Privacy Policy2018-07-16T00:41:40+00:00

PATHWAY21 PRIVACY POLICY

Effective Date: May 18, 2018

Pathway21 P.B.C. (“Pathway21,” “we,” “us,” “our”) understands your privacy is important. This Privacy Policy (“Policy”) describes how we collect, use, store, process, and share your information in relation to your access and use of https://pathway21.com/ (the “Site”), including all related Pathway21 websites, associated media, printed or electronic materials, and Updates (all collectively, the “Service”). By visiting, accessing, or using the Service, you expressly consent to the collection, use, storage, transfer, processing, and disclosure of your information, including personal information, as described in this Policy. IF YOU DO NOT AGREE WITH THIS POLICY, DO NOT ACCESS OR USE ANY PART OF THE SERVICE, REGISTER FOR AN ACCOUNT, OR MAKE A PURCHASE.

1.  INFORMATION COLLECTION.

a.  General. When you visit the Site without registering for an account (“Account”) or making a purchase, you can browse without submitting any personally identifiable information. In order to set up an Account and use the Service to purchase Materials, however, you will be asked to provide personally identifiable information. Personally-identifiable information is information that can identify you, including, for example, your name or email address.

b.  Account, Login, Purchase, and Other Information. If you create an Account or purchase or offer for sale any products or materials (each a “Material”) through the Service, you will be asked to provide and we may collect certain information you provide to us, including, but not limited to, name, email address, password, business name, billing address, and other information.

c.  Listings. Registered users may create a list (“Listing”) of Materials available for purchase through the Service. To create a Listing, you will be required to provide and we will collect certain information about the Material you are selling, including Material name, the quantity of the Material available, and a description of the Material.

d.  Request Certain Information. You may provide your email address and other contact information to us in order to request information related to Pathway21’s products, programs, and services even if you do not sign up for an Account or make a purchase.

e.  Communications. In order to receive certain communications from us, you will be required to submit certain personal information, including, but not limited to, your name, email address, physical address, phone number, and other contact information.

f.  Social Media. We may collect information when you visit or use third-party websites and apps that we have a registered page with such as Facebook, LinkedIn, and Twitter. We receive information about you and your activities on and off our Website from third-party websites and apps through their reporting tools.

g.  Payment Information; Third Party Payment Processor. We use a third-party payment processor to assist in securely processing your personally identifiable payment information. The credit card information that you provide is encrypted and transmitted directly to our third-party payment processor. We do not store your credit card information and do not control and are not responsible for its collection or use of your information.

h.  Automatically Collected Information. Similar to other websites, we may collect some information automatically and store it in log files. This collection may include, but is not limited to, your IP address, browser and device type, referring/exit pages and URLs, other browser history, number of clicks, landing pages, cookie information, the pages you requested and viewed, the amount of time spent on particular pages, and the date and time of each request you make. We collect this non-identifying information in order to better understand our users, to more efficiently operate our business, to promote our products and services, and to improve the quality of the Service. We may automatically collect information using various mechanisms, including, but not limited to, cookies and pixels.

Cookies. A cookie is a small text file that is stored on a computer for record-keeping purposes. Our third-party analytics providers use cookies to record information about your activities while using the Service and to “remember” you when you return to the Service. Some cookies remain on your computer until you delete them. Others, like session ID cookies, expire when you close your browser. You may set your browser setting to attempt to reject cookies and you may still use the Service, however, certain features of the Service may not be available if your browser does not accept cookies. See the section titled “Do Not Track Settings” below for more information on how the Service may respond to your browser settings. We do not control the use of cookies by third parties. See also the section titled “Third Party Analytics Providers” below.

Pixels. Pixels are tiny graphics with a unique identifier that are used to track the online movements of web users. Unlike cookies, which are stored on a computer’s hard drive, pixels are small graphics that are about the size of the period at the end of the sentence that are embedded invisibly on web pages or in HTML-based emails. Our third-party analytics providers may place pixels on the Site that track what other websites you visit (both before and after visiting the Site). Our third-party analytics providers use information obtained from pixels to help us improve our business and the Service. We do not control the use of pixels by third parties.

i.  Third Party Analytics Providers. We use third parties to help us operate and improve the Service. In doing so, we may share with these third parties non-personally identifiable information about users’ use of the Service. These third-party providers also use cookies. We use third party analytics providers, such as Google Analytics, to provide us with general demographic and interest-level information about our users and to help create a better user experience. We do not control information collected by third parties and are not responsible for their use of that information.

Google Analytics uses cookies and pixels in order to collect demographic and interest-level information and usage information from users that visit the Service, including, but not limited, to information about the pages where users enter and exit the Service and what pages users view on the Service, time spent, browser, operating system, device information, and IP address. Cookies and pixels allow Google to recognize a user when a user visits the Service and when the user visits other websites. Google uses the information it collects from the Service and other websites to share with us and other website operator’s information about users including, but not limited to, age range, gender, geographic regions, general interests, and details about devices used to visit websites and purchase items. We take reasonable measures to prevent linking information we receive from Google with any of your personally identifiable information. For more information regarding Google’s use of cookies and collection and use of information see the Google Privacy Policy. To opt out of Google Analytics, please visit the Google Analytics Opt-Out Page to learn about opting out and installing the appropriate browser add-on.

j.  “Do Not Track” Settings. Because we track Service usage information through the use of cookies, pixels, and other tracking mechanisms, your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information. The only way to completely “opt out” of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser to delete and disable cookies and other tracking/recording tools. However, getting a “Do Not Track” signal to work as you might want is difficult. Using browsers as an example, not all tracking technologies can be controlled by browsers; unique aspects of your browser might be recognizable even if you disable a tracking technology; not all settings will necessarily last or be effective; even if a setting is effective for one purpose, data still may be collected for another; and even if one website observes a “Do Not Track” signal, that website usually will not be able to control other websites.

