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Website Privacy

PRIVACY NOTICE

Last updated October 25, 2023

This privacy notice for Pathways Technologies Limited (doing business as Pathways Technologies) (“Company,” “we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you:

  • Visit our website at www.pathwaystechnologies.com, or any website of ours that links to this privacy notice
  • Download and use our application(s), such as our mobile applications, or any other application of ours that links to this privacy notice.
  • Engage with us in other related ways ― including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@pathwaystechnologies.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Pathways Technologies and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information. / We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.

Do you receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources.

How do you process my information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do I exercise my rights? The easiest way to exercise your rights is by filling out our data subject request form available here: https://pathwaystechnologies.com/contacts, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what Pathways Technologies does with any information we collect? Review the notice in full below.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
9. HOW LONG DO WE KEEP YOUR INFORMATION?
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
11. DO WE COLLECT INFORMATION FROM MINORS?
12. WHAT ARE YOUR PRIVACY RIGHTS?
13. CONTROLS FOR DO-NOT-TRACK FEATURES
14. DO WE MAKE UPDATES TO THIS NOTICE?
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register for training or download informational material eg. course outlines, case studies, company profiles, etc; express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • Name
  • Email
  • Phone Number
  • Company
  • Role

Sensitive Information. [We do not process sensitive information. / When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

  • Name
  • Email
  • Telephone

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.

[Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

  • Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
  • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s bluetooth, calendar, camera, own, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
  • Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
  • Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.]

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: [https://www.cookieyes.com/cookie-policy/].

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
  • Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
  • [Other]

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.

[Information collected when you use our Facebook application(s). We by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.]

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
  • To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
  • To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
  • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?” below).
  • To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. For more information see our Cookie Notice: https://www.cookieyes.com/cookie-policy.
  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
  • To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
  • To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
  • [Other]

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
  • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
    • Send users information about special offers and discounts on our products and services
    • Develop and display personalized and relevant advertising content for our users
    • Analyze how our services are used so we can improve them to engage and retain users
    • Support our marketing activities
    • Diagnose problems and/or prevent fraudulent activities
    • Understand how our users use our products and services so we can improve user experience
    • [Other]
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. This privacy notice does not apply to the personal information we process as a “data processor” on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the “data controller” responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers’ privacy practices, you should read their privacy policies and direct any questions you have to them.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

  • Ad Networks
  • Affiliate Marketing Programs
  • Cloud Computing Services
  • Communication & Collaboration Tools
  • Data Analytics Services
  • Data Storage Service Providers
  • Finance & Accounting Tools
  • Government Entities
  • Order Fulfillment Service Providers
  • Payment Processors
  • Performance Monitoring Tools
  • Product Engineering & Design Tools
  • Retargeting Platforms
  • Sales & Marketing Tools
  • Social Networks
  • Testing Tools
  • User Account Registration & Authentication Services
  • Website Hosting Service Providers

We also may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
  • Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.
  • Offer Wall. Our application(s) may display a third-party hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services, [including our offer wall], may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: Cookie Notice.

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform. If you log in using Facebook, we may also request access to other permissions related to your account, such as your friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our website servers are located in Tempe, Arizona USA. If you are accessing our Services from outside Tempe, Arizona USA, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), in Countries where Third-Party Servers are Located, and other countries.

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

European Commission’s Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Data Processing Agreements that include Standard Contractual Clauses are available here: [Standard Contractual Clauses URL]. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

Binding Corporate Rules:

These include a set of Binding Corporate Rules (“BCRs”) established and implemented by Pathways Technologies. Our BCRs have been recognized by EEA and UK data protection authorities as providing an adequate level of protection to the personal information we process internationally. You can find a copy of our BCRs here: [BCRs URL].

[EU-US] and [Swiss-US] Privacy Shield Framework[s]

Pathways Technologies and the following entities and subsidiaries: [List of Entities/Subsidiaries] comply with the [EU-US] and [Swiss-US] Privacy Shield Framework[s] as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from [the European Union (EU)], [the UK], and [Switzerland] to the United States. Although Privacy Shield is no longer considered a valid transfer mechanism for the purposes of [EU] and [Swiss] data protection law, in light of the judgment of the Court of Justice of the European Union in Case C-311/18 and opinion of the Federal Data Protection and Information Commissioner of Switzerland dated 8 September 2020, Pathways Technologies will continue to comply with the principles of the [EU-US] and [Swiss-US] Privacy Shield Framework[s]. To learn more about the Privacy Shield program, please visit www.privacyshield.gov. To view our certification, please visit [Privacy Shield Certification URL].

