Privacy Policy

1. When This Policy Applies

This Policy applies to personal data we collect through the Site, including through contact forms, partnership inquiry forms, donation processing, network directory features, scholarship-related interactions, event registrations, and any other digital interaction managed by Gwags.

This Policy does not apply to any third-party applications, integrations, or websites that may link to, or be accessible from, the Site. We are not responsible for the content, features, functionality, or privacy practices of any linked third-party site. The data collection and use practices of any linked third-party site will be governed by that third party's own privacy notice and terms of use. We encourage you to read them.

2. Data We Collect About You

(a) Data You Provide Directly: We collect personal data when you voluntarily provide it to us. This may include:

• your name, email address, phone number, country of residence, and organizational affiliation when you submit a contact form, partnership inquiry, or other communication through the Site;
• your name, email address, payment method details, and donation amount when you make a donation through the Site;
• any personal data contained in proposals, messages, feedback, documents, or other materials you submit through our forms or portals;
• your name, academic information, and any other data you provide when applying to Gwags programs, including the Gwags Scholars Program; and
• any other personal data you choose to provide in the course of interacting with the Site.

It is always your choice whether to provide personal data. However, some personal data is required to enable certain features of the Site or to participate in certain programs. The decision not to provide such data may limit your ability to use those features or participate in those programs.

(b) Data You Provide About Others: Do not provide personal data about others unless you are authorized or required to do so by applicable law or contract. If you provide personal data about another person, you represent that you have provided them with a copy of this Policy and obtained their consent where required.

(c) Data We Collect Automatically: When you visit the Site, we may automatically collect certain technical data, including:

• your Internet Protocol ("IP") address, internet service provider ("ISP") information, browser type and language, and device type;
• data about your interaction with the Site, including referring webpage, pages visited, time spent on pages, and navigation paths; and
• data collected through cookies, pixels, and similar technologies as described in Section 5.

We may link automatically collected data with data you provide in other contexts on the Site to personalize and improve your experience.

(d) Data We Obtain From Third Parties: We may obtain personal data about you from other sources, including publicly available sources, service providers, and third parties acting on your behalf or on apparent authority. For example, we may receive your personal data if another person designates you as a contact person for their organization, or if a service provider shares data with us in the course of providing services related to the Site.

3. How We Use Your Data

We may use your personal data to:

• respond to your inquiries, messages, and communications submitted through the Site;
• process, acknowledge, and issue receipts for donations;
• review and respond to partnership inquiries, proposals, and other submissions;
• administer Gwags programs, including the Gwags Scholars Program, and evaluate applications;
• manage the Network Directory and process network affiliation requests;
• send you transactional communications, including donation confirmations, account notifications, and correspondence related to your submissions;
• send you institutional communications, including newsletters, program updates, and other information you have consented to receive;
• administer, maintain, and improve the Site, including analyzing usage patterns and troubleshooting issues;
• protect the rights, safety, and security of Gwags, its users, and the public;
• maintain institutional records and archives; and
• comply with applicable laws, regulations, court orders, or legal processes.

4. Legal Bases for Processing

We collect and use your personal data only where we have a lawful basis for doing so under applicable law. The legal basis depends on the nature of your interaction with us and may include:

• your consent (for example, when you subscribe to communications or submit a form);
• the performance of a contract or steps taken at your request prior to entering a contract;
• compliance with a legal obligation to which Gwags is subject;
• our legitimate interests or those of a third party, provided your fundamental rights and freedoms do not override those interests (for example, administering our programs, improving the Site, or protecting our operations); and
• the protection of your vital interests or those of another person.

Where the legal basis is consent, we will notify you clearly. You may withdraw your consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal.

5. Cookies and Similar Technologies

(a) What Are Cookies: Cookies are small text files stored on your device when you access a website. We use cookies and similar technologies (including pixels and web beacons) to collect data about your interaction with the Site.

(b) How We Use Cookies: We may use cookies to:

• enable essential Site functionality, such as session management and security;
• remember your preferences and settings;
• understand how visitors use the Site, including which pages are visited most frequently;
• analyze Site performance and identify areas for improvement; and
• support analytics services as described in Section 5(d).