2.  INFORMATION USE.

a.  General. We will use your personally identifiable information to operate, manage, and administer your Account and the Service; to assist in facilitating your Materials transactions; to provide you with support for the Service; to communicate with you; to improve the Service; and to provide you information about Pathway21 products and services (as well as the products and services of third parties). We may also use personally identifiable information to resolve disputes; to detect and protect against errors, fraud, and illegal activity; to assist law enforcement; to enforce this Policy and our Terms of Service; or for any other purpose described in this Policy or described to you at the time of collection.

b.  Communications. We may use your personally identifiable information to send you emails, notifications, or other communications related to your use of the Service, your Account, your orders for Materials, or to respond to your inquiries or requests. You may not opt out of these Service-related emails. We may also send you promotional emails to notify you about products or services that may be of interest to you. If you would like to stop receiving promotional messages from us or third parties, please click on the opt-out link in any non-Service related email you receive. Even if you opt out, you will continue to receive Service-related communications from us.

c.  Use of Non-Personally Identifiable and Aggregate Information. We may use non-personally identifiable information and aggregate information for any lawful purpose, including, but not limited to, analyzing trends, managing and administering the Service, tracking users’ interaction with the Service, to create new products or services, or to improve our business and the Service. In addition, we may share aggregate information with our business partners. We may also combine your non-personally identifiable information and aggregate information with other non-personally identifiable information and aggregate information collected from other sources. We will take reasonable steps, including those described in this Policy, to ensure that aggregate information is never associated with you or your personally identifiable information.

d.  Information Retention. We may retain your non-personally identifiable information indefinitely, or as long as legally required or allowed, for our business needs and in order to deter fraud or abuse of the Service. We may dispose of any information in our discretion without notice, subject to applicable law. We do not undertake any retention obligations through this statement.

3.  INFORMATION DISCLOSURE.

a.  Affiliated Entities and Service Providers. We may disclose your information, including personal information, to affiliated entities or organizations, business partners, and to agents and service providers to help us operate the Service, improve our business or the Service, and to provide services to us.

b.  Legal Requirements. In some cases, we may disclose your information, including personal information: (i) as required by any applicable law or legal regulation; (ii) if we believe disclosure is needed to protect our rights, property, or safety; (iii) to government regulators or law enforcement authorities in connection with any judicial proceeding, court order, subpoena, or legal process served on us or the Service; and (iv) to respond to a physical threat to you or another person.

c.  Insolvency and Business Transitions. If we should ever file for bankruptcy or engage in a business transition such as a merger with another company, or if we purchase, sell, or reorganize all or part of our business or assets, we may disclose your information, including, but not limited to, personal information, to prospective or actual purchasers in connection with one of these transactions.

d.  Disclaimer. We cannot ensure that all of your personal information will never be disclosed in ways not otherwise described in this Policy. For example, a third party may unlawfully intercept or access transmissions or private communications, or other users of the Service may abuse or misuse your personal information. No transmission of data over the internet can be 100% secure.

4.  INFORMATION SECURITY MEASURES. We exercise care in facilitating the transmission of information between your device or computer and the third-party servers that operate and store information for the Service. The personal information we collect is stored in operating environments that are not available to the public. While we have mechanisms in place to safeguard your personal information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.

5.  ADDITIONAL TERMS.

a.  The Service Is Not for or Directed Towards Children. The Service is not intended for anyone under the age of 18, and children under the age of 13 are prohibited from using the Service. If we learn that we have collected information from a child under the age of 13, we will remove that information immediately and delete it from our servers. If you believe information from a child under the age of 13 has been provided to the Service, please notify us at: serviceterms@pathway21.com.

b.  California Minors. While the Service is not intended for anyone under the age of 18, if you are a California resident under age 18 and you believe your information has become publicly-available through the Service and you are unable to remove it, you may request removal by contacting us at: serviceterms@pathway21.com.

c.  Your California Privacy Rights; California Shine the Light Law. California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to serviceterms@pathway21.com.

6.  CHANGES TO THIS POLICY. Pathway21 reserves the right to change this Policy at any time upon notice. Pathway21 may give notice by making the updated Policy available through the Service or by any other reasonable means. You can review the most current version of the Policy at any time at Privacy Policy. The updated Policy is binding on you on the effective date indicated at the top of this Policy. If you do not agree to the updated Policy, you must stop using the Service before the effective date. Your continued use of the Service after the effective date posted at the top of this Policy will constitute your acceptance of the updated Policy.

7.  ACCESSING, UPDATING, OR DELETING YOUR PERSONAL INFORMATION. You may access, update, or delete your personal information by contacting us at: serviceterms@pathway21.com. We will make good faith efforts to resolve requests to correct inaccurate information except where the request is unreasonable, requires disproportionate technical effort or expense, jeopardizes the privacy of others, or would be impractical. If your Account is terminated for any reason, your information will no longer be accessible through your Account or associated with your Account. However, activity that occurred prior to deletion may still continue to be stored on our systems or the systems of our service providers.

8.  PRIVACY QUESTIONS. If you have any questions about this Policy, please contact us at: serviceterms@pathway21.com.