Pathways Technologies adheres to and complies with the Privacy Shield Principles when processing personal information from [the EU], [UK], or [Switzerland]. If we have received your personal information in the United States and subsequently transfer that information to a third party acting as our agent, and such third party agent processes your personal information in a manner inconsistent with the Privacy Shield Principles, we will remain liable unless we can prove we are not responsible for the event giving rise to the damage.

With respect to personal information received or transferred pursuant to the Privacy Shield Framework[s], Pathways Technologies is subject to the investigatory and enforcement powers of the US Federal Trade Commission (“FTC”). In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have any questions or concerns relating to Pathways Technologies’s Privacy Shield certification, please write to us at the contact details below. We commit to resolving any complaints or disputes about our collection and use of your personal information under the Privacy Shield. [However, if you have an unresolved complaint in connection with our certification, we commit to cooperating with the panel established by [the EU data protection authorities (DPAs)], [the UK Information Commissioner], and [the Swiss Federal Data Protection and Information Commissioner], as applicable, and to comply with the advice given by them in respect of the complaint. Click here for a list of EU DPAs. / However, if you have an unresolved complaint in connection with our certification, you may contact our independent dispute resolution provider based in the [EU/United States], [Dispute Resolution Provider Name]. Please visit [Dispute Resolution Provider URL] for more information or to file a complaint. These services are provided to you free of charge.]

In limited situations, [EU], [UK], and [Swiss] individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

Please be sure to review the following sections of this Privacy Notice for additional details relevant to Pathways Technologies’s participation in the [EU-US] and [Swiss-US] Privacy Shield:

  • WHAT INFORMATION DO WE COLLECT? To learn more about the types of personal data Pathways Technologies collects.
  • HOW DO WE PROCESS YOUR INFORMATION? To learn more about the purposes for which Pathways Technologies collects and uses personal information about you.
  • WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? To learn more about the type or identity of third parties to which Pathways Technologies discloses personal information, and the purposes for which we do so.
  • WHAT ARE YOUR PRIVACY RIGHTS? To learn more about the right of individuals to access their personal data.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than [the period of time in which users have an account with us / [#] months past the termination of the user’s account / [#] months past the start of the idle period of the user’s account / other].

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

11. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@pathwaystechnologies.com.

12. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages that we send, [Other] or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists — however, we may still communicate with you, for example to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Log in to your account settings and update your user account.
  • Contact us using the contact information provided.
  • [Other]

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/. For further information, please see our Cookie Notice: https://www.cookieyes.com/cookie-policy/.

If you have questions or comments about your privacy rights, you may email us at info@pathwaystechnologies.com.

13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

14. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Gideon Aswani, by email at gideon.aswani@pathwaystechnologies.com, by phone at +254 771 616 839, or by post to:

Pathways Technologies
236 Owashika Road
Lavington, Nairobi
Kenya

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please visit: https://pathwaystechnologies.com/contacts.

PATHWAYS TECHNOLOGIES LIMITED PRIVACY STATEMENT

Last updated 8th June 2024

Pathways Technologies Limited believes in the importance of thoughtfully handling personal information and is committed to privacy practices that are transparent and compliant with the data protection act 2019. This privacy policy will inform you as to how we look after your personal data that we may obtain from you or about you, and inform you about your privacy rights and how the law protects you.

What data do we collect?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, store, process, use, and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.
  • Contact Data includes billing address, delivery address, email address, and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type, and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username, purchases, or orders made by you, your interests, preferences, and feedback and survey responses.
  • Usage Data includes information about how you use our website, products, and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

 

How do we collect your data?

The categories of information we collect will depend on your interactions with Pathways Technologies Limited:

Contact data. Name, employer, title, email address, physical address, phone number, and similar contact info, user names, and passwords.

Transaction and financial data. Credit card number, banking information, and billing address.

Demographic Information. Employment status, occupation, region. If you participate in a Pathways Technologies Limited innovation focus group, then you will have the option to provide further information, such as gender, race, and age.

Inferred and derived information. Data such as propensities and attributes that Pathways Technologies Limited generates to help us understand you and your preferences.

Transaction and registration information. The information is generated in the course of your transaction with Pathways Technologies Limited, including account information, logins, passwords, and purchase history. Product registration information, product interest information, transaction information, and in some cases, student verification information. We may also collect registration information related to your attendance at Pathways Technologies Limited events, including travel information, scheduling information, food preferences or allergies, and accessibility requests.

