Privacy Policy
GAP Leadership Program
Effective Date: November 7, 2026
Last Updated: November 7, 2026
1. INTRODUCTION
GAP Leadership Program ("GAP Leadership," "GAP," "Organization," "we," "us," or "our") is committed to protecting the privacy, confidentiality, and security of personal information entrusted to us by website visitors, program participants, parents, legal guardians, donors, volunteers, community partners, and other individuals who interact with our organization.
GAP Leadership is a nonprofit organization recognized as tax-exempt under Section 501(c)(3) of the Internal Revenue Code. Our mission is to equip youth with the tools, experiences, and support necessary to lead in entrepreneurship, education, and civic life. By bridging the gap between schools, families, and communities, we seek to empower young people to develop their voices, pursue opportunities, and create lasting impact throughout the Mississippi Delta and beyond.
This Privacy Policy ("Policy") describes how GAP Leadership collects, uses, processes, stores, discloses, retains, and safeguards personal information in connection with its website, educational initiatives, charitable activities, communications, and related services (collectively, the "Services").
This Policy also explains the rights and choices individuals may have regarding their personal information.
By accessing or using our Services, you acknowledge that this Privacy Policy has been made available to you. Where applicable law requires consent for particular processing activities, GAP Leadership will seek that consent separately.
2. SCOPE AND APPLICABILITY
This Privacy Policy applies to personal information collected through:
1. GAP Leadership's official website, hosted through ClickFunnels 2.0;
2. Online contact forms, inquiries, and email subscriptions;
3. Program applications, enrollment forms, and registration systems;
4. Charitable donations processed through Zeffy;
5. Volunteer applications and community partnership inquiries;
6. Event registrations, surveys, and organizational communications;
7. Educational enrichment, mentorship, entrepreneurship, and leadership development activities;
8. Website analytics and advertising measurement technologies, including Google Analytics and Meta Pixel;
9. Authorized digital platforms and third-party services supporting organizational operations; and
10. Other interactions in which GAP Leadership provides or references this Policy.
This Policy applies to information collected electronically and, where relevant, information collected through offline activities that is subsequently maintained in GAP Leadership's administrative systems.
Certain programs or activities may be governed by supplemental privacy notices, parental consent forms, participation agreements, or other applicable policies.
Where a supplemental notice establishes more specific privacy protections, those protections shall apply to the relevant activity.
3. INFORMATION WE COLLECT
GAP Leadership collects personal information directly from individuals, automatically through website technologies, and, where authorized, from third parties.
The categories of information collected depend on the nature of an individual's interaction with the Organization.
3.1 Personal Identification and Contact Information
We may collect:
- Full name;
- Email address;
- Telephone number;
- Mailing address;
- City, state, and ZIP code;
- Organizational affiliation;
- Preferred method of communication; and
- Other information voluntarily provided through contact forms or correspondence.
3.2 Program Application and Participant Information
When individuals apply for or participate in GAP Leadership programs, we collect information reasonably necessary to evaluate eligibility, administer services, communicate with families, and support participant safety.
This information may include:
- Participant's full name;
- Date of birth and age;
- School name and grade level;
- Parent or legal guardian information;
- Emergency contact information;
- Educational interests and goals;
- Program participation and attendance records;
- Relevant academic or developmental information;
- Health, accessibility, or accommodation information when necessary and appropriately authorized;
- Parental consent and release documentation; and
- Other information necessary for program administration.
Certain information collected through program applications may be considered sensitive personal information under applicable law.
GAP Leadership seeks to limit the collection of such information to what is reasonably necessary for legitimate educational, administrative, safety, and organizational purposes.
3.3 Donation and Financial Transaction Information
GAP Leadership utilizes Zeffy, a third-party fundraising and donation management platform, to facilitate online charitable contributions.
When an individual makes a donation, information collected or processed may include:
- Donor name;
- Email address;
- Contact and billing information;
- Donation amount;
- Transaction date;
- Donation designation;
- Recurring contribution preferences;
- Transaction identifiers; and
- Information necessary for acknowledgments and financial recordkeeping.
Payment transactions are processed through Zeffy and its applicable payment processing partners.
Financial information submitted through Zeffy's payment interface is subject to Zeffy's privacy and security practices.
GAP Leadership may receive donation and transaction records necessary for charitable administration, accounting, donor communications, and compliance purposes.
Donors are encouraged to review Zeffy's Privacy Policy at https://www.zeffy.com.
3.4 Email Subscription and Communication Information
GAP Leadership utilizes ClickFunnels 2.0 to manage website forms, email subscriptions, and organizational email communications.
When individuals subscribe to our mailing list or submit information through our website, we may collect:
- Name;
- Email address;
- Subscription date;
- Form submission information;
- Communication preferences; and
- Email engagement information, including delivery, opens, or link interactions where supported and enabled.
This information may be used to distribute newsletters, program announcements, event information, organizational updates, and fundraising communications.
Individuals may unsubscribe from promotional communications using the unsubscribe mechanism provided in applicable emails.
3.5 Volunteer and Partnership Information
Individuals interested in volunteering, mentoring, sponsoring, or partnering with GAP Leadership may be asked to provide:
- Contact information;
- Professional or organizational affiliation;
- Relevant experience and qualifications;
- Areas of interest;
- Availability;
- References, where appropriate; and
- Other information necessary to evaluate or coordinate the requested opportunity.
Certain volunteer or mentorship positions may require additional screening procedures, subject to applicable law and separate authorization requirements.
3.6 Automatically Collected Website Information
GAP Leadership's website is hosted through ClickFunnels 2.0 and utilizes Google Analytics, Meta Pixel, and potentially other website measurement technologies.
These systems may automatically collect:
- Internet Protocol (IP) address;
- Browser type and version;
- Device type and operating system;
- Referring website or traffic source;
- Pages visited;
- Date and time of access;
- Approximate geographic location;
- Website navigation and interaction data;
- Device and browser identifiers;
- Cookie identifiers; and
- Information concerning website events or conversions.
The information collected depends on the configuration of the relevant platform and tracking technologies.
4. HOW WE USE PERSONAL INFORMATION
GAP Leadership may use personal information for legitimate charitable, educational, administrative, operational, and legal purposes, including to:
1. Respond to inquiries and requests for information;
2. Process program applications and registrations;
3. Administer educational, mentorship, entrepreneurship, and leadership development initiatives;
4. Communicate with participants, parents, and legal guardians;
5. Coordinate volunteer and community partnership opportunities;
6. Process charitable contributions through Zeffy;
7. Issue donation acknowledgments and maintain financial records;
8. Organize events, workshops, and community activities;
9. Deliver newsletters and organizational updates through ClickFunnels;
10. Evaluate program effectiveness and organizational impact;
11. Analyze website traffic, visitor engagement, and campaign performance;
12. Improve website functionality, accessibility, and user experience;
13. Maintain administrative and financial records;
14. Protect the safety and welfare of program participants;
15. Detect, prevent, and investigate fraud, misuse, or security incidents;
16. Comply with applicable laws, regulations, and reporting obligations; and
17. Advance GAP Leadership's charitable mission through lawful organizational activities.
We will not use personal information for materially unrelated purposes without providing any notice or obtaining any consent required by applicable law.
5. CHILDREN'S PRIVACY AND PROTECTION OF MINORS
Protecting the personal information of children and young people is a priority for GAP Leadership.
Because our programs serve youth, additional privacy safeguards may apply when collecting, using, storing, or disclosing information concerning minors.
5.1 Children Under Thirteen
GAP Leadership intends to comply with the Children's Online Privacy Protection Act ("COPPA") and its implementing regulations to the extent applicable to its online Services.
Where COPPA applies, GAP Leadership will provide required notices and obtain verifiable parental consent before collecting, using, or disclosing personal information from children under thirteen (13), unless a recognized legal exception applies.
Children under thirteen should not independently submit personal information through our website unless an applicable consent process or lawful exception permits the collection.
If GAP Leadership becomes aware that personal information has been collected from a child in violation of applicable requirements, it will take appropriate corrective action, which may include deletion of the information.
5.2 Parental and Guardian Involvement
Parents and legal guardians may be required to provide consent before a minor participates in GAP Leadership programs or submits particular categories of personal information.
Where applicable law provides parental rights to review, correct, restrict, or request deletion of a child's information, GAP Leadership will provide a reasonable method for exercising those rights.
Requests may be subject to appropriate identity and parental authority verification.
5.3 Educational and Sensitive Information
GAP Leadership collects educational and other sensitive participant information through program applications when reasonably necessary to provide authorized services.
This may include dates of birth, school information, emergency contacts, educational records, and relevant health or accommodation information.
Such information will be handled in accordance with applicable law, contractual obligations, and relevant confidentiality requirements.
Where GAP Leadership receives education records from a school or educational institution, the use and disclosure of those records may be subject to the Family Educational Rights and Privacy Act ("FERPA"), where applicable, and the terms of the governing agreement.
