessions.

12 How to manage cookies
12.1 You can set your browser not to accept cookies. Please be aware that blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will still be able to use all the features on our website.
12.2 Different browsers provide different methods to block and delete cookies used by websites. Methods for doing so vary from browser to browser. To find out more out more on how to manage and delete cookies, visit here www.allaboutcookies.org.

13 Can I control cookie preferences?
13.1 Should you decide to change your preferences later through your browsing session on our website, you can modify your cookie preferences by going to your browser settings, find the cookies and site permissions-related tab. From this tab, you can enable or disable cookies for your entire browser or the GEMS website. Return to the GEMS website which will display the consent notice again enabling you to change your preferences.

14 Cookies used by our service provider
14.1 Our service providers WIX.com use cookies and those cookies may be stored on your computer when you visit our website.
14.2 We use WIX.com to analyse the use of our website. WIX.com gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. WIX.com privacy policy is available at: https://www.wix.com/about/privacy and https://www.wix.com/about/cookie-policy

15 Cookie Policy
15.1 We are hosted on the Wix.com platform. Wix.com uses cookies that are included in our website to improve your browsing experience. By clicking “Accept All Cookies”, you agree to the Cookie policy. By clicking “Settings”, you can select which cookies in the Cookie policy you accept.

16 Changes to our privacy policy
16.1 We keep our privacy policy under regular review and places any updates on this web page.
16.2 We may update our privacy policy by publishing a new version on our website.
16.3 You should check this page occasionally to ensure you are happy with any
changes to our privacy policy.
16.4 We may notify you of changes to our privacy policy by email.
16.5 This privacy policy was last updated in 2024.

17 How to contact us
17.1If you have any questions about our privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us using the contact form on the website to request our email address.