(c) Managing Cookies: You do not need to have cookies enabled to browse the Site, but certain features may not function properly without them. Most browsers allow you to manage or block cookies through browser settings. Please note that disabling cookies may affect your experience on the Site. More information about managing cookies is available at www.aboutcookies.org.

(d) Third-Party Analytics: We may use third-party analytics services, including Google Analytics, to collect and analyze information about use of the Site. These services use cookies and similar technologies to collect data about Site usage and report trends without identifying individuals to us. You can learn about Google's practices at https://policies.google.com/technologies/partner-sites and opt out of Google Analytics data collection at https://tools.google.com/dlpage/gaoptout.

6. Payment Processing

Donations made through the Site are processed by Stripe, Inc. ("Stripe"), a third-party payment processor. When you make a donation, Stripe collects and processes your payment information (including card details) directly. Gwags does not receive, access, or store your full payment card information.

If you establish a recurring donation, Stripe retains your payment information as necessary to process future charges until you cancel. Cancellation of a recurring donation through Gwags does not automatically result in the deletion of your payment data by Stripe. Please refer to Stripe's privacy policy for information about how to request deletion of your payment data directly from Stripe.

Stripe's collection and use of your payment data is governed by Stripe's own privacy policy and terms of service. We encourage you to review them. Gwags receives only the information necessary to confirm and acknowledge your donation, such as your name, email address, donation amount, and transaction confirmation.

7. When We Share Your Data

(a) Service Providers: We may share your personal data with service providers who assist us in operating the Site and fulfilling our institutional functions, including payment processing (Stripe), email services, hosting providers, and analytics providers. Our service providers are authorized to use your personal data only as necessary to provide services to Gwags, solely for the purposes for which it was shared with them, and are contractually required to protect your data in accordance with applicable law.

(b) Institutional Personnel: We may share your personal data with Gwags officers, directors, employees, and authorized volunteers who have a legitimate need to access the data in connection with their institutional responsibilities.

(c) Network Organizations and Partners: If you submit information in connection with a network affiliation request or partnership inquiry, we may share relevant data with Gwags leadership and, where applicable, with the organizations involved in the proposed affiliation or partnership, solely for the purpose of evaluating and administering the request.

(d) Legal Requirements: We may disclose your personal data where required to do so by applicable law, court order, subpoena, or legal process, or where we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, investigate fraud, or respond to a government request.

(e) No Sale of Data: Gwags does not sell, rent, lease, or trade your personal data to any third party for marketing or commercial purposes.

8. International Data Transfers

Gwags operates in both the United States and the Republic of Cameroon. Your personal data may be transferred to, stored, and processed in the United States, Cameroon, or any other country where Gwags or its service providers maintain facilities.

Data protection in the United States is governed by applicable federal and state laws. Data protection in Cameroon is governed by Law No. 2010/012 of 21 December 2010 on cybersecurity and electronic commerce, and related regulations. Gwags complies with applicable data protection requirements in both jurisdictions.

If you access the Site from outside these jurisdictions, you consent to the transfer, storage, and processing of your data in jurisdictions that may have different data protection standards than your jurisdiction of residence. Where required by applicable law, we will ensure that appropriate safeguards are in place to protect your personal data in connection with any such transfer, including the use of standard contractual clauses or other legally recognized mechanisms.

9. Data Storage and Retention

(a) Retention Period: We retain your personal data only for as long as reasonably necessary to fulfill the purposes for which it was collected, as described in this Policy, or as otherwise required or permitted by applicable law. Specific retention periods vary by data category and are determined based on the nature of the data, the sensitivity of the information, the purposes of processing, and applicable legal requirements.

(b) Donation Records: Records relating to donations, including donor identity, donation amount, date, and designation, are retained for as long as required by applicable tax, financial reporting, and nonprofit governance laws in the jurisdictions in which Gwags is incorporated.

(c) Submissions: Data provided through contact forms, partnership inquiries, and other submissions is retained for as long as necessary to respond to and administer your inquiry, and thereafter as needed for institutional record-keeping or as required by law.

(d) Deletion: After the applicable retention period, we will delete or anonymize your personal data. If deletion is not immediately possible (for example, because data is stored in backup archives), we will securely isolate it from further processing until deletion is feasible.