GAP Leadership does not represent that all information it maintains is automatically subject to FERPA.
5.4 Photographs, Videos, and Media Involving Minors
GAP Leadership documents certain programs, activities, and community initiatives through photographs, videos, testimonials, and other media.
GAP Leadership obtains parental or legal guardian permission before publishing identifiable photographs of minor participants.
Media authorization is obtained through the Organization's applicable consent and release procedures.
Participation in a GAP Leadership program does not automatically constitute unrestricted permission to use a participant's name, image, likeness, or testimonial for promotional purposes.
Parents or legal guardians may contact GAP Leadership to request review of an existing media authorization or removal of an identifiable image from platforms under the Organization's control.
Requests will be evaluated in accordance with applicable law, the terms of the authorization, and reasonable operational limitations.
6. WEBSITE HOSTING, COOKIES, AND TRACKING TECHNOLOGIES
GAP Leadership uses ClickFunnels 2.0 to host and operate its website.
The website also utilizes Google Analytics, Meta Pixel, and other technologies that may collect information concerning website activity and visitor interactions.
6.1 ClickFunnels 2.0
ClickFunnels 2.0 supports GAP Leadership's website hosting, online forms, email subscriptions, and organizational communications.
Information submitted through website forms may be stored and processed within ClickFunnels systems.
ClickFunnels may also process technical and usage information necessary to operate, secure, and maintain the website.
Additional information regarding ClickFunnels' privacy practices is available at https://www.clickfunnels.com.
6.2 Google Analytics
GAP Leadership uses Google Analytics to evaluate website traffic, visitor engagement, and website performance.
Google Analytics may collect information such as device identifiers, approximate location, browser characteristics, page visits, and interactions with website content.
The information helps GAP Leadership understand how visitors use its website and identify opportunities to improve accessibility, navigation, and content.
Google's handling of information is subject to its applicable privacy practices, available at https://policies.google.com/privacy.
6.3 Meta Pixel
GAP Leadership uses Meta Pixel to measure website interactions and evaluate the effectiveness of digital outreach and advertising activities.
Depending on its configuration, Meta Pixel may collect or receive information concerning website visits, page interactions, conversion events, and certain device or browser identifiers.
Meta may process this information in accordance with its applicable privacy practices.
Additional information is available at https://www.facebook.com/privacy/policy/.
6.4 Cookie Categories
Technologies used on our website may include:
Essential Cookies: Necessary for website operation, security, form functionality, and session management.
Analytics Cookies: Used to understand website traffic, engagement, and performance.
Preference Cookies: Used to remember certain visitor settings or selections.
Advertising and Measurement Technologies: Used to evaluate outreach campaigns, measure conversions, and support relevant advertising activities.
6.5 Managing Tracking Preferences
Visitors may manage certain cookies through their browser settings and any privacy or consent controls made available on the website.
Google and Meta may also provide settings or tools for managing certain advertising and data collection preferences.
Disabling certain technologies may affect website functionality or limit the accuracy of website analytics.
Where applicable law requires consent or an opt-out mechanism for nonessential tracking technologies, GAP Leadership will implement the relevant requirements.
GAP Leadership's use of analytics and advertising technologies does not authorize the intentional transmission of sensitive youth application information to advertising platforms. Tracking configurations should be maintained to prevent such disclosures.
7. DISCLOSURE AND SHARING OF INFORMATION
GAP Leadership may disclose personal information to authorized third parties when reasonably necessary to provide Services, fulfill its charitable mission, or comply with applicable law.
7.1 Website and Email Service Providers
GAP Leadership shares or makes information available to ClickFunnels 2.0 as necessary to operate its website, process form submissions, manage email subscriptions, and deliver organizational communications.
7.2 Donation Processing Providers
GAP Leadership utilizes Zeffy to facilitate charitable contributions and maintain associated donation records.
Donation information may be processed by Zeffy and its authorized payment processing partners in accordance with applicable agreements and privacy practices.
7.3 Analytics and Advertising Providers
Website activity information may be collected or disclosed through Google Analytics, Meta Pixel, and other enabled measurement technologies.
These providers may process information for analytics, measurement, security, and other purposes described in their respective policies.
7.4 Educational and Community Partners
Where appropriate and legally permitted, information may be shared with schools, educational institutions, community organizations, mentors, or program partners involved in delivering authorized services.
Disclosures involving minors or protected educational information will be subject to applicable consent, confidentiality, and legal requirements.
