PATHWAYS INTERNATIONAL LIMITED PRIVACY STATEMENT

Last updated 5th January 2020

Pathways International 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 International 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 International 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 International Limited generates to help us understand you and your preferences.

Transaction and registration information. The information which is generated in the course of your transaction with Pathways International 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 International Limited events, including travel information, scheduling information, food preferences or allergies, and accessibility requests.

 

Usage and geographic data. Pathways International 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 International 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 International 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 International 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 International 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 International Limited. For example, if you attend a Pathways International Limited event, your image may be captured in a photo or video. If you call Pathways International 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 International 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 International Limited works to keep your personal information confidential and secure. In some circumstances Pathways International 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 international 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 International communicate with you, including making offers from Pathways international and our partners. Pathways International 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 International, 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 International 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 International 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 International 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 International 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 International 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 International 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 International. 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 International 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. You may also contact us at customersuccess@pathwaysinternational.com at any time to let us know that you no longer wish to receive 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 International 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 International Limited correct any information you believe is inaccurate. You also have the right to request Pathways International Limited to complete the information you believe is incomplete.

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

The right to restrict processing – You have the right to request that Pathways International 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 International 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 International 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 International 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 International 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 International 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 International 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@pathwaysinternational.com.