10. Data Security

We maintain appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, destruction, or loss. These measures include access controls, encryption where appropriate, and regular security assessments.

We limit access to personal data to authorized personnel who require it in connection with their institutional responsibilities and who are bound by confidentiality obligations.

We require our service providers to maintain data privacy and security standards at least equivalent to our own.

However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee its absolute security. Any transmission of data to the Site is at your own risk.

11. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, Gwags will notify affected individuals and relevant data protection authorities in accordance with applicable law and within the timeframes required by such law. Notification will include, to the extent known at the time, the nature of the breach, the categories of data affected, the likely consequences, and the measures taken or proposed to address the breach and mitigate its effects.

12. Minors

The Site is not directed at individuals under the age of 13 (or the equivalent minimum age in your jurisdiction). In compliance with the Children's Online Privacy Protection Act (COPPA) and equivalent protections under applicable law, Gwags does not knowingly collect personal data from minors through the Site.

Certain Gwags programs, including the Gwags Scholars Program, may involve individuals under 18. In such cases, the collection and processing of personal data from individuals under 18 will be conducted with the consent of a parent or legal guardian, as described in our Terms of Use.

If you become aware that personal data has been collected from a minor without appropriate consent, please contact us at contact@gwags.org. We will take reasonable steps to delete such data promptly.

13. Your Rights

Depending on your jurisdiction and applicable law, you may have the right to:

• obtain confirmation of whether we hold personal data about you;
• access your personal data and receive a copy of it;
• correct or update inaccurate or incomplete personal data;
• request deletion of your personal data, subject to legal retention requirements;
• withdraw any consent you have previously provided;
• object to or restrict certain processing of your personal data;
• request portability of your personal data (i.e., receive it in a structured, commonly used, machine-readable format); and
• lodge a complaint with the applicable data protection authority in your jurisdiction.

To exercise any of these rights, please contact our designated Data Privacy Contact at contact@gwags.org. We will acknowledge your request within five (5) business days and provide a substantive response within thirty (30) days, or inform you if an extension is necessary. We may ask you to verify your identity before processing your request.

Please note that certain rights may be limited where we have an overriding legitimate interest, a legal obligation to retain data, or where exemptions apply under applicable law.

14. Sensitive Personal Data

We will not intentionally collect sensitive personal data (such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data concerning sex life or sexual orientation) without your explicit consent for one or more specified purposes, unless otherwise permitted or required by applicable law.

15. Email Communications and Opt-Out

(a) Transactional Communications: When you make a donation, submit a form, or interact with certain features of the Site, we may send you transactional communications, including donation receipts, confirmations, and correspondence directly related to your interaction. These communications are necessary for the administration of your request and cannot be opted out of.

(b) Institutional Communications: With your consent, we may send you newsletters, program updates, and other institutional communications. You may opt out of these communications at any time by following the unsubscribe instructions included in such communications or by contacting us at contact@gwags.org.

(c) Administrative Communications: We reserve the right to send you administrative communications relating to the Site, your Account, or changes to our policies, as permitted by applicable law. These communications are not promotional in nature and cannot be opted out of.

16. Do-Not-Track Signals

The Site does not currently respond to Do Not Track signals, as there is no universally accepted standard for such responses. However, you may manage your cookie preferences as described in Section 5(c) and opt out of third-party analytics as described in Section 5(d). As industry standards develop, we will revisit this practice and update this Policy if our approach changes.

17. Multilingual Content

This Policy is available in English and French. Translations are provided for the convenience of users. In the event of any inconsistency between the English and French versions of this Policy, the English version shall prevail and be treated as authoritative.

18. Changes to This Policy

Gwags reserves the right to modify, amend, or replace this Policy at any time. Changes will be effective upon posting to the Site with an updated "Last updated" date. If we make a material change, we will post a prominent notice on the Site. Your continued use of the Site after any such changes constitutes your acceptance of the revised Policy.

19. Contact

For questions, concerns, or requests relating to this Policy or your personal data, please contact our designated Data Privacy Contact:

Gwags Global Impact Institution

Email: contact@gwags.org

For donation-related privacy inquiries: donate@gwags.org