PATH2 Privacy Notice
Last Updated: 2020–September-1
Protecting the privacy and security of your personal data is important to PATH2. This notice describes PATH2’s practices concerning how we handle your personal data. This Privacy Notice applies to PATH2’s websites, and any of their subpages, subdomains or desktop and mobile versions, including any content, materials, software, information, data, features, functionality and services made available therein (the “Site”).
Please review this Privacy Notice carefully to understand how we process your information. By using the Site, you agree to the personal data practices explained below. If you do not agree with the practices and procedures described in this Privacy Notice, please discontinue using the Site.
We may modify this Privacy Notice at any time. Amendments to the Privacy Statement are effective immediately when posted on the Site. Your continued use of the Site after posting of amendments will be deemed your acceptance of the changes to this Privacy Notice.
You can determine when this Privacy Notice was last revised by referring to the date it was “Last Updated” above.
PATH2 will handle your personal data in compliance with applicable laws on data privacy protection and data security. PATH2 does not install any software applications, including spyware, on your computer and does not sell any information under any circumstances to third parties.
COLLECTION OF INFORMATION
When you interact with the Site, we may collect information about you, including “personal information” and “non-identifying” information.
“Personal information” means information about you that specifically identifies you or, when combined with other information we have, can be used to identify you, such as name, telephone number, email address, physical address, customer number, employer, job title, industry, and payment card information.
“Non-identifying information” means information that alone cannot directly identify you, such as usage data that automatically records information about your visit (like your browser, domains, page views, the URL of the page that referred you, the URL of the page you next visit, your IP address, page navigation, time and duration of your visits to the Site, and the type and amounts of your purchases); data from cookies, pixel tags, and web beacons; and device data (like the type of operating system you use, mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, and mobile phone carrier identification).
HOW WE COLLECT AND USE INFORMATION
PATH2’s Site collects information in three ways:
Volunteered Information: We only collect personal information from you if you choose to share such information with us. For example, you may be required to provide us with certain Personal Information to register with the Site, sign up for certain services available through the Site, complete transactions via the Site, contact PATH2, or respond to surveys, questionnaires or applications.
Data Collected Automatