The Jerusalem Music Centre (“JMC”, “we”, “our”, “us”) is a non for-profit lending platform for combining Israel engagement and social impact investing, jointly owned by The Jewish Agency for Israel and Ogen (formerly the Israel Free Loan Association).

The Jerusalem Music Centre manages programs for young musicians, organizes concerts and events, and collects and processes personal information from students, participants, donors, and attendees as part of its educational, artistic, and administrative activities (all together the “Services”).

We respect your privacy and are committed to protect the personal information that you share with us. We are transparent about our practices regarding the information we may collect and use when you use the Services, visit our websites or otherwise engage with us, and describe our practices in this privacy policy.

Individuals making use of these Services are entitled to protection of their data as described in this privacy and data protection policy and notice (the “Privacy Policy”). This Privacy Policy also describes JMC’s practices for collecting, using, maintaining and processing information. It also provides notice to you as may be required by the Israel’s Protection of Privacy Law 5741-1981, the EU’s General Data Protection Regulations (“GDPR”) UK and Swiss data protection law, US state privacy laws (where applicable), or any other privacy or data protection law applicable to JMC and your use of its Services (“Data Protection Law”).

Please read the following carefully to understand our practices regarding your Personal Data and how we will treat it.

For the purposes of Data Protection Law, JMC will generally be regarded as a data controller with regards to the personal data it processes.

1. WHICH INFORMATION MAY WE COLLECT AND HOW DO WE COLLECT IT?

Summary: we collect various categories of personal data in order to meet our contractual obligations, and also to meet various legitimate interests, such as marketing.

Data we collect about you prior to, and from, your use of the Services.

To operate our services, manage our programs and events, and maintain our relationships with students, parents, visitors, artists, donors, employees, and service providers, we collect and process personal information from the following sources:

Information you provide directly. When registering for and participating in programs or activities, purchasing tickets, attending concerts, submitting inquiries, or making donations. This includes identification and contact details, ID/passport number, payment information, preferences, participation records, and correspondence.

Information about students, participants, and artists. Details provided in connection with educational or artistic programs, such as date of birth, contact information, musical background, CVs, recordings, recommendations, administrative data (attendance, evaluations, scholarships, payments), and photos or recordings of activities.

Information about employees, candidates, and suppliers. Data collected during recruitment and employment (CVs, certificates, references, interview notes, role, salary, bank details, contracts), as well as supplier and service-provider contact and payment information.

Information collected automatically online: IP address, device and browser data, usage logs, and information collected through cookies and similar technologies for site functionality, security, analytics, and marketing.

Security camera footage: CCTV recordings from our premises for safety and security purposes.

Information from external partners: Data received from partner organizations, supporting foundations, educational and cultural institutions, government bodies, or publicly available sources, where needed for collaboration or to support our mission.

1. WHAT ARE THE PURPOSES OF OROCESSING OF PERSONAL DATA WE COLLECT?

Summary: we process Personal Data to meet our obligations, protect our rights, and manage our organization.

We will use Personal Data to provide and improve the Services and meet our contractual, ethical and legal obligations, including for example:

Processing Necessary for the Performance of a Contract. 

We process personal information when it is required to provide our services, fulfill your requests, or enter into an agreement with you. This includes:

• Managing and delivering educational and artistic programs (registration, participation, evaluations, scholarships, communications).
• Organizing and operating concerts and events (ticketing, attendance, seating, event communications).
• Processing payments, donations, and issuing confirmations or receipts.
• Managing relationships with suppliers, partners, and service providers.
• Recruitment and employment-related processing for candidates and staff.

Processing Based on Our Legitimate Interests. 

We process personal information where it is necessary for the operation, development, and protection of the JMC and its activities, and where these interests do not override your rights. This includes:

• Maintaining ongoing relationships with students, parents, artists, donors, partners, and visitors.
• Administering day-to-day operations and improving the efficiency of our internal processes.
• Improving and securing our website and digital services, including analytics, troubleshooting, and preventing misuse.
• Documenting artistic activities, including photos and recordings, for program administration and institutional documentation.
• Operating security measures, including CCTV, to protect visitors, staff, artists, and JMC property.
• Supporting collaborations and joint programs with arts, cultural, and educational institutions.

Processing Required to Comply with Legal Obligations. 

We process personal information when required to meet our obligations under applicable laws, regulations, and public-authority requirements, including:

• Record-keeping, accounting, tax, and audit requirements.
• Employment, payroll, and social-benefit obligations.
• Responding to lawful requests from authorities or regulators.
• Health, safety, and security requirements, including maintaining CCTV footage where mandated or justified.
• Requirements associated with public funding, grants, or reporting to government bodies.

Personal Data which you provide us may be combined with personal data which may be provided by other sources, all of which will be used for the purposes set out above. We aggregate and de-identify Personal Data (i.e., use your data in a way which no longer allows to identify you) to analyze and improve our Services, and to conduct research, and for other similar purposes. We may share non-personal aggregated information with third parties, as described below. 

1. SHARING DATA WITH THIRD PARTIES

Summary: we share Personal Data with our service providers and partners, and authorities where required.

We may transfer Personal Data to:

• Service providers, including IT and hosting providers, payment processors, ticketing systems, marketing and communication platforms, security and maintenance contractors, who process data on our behalf under confidentiality obligations.
• Event-related partners such as venues, production teams, and ticketing platforms.
• Educational, cultural, and artistic partners involved in programs, masterclasses, scholarships, and joint events.
• Funding bodies and government agencies when required for grants, reporting, or regulatory compliance.
• Legal and regulatory authorities where required by law, court order, or safety considerations.
• With your consent, where applicable.

For avoidance of doubt, JMC may transfer and disclose non-personal data to third parties at its own discretion. 

1. WHERE DO WE STORE YOUR DATA?

Summary: we store your Personal Data across multiple locations globally.

We store your Personal Data in databases owned or controlled by us, or processed by third parties on our behalf, by reputable cloud-service providers (see the following section regarding international transfers).

1. INTERNATIONAL DATA TRANSFERS

Summary: we transfer Personal Data within and to the EEA, USA, Israel and elsewhere, with appropriate safeguards in place.

Personal Data may be transferred to, and stored and used at, a destination outside your location that may not be subject to equivalent Data protection laws to those of their origin. Where your Data is transferred outside of the EEA or Israel, we will take all steps reasonably necessary to ensure that your Data is subject to appropriate safeguards, and that it is treated securely and in accordance with this Privacy Policy. 

We may transfer your personal data outside your location, in order to:

• Store or backup the information;
• Enable us to provide you with the Services and fulfil our contract with you;
• Fulfil any legal, audit or compliance obligations which require us to make that transfer;
• Facilitate the operation of our organization, where it is in our legitimate interests and we have concluded these are not overridden by your rights;
• To offer our Services across multiple jurisdictions; and
• To operate our organization and affiliates in an efficient and optimal manner.

1. DATA RETENTION

Summary: we retain Personal Data according to our data retention policy, as required to meet our obligations, protect our rights, and manage our business.

JMC will retain data it processes only for as long as required to provide the Services and as necessary to comply with its legal obligations, resolve disputes and enforce its agreements. Data will be kept in accordance with applicable best business practices and legal obligations. Some metadata and statistical information concerning the use of the Services are not subject to the deletion procedures in this policy and may be retained by JMC. We will not be able to identify you from this data. Some data may also be retained on our third-party service providers’ servers until deleted in accordance with their privacy policy and their retention policy.

1. WEBSITE DATA COLLECTION AND COOKIES

Summary: with your consent, we place cookies on your device. You control our use of cookies through a cookie management tool on our website, or through your device and browser.

When you access or use our Services, we may use industry standard technologies such as Cookies, pixels and similar technologies, which store certain information on your computer or browsing device and which will allow us to identify the computer or device with the user, and to enable automatic activation of certain features, and make your Service experience much more convenient and effortless. We use different types of Cookies: some cookies are strictly necessary, they are required for the operation of our Site and under our terms with you; this includes for example, cookies that enable you to log into secure areas of our Service. We also use analytical and performance monitoring cookies, which allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. Finally, we use functionality cookies which are used to recognise you when you return to our Site. This enables us, subject to personalise content to your preferences, including for example, your choice of language or region.

Different cookies are kept for different periods. Session cookies are used to keep track of your activities online in a given browsing session; these cookies generally expire when the browser is closed but may be retained for a period on your device. Permanent cookies remain in operation even when you have closed the browser; they are used to remember your login details and password. Third-party cookies are installed by third parties with the aim of collecting certain information to research behaviour, demographics. Third party cookies on our site include, for example, Google Analytics. Likewise, pixels from Facebook and others enable integration of third party service providers (eg Facebook (Meta), Instagram, TikTok) on our site. Third party cookies will be retained according to the terms of those third parties, and you can control those cookies in your browser settings. 

We use Cookies and other technologies on the basis that it is in our legitimate interests and these are not overridden by your rights.

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience on our website will be limited.

How to disable cookies: The effect of disabling cookies depends on which cookies you disable but, in general, the website and some services delivered through it may not operate properly, may not recognize your device, may not remember your preferences and so on, if cookies are disabled or removed. However, allowing or disabling cookies is your choice and in your control. If you want to disable cookies on our site, you need to change your browser settings to reject cookies. How you can do this will depend on the browser you use. 

Our website may, from time to time, contain links to external sites. We are not responsible for the operation, privacy policies or the content of such sites.

1. SECURITY AND STORAGE OF INFORMATION

Summary: We apply strong security measures, limit access to trained staff, and will promptly act and notify if a data breach occurs, while noting that no system is completely secure.

We take great care in implementing, enforcing and maintaining the security of the personal data we process. JMC endeavors to implement, enforce and maintain security measures, technologies and policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of Personal Data. We likewise take steps to monitor compliance of such policies on an ongoing basis. Where we deem it necessary in light of the nature of the data in question and the risks to data subjects, we may encrypt data. Likewise, we take industry standard steps to ensure our website is safe.

Note however, that no data security measures are perfect or impenetrable, and we cannot guarantee that unauthorized access, leaks, viruses and other data security breaches will never occur.

Within JMC, we endeavor to limit access to Personal Data to those of our personnel who: (i) require access in order for JMC to fulfil its obligations under this Privacy Policy and its agreements and (ii) have been appropriately and periodically trained on the requirements applicable to the processing, care and handling of the Personal Data (iii) are under confidentiality obligations as required under applicable law. We take steps to ensure that its staff who have access to Personal Data are honest, reliable, competent and trained.

JMC shall act in accordance with its policies to promptly notify the relevant authorities and data subjects in the event that any Personal Data processed by JMC is lost, stolen, or where there has been any unauthorized access to it, all in accordance with applicable law and on the instructions of qualified authority. We shall promptly take reasonable remedial measures.

1. DATA SUBJECT RIGHTS

Summary: depending on the law that applies to your Personal Data, you may have various data subject rights, such as rights to access, and correct Personal Data, and information rights. We will respect any lawful request to exercise those rights.

Data subjects, have rights under Data Protection Law, including, in different circumstances, rights to: access data, rectify data, etc. It is clarified for the removal of doubt, that data subject rights cannot be exercised in a manner inconsistent with the rights of JMC’s employees, with our proprietary rights, and third party rights. As such, job references, reviews, internal notes and assessments, documents and notes including proprietary information or forms of intellectual property, cannot be accessed or erased or rectified. In addition, these rights may not be exercisable where they relate to data that is not in a structured form, for example emails, or where other exemptions apply. If processing occurs based on consent, data subjects have a right to withdraw their consent. 

If, for any reason, a data subject wishes to exercise these rights and modify, delete or retrieve their Personal Data, they may be able to do so by contacting JMC [info@jmc.org.il]. Note that we may have to undertake a process to identify a data subject exercising their rights. JMC may keep details of such rights exercised for its own compliance and audit requirements. Please note that Personal Data may be either deleted or retained in an aggregated manner without being linked to any identifiers or Personal Data, depending on technical commercial capability. Such information may continue to be used by JMC.

1. GENERAL

JMC aims to process only adequate, accurate and relevant data limited to the needs and purposes for which it is gathered. It also aims to store data for the time period necessary to fulfil the purpose for which the data is gathered. We only collect data in connection with a specific legitimate purpose and only processes data in accordance with this Privacy Policy.

In the event of any concerns about data protection practices at JMC, you may contact our team at info@jmc.org.il. EU persons have the right to lodge a complaint with a supervisory authority.

1. CHANGES TO THIS PRIVACY POLICY

The terms of this Privacy Policy will govern the use of the services, website and any information collected in connection with them. JMC may amend or update this Privacy Policy from time to time. The most current version of this Privacy Policy will be available at: www.jmc.org.il. Changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of Services will constitute your recognition and acceptance of the Privacy Policy’s governing your personal data at JMC.

If you have any reasonable questions or comments concerning this Privacy Policy, you are welcome to send us an email or otherwise contact us at privacy@jmc.org.il and if we can help, we will make an effort to reply within a reasonable timeframe.

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Last Revised: November 18, 2025.