Usage and geographic data. Pathways Technologies Limited collects information related to your use of our products, services, and websites. We analyze that usage data so that we can improve our products and your experience with them. In certain instances, Pathways Technologies Limited provides administrative tools so you can opt-out of the collection of some usage data.

Usage data includes online and technical information about your computer’s or mobile device’s operating system and browser type; your device type; details about how you are using our products (including natural language queries); your Internet Protocol (IP) address, and geographic areas derived from your IP address; networking connection data; Pathways Technologies Limited cookie information; file information; metadata; time-stamped logs regarding access times and duration of visits; the web pages you visited before coming to Pathways Technologies Limited websites (referring URL); and other usage data relating to your activities on our Sites, including the pages you request. We may link this information to the personal information we have collected about you and use it for the purposes described in this Privacy Statement, and we may deliver targeted marketing and product information back to you based on your usage data.

Third-party data. We may receive your personal information from third party suppliers or partners. If you connect with Pathways Technologies Limited accounts on third party social networking sites, we may receive information about your social networking accounts, for example, your name, username or display name, public profile, and email address. We may combine information you provide with data we collect automatically and with data we receive from third parties.

Images, video, and recordings. Pictures, videos, or audio recordings may be collected by Pathways Technologies Limited. For example, if you attend a Pathways Technologies Limited event, your image may be captured in a photo or video. If you call Pathways Technologies Limited customer support, your call may be recorded.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How will we use your data?

We use the personal information we collect for the purposes described in this Privacy Statement, as covered in any agreement that incorporates this Policy, or as disclosed to you in connection with our websites. For example, we will use your information to:

  1. Provide and deliver services or products.
  2. Operate and improve our operations, systems, products, and services;
  3. Understand you and your preferences to enhance your experience;
  4. Respond to your comments and questions and provide customer service;
  5. Provide service and support, such as sending confirmations, invoices, technical notices, updates, security alerts, and administrative messages and providing customer support and troubleshooting;
  6. Communicate with you and your referrals about promotions, upcoming events, and news about products and services offered by Pathways Technologies Limited and our selected partners;
  7. Link or combine information about you with other personal information we get from third parties, to help understand your needs and provide you with better and more personalized service;
  8. Enforce our terms and conditions or protect our business, partners, or users;
  9. Protect against, investigate, and deter fraudulent, unauthorized, or illegal activity; and
  10. Keep our products, facilities, and services secure.

Why we use your information

When we process your personal information, we will only do so where at least one of the following applies:

  1. We need to use your personal information to perform our responsibilities under our contract with you and to provide you with tools and services.
  2. We have a legitimate reason to collect and use your personal information. For example, it is in our legitimate interests to use usage data including your personal information to improve our products and services; to tell you about changes to this Privacy Statement and other policies; to tell you about new products, services, and events or changes to our products, services or websites; for business reasons (for example to develop and expand our business); and to tell you about offers or promotions we are running.
  3. You have given consent to use your personal information. You may withdraw consent by opting out where we give you the opportunity to do so, or by contacting us using the contact details below.
  4. If it is necessary for us to use your personal information in order to comply with a legal obligation.
  5. You have chosen to make the information public. You should not share any personal information which you wish to keep confidential or private.

Sharing of personal information

Pathways Technologies Limited works to keep your personal information confidential and secure. In some circumstances Pathways Technologies Limited may share your information with third parties, for example:

  • We may share your personal information when we have your permission, including when you choose to share information using our websites, public pages, and event registrations.
  • We provide personal information to trusted partners who work on behalf of or with Pathways Technologies to provide us with services. For example, we share contact information with our training and certification partners, consulting partners and service partners, our data storage, customer support, and marketing vendors, and with our software providers. These companies may use your personal information to perform services and to help Pathways Technologies communicate with you, including making offers from Pathways Technologies and our partners. Pathways Technologies maintains contracts with these companies restricting their access, use, and disclosure of personal information in compliance with this Privacy Statement and any legal obligations;
  • If you connect to your third party accounts through our products, we will use that information to authenticate you, enumerate the data sources available to you, download any data you request us to, and download and refresh authentication tokens or persist authentication information such as user names and passwords as necessary to continue to connect to these data;
  • We may share your contact and transactional information with our current or future affiliates, which may include parent and subsidiary companies, joint ventures, or other companies under common control, in which case we will require our affiliates to honor this Privacy Statement;
  • We will disclose your personal information to comply with legal requirements, such as in response to a court order or a subpoena. We also may disclose your personal information in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, verify, prevent, enforce compliance with, or take action regarding illegal or suspected illegal activities; suspected fraud; situations involving potential threats to the physical safety of any person; protection of the rights and property of Pathways Technologies, our agents, customers, or others; violations or suspected violations of our agreements and policies; or as otherwise required or permitted by law or consistent with legal requirements;
  • We transfer or disclose your personal information for corporate reasons. For example, to third parties in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, or similar transaction. We may also share personal information with our auditors, attorneys or other advisors in the connection with corporate functions; and
  • Finally, we also share aggregated, anonymized, or statistical information about you, including demographics data, with others for a variety of purposes, for example, for improving products and services for Pathways Technologies and others.
  • We may facilitate third party services or ways to share data through third parties, including social media platforms, websites, applications, and services through plug-ins, widgets, buttons, and other third-party features on and connected with our websites, communications or products. Third parties whose services you use in connection with Pathways Technologies services and products, such as our analytics platform provider partners, or third parties whose websites we link to, may have information practices that are different from ours. This Privacy Statement does not apply to the activities of third parties when they are collecting or using data for their own purpose or on behalf of others. We are not responsible for the activities of these third parties. We encourage you to review their privacy policies to understand how they use your information.