7.5 Legal and Regulatory Requirements
We may disclose information when reasonably necessary to:
- Comply with applicable law or valid legal process;
- Respond to lawful governmental requests;
- Fulfill mandatory reporting obligations;
- Protect the safety of participants or other individuals;
- Investigate suspected fraud or unlawful activity; or
- Establish, exercise, or defend legal rights.
7.6 Sale of Personal Information
GAP Leadership does not intend to sell personal information, including children's personal information, to data brokers or other third parties for monetary compensation.
Certain disclosures through advertising and analytics technologies may nevertheless be classified as a "sale," "sharing," or targeted advertising under applicable privacy laws, regardless of whether money is exchanged.
GAP Leadership will evaluate such disclosures and provide any legally required notices, consent mechanisms, or opt-out rights.
8. DONOR PRIVACY
GAP Leadership respects the confidentiality of individuals and organizations that support its charitable mission.
Donor information collected through Zeffy may be used to process contributions, maintain financial records, provide acknowledgments, communicate about organizational activities, and satisfy legal reporting obligations.
GAP Leadership will not publicly identify a donor as a supporter without an appropriate basis for doing so, including any consent required by law.
Donors may request that their contributions remain anonymous in public-facing recognition materials, subject to applicable recordkeeping, tax reporting, and legal disclosure obligations.
Donor information may be disclosed to authorized payment processors, accountants, auditors, regulators, and other parties when reasonably necessary for lawful organizational operations.
Requests concerning donor communications, recognition, or personal information may be submitted to privacy@gapleadership.org.
9. EMAIL COMMUNICATIONS AND MARKETING PREFERENCES
GAP Leadership utilizes ClickFunnels 2.0 to manage its email subscriber database and distribute organizational communications.
Individuals who subscribe to GAP Leadership's mailing list may receive information concerning:
- Educational and leadership programs;
- Community events and initiatives;
- Volunteer and mentorship opportunities;
- Organizational announcements;
- Fundraising campaigns;
- Program updates; and
- Other communications related to GAP Leadership's mission.
GAP Leadership will comply with applicable requirements governing commercial electronic communications, including the Controlling the Assault of Non-Solicited Pornography and Marketing Act ("CAN-SPAM Act"), where applicable.
Promotional emails will include an appropriate method for unsubscribing when required by law.
Individuals may withdraw consent to optional promotional communications at any time.
Withdrawal from promotional communications does not necessarily prevent GAP Leadership from sending essential administrative, transactional, program-related, or legally required notices.
10. DATA SECURITY
GAP Leadership recognizes the importance of protecting personal information against unauthorized access, disclosure, alteration, misuse, loss, and destruction.
The Organization seeks to maintain administrative, technical, and organizational safeguards appropriate to the nature and sensitivity of the information it processes.
Such safeguards may include access restrictions, account authentication, secure service providers, confidentiality procedures, data minimization, and incident response measures.
GAP Leadership relies in part on the security controls maintained by ClickFunnels, Zeffy, and other authorized service providers.
No electronic transmission, website, database, or information storage system can be guaranteed to be completely secure.
Accordingly, GAP Leadership cannot guarantee absolute protection against every potential security threat.
In the event of a security incident involving personal information, GAP Leadership will investigate and take appropriate action consistent with applicable law, including any legally required notification obligations.
11. DATA RETENTION AND DELETION
GAP Leadership generally retains program applications, donor records, participant information, and related organizational records until a deletion or destruction request is received, subject to applicable legal, administrative, and operational requirements.
Individuals, parents, or legal guardians may request deletion of eligible personal information by contacting privacy@gapleadership.org.
Upon receiving a request, GAP Leadership will evaluate the information involved and determine whether deletion is appropriate or legally required.
Certain records may need to be retained notwithstanding a deletion request, including information necessary to:
1. Comply with federal or state recordkeeping obligations;
2. Maintain required financial, accounting, and tax documentation;
3. Fulfill legal or contractual obligations;
4. Protect participant safety;
5. Respond to legal claims, investigations, or proceedings;
6. Preserve records subject to a legal hold; or
7. Satisfy other lawful retention requirements.
Where deletion is appropriate, GAP Leadership will take reasonable steps to delete, destroy, de-identify, or otherwise securely dispose of the relevant information.
Deletion from active organizational systems may not immediately remove information from authorized backups, archives, or third-party systems where continued retention is legally permitted or technically necessary for a limited period.
GAP Leadership will not retain personal information indefinitely where applicable law requires earlier deletion, including any relevant requirements governing children's personal information.