How do we store your data?

We have reasonable and appropriate physical, electronic, and managerial procedures in place to help safeguard your personal information. However, you should know that no company, including Pathways Technologies Limited, can fully eliminate security risks associated with personal information. To help protect yourself, use a strong password, do not use the same passwords to access your Pathways Technologies Limited accounts that you use with other accounts or services, and protect your user names and passwords to help prevent others from accessing your accounts and services. Pathways Technologies Limited will not be responsible in the event that you disclose personal information in your posts, through our public services or during any other communication with other website users.

Information collected by Pathways Technologies or on our behalf may be stored on your computers, mobiles devices or our servers and may be transferred to, accessed from or stored and processed in  Africa, United States and other countries including those that may not have data privacy laws that provide protections equivalent to those provided in your home country. However, we will protect all personal information we obtain in accordance with this Privacy Statement and take reasonable steps to ensure that it is treated lawfully.

In certain circumstances, we may retain your personal information after you have closed your account or are no longer actively engaged with Pathways Technologies. For example:

  • We may retain your personal information after you have closed your account so that we can send you information about products, services, and publications we think you may be interested in. You can “unsubscribe” from receiving such messages or tell us you are no longer interested;
  • We may retain your personal information in order to protect our legal rights, or those of third parties, or to comply with the law;
  • We may retain personal information about how you have used our products and services in order to improve and develop our business;
  • If you purchase products or services from us, we may retain your personal information for as long as we need to in order to provide you with customer service, or for compliance purposes, for example, in order to comply with our record-keeping requirements;
  • Pathways Technologies may also use and share aggregated, non-personally identifiable data for research, external training, and marketing purposes.

What are your data protection rights?

Our marketing emails permit you to opt out of receiving further marketing emails. If you opt-out but are a current customer, we will still send you transactional emails. Transactional emails are necessary communications about your accounts and our business dealings with you, such as renewals and updates, and, as allowed by applicable law, requests for your participation in surveys.

When you use our websites, you can choose to set your browser to remove cookies and to reject cookies from our servers. If you choose to remove or reject cookies, this could affect certain features or services of our websites. For information about how to remove or manage cookies please read our cookie policy.

You have certain rights in your personal information, subject to local data protection laws.

The right to access – You have the right to request Pathways Technologies Limited for copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that Pathways Technologies Limited correct any information you believe is inaccurate. You also have the right to request Pathways Technologies Limited to complete the information you believe is incomplete.

The right to erasure – You have the right to request that Pathways Technologies Limited erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that Pathways Technologies Limited restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to Our Company’s processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that Pathways Technologies Limited transfer the data that we have collected to another organization, or directly to you, under certain conditions.

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 at our email:info@pathwaysinternational.com

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.

How do we use cookies

There are a number of different types of cookies, however, our website uses:

  • Functionality – Pathways Technologies Limited uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and the location you are in. A mix of first-party and third-party cookies are used.
  • Advertising – Pathways Technologies Limited uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed, and information about your browser, device, and your IP address. Pathways Technologies Limited sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Privacy policies of other websites

The Pathways Technologies website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

Changes to our privacy policy

Pathways Technologies keeps its privacy policy under regular review and places any updates on this web page and in some cases sends a notification of changes via email.

How to contact us

If you have any questions about how we use your personal information, or if you have any other privacy-related questions, please contact us here or at info@pathwaystechnologes.com.