12. INDIVIDUAL PRIVACY RIGHTS AND CHOICES
Depending on applicable law and the nature of the information maintained, individuals may have rights to request access to, correction of, deletion of, or restrictions on the processing of their personal information.
GAP Leadership will evaluate privacy requests in accordance with applicable legal requirements and organizational obligations.
Individuals may contact GAP Leadership to:
1. Request information about personal data maintained by the Organization;
2. Request correction of inaccurate or outdated information;
3. Request deletion of eligible personal information;
4. Withdraw consent where processing is based on consent;
5. Update communication preferences;
6. Request information about certain disclosures; or
7. Raise concerns about the handling of personal information.
Privacy requests should be submitted to privacy@gapleadership.org.
Before fulfilling a request, GAP Leadership may require reasonable verification of identity or legal authority.
Certain requests may be denied or limited where retention or disclosure is required or permitted by law, necessary to protect another individual's rights, or subject to an applicable legal exception.
Nothing in this Policy is intended to diminish rights provided by applicable privacy laws.
13. THIRD-PARTY WEBSITES AND SERVICES
Our website may contain links to websites, applications, social media platforms, donation processors, or other services operated by third parties.
These services may include ClickFunnels, Zeffy, Google, Meta, and other authorized providers.
GAP Leadership does not control the independent privacy practices of these third parties.
When individuals leave our website or interact directly with an external service, their information may be governed by that provider's privacy policy and terms of use.
We encourage Users to review the privacy practices of third-party services before providing personal information.
The inclusion of an external link does not necessarily constitute endorsement of the provider's privacy or security practices.
14. SOCIAL MEDIA AND PUBLIC INTERACTIONS
GAP Leadership may maintain official accounts on social media and other public communication platforms.
Individuals who interact with these accounts should understand that comments, reactions, posts, and other publicly shared content may be visible to other users.
Information submitted directly to a social media platform is also subject to that platform's independent privacy practices.
Users should avoid posting confidential participant information, sensitive personal details, or identifying information about minors in public comment sections.
GAP Leadership may moderate or remove content from its organizational pages when appropriate to protect privacy, safety, or the integrity of its communications, subject to applicable law.
15. INTERNATIONAL WEBSITE VISITORS
GAP Leadership primarily operates in the United States and serves communities throughout the Mississippi Delta and beyond.
Individuals accessing the website from outside the United States should understand that information submitted through the Services may be processed or stored in the United States or other locations where authorized service providers operate.
Such processing may be subject to laws that differ from those of the individual's country of residence.
Where international data protection laws apply to GAP Leadership's activities, the Organization will comply with applicable requirements, including any necessary safeguards for international transfers.
16. ACCESSIBILITY AND PRIVACY INQUIRIES
GAP Leadership seeks to make its website and organizational information accessible to the communities it serves.
Individuals who encounter difficulty accessing this Privacy Policy or submitting a privacy-related request may contact the Organization for reasonable assistance.
Requests for assistance will be handled in a manner consistent with applicable accessibility, privacy, and nondiscrimination requirements.
17. CHANGES TO THIS PRIVACY POLICY
GAP Leadership reserves the right to revise this Privacy Policy periodically to reflect changes in its programs, website technologies, organizational operations, service providers, or applicable legal requirements.
Revised versions will be published on the website with an updated effective date.
Where changes materially affect the handling of personal information, GAP Leadership will provide additional notice or obtain consent when required by law.
The version posted on the website shall govern the Organization's stated privacy practices as of its effective date, subject to applicable legal requirements.
18. GOVERNING LAW
This Privacy Policy shall be interpreted in accordance with applicable federal law and the laws of the State of Mississippi, except where another jurisdiction's mandatory privacy laws govern particular processing activities.
Nothing in this Policy shall be construed to waive, restrict, or eliminate any privacy right or legal remedy that cannot lawfully be waived.
19. CONTACT INFORMATION
Questions, requests, or concerns regarding this Privacy Policy or GAP Leadership's handling of personal information may be directed to:
GAP Leadership Program
1001 West Delta Avenue
Morehead, Mississippi 38761
United States
Privacy Email: privacy@gapleadership.org
Please include sufficient information to identify the nature of your request.
For security purposes, do not include Social Security numbers, complete payment card details, medical records, or other highly sensitive information in an initial email inquiry.
GAP Leadership may request additional information through an appropriate channel when necessary to verify identity or process a request.
© 2026 GAP Leadership Program. All Rights Reserved.
Bridging the Gap. Building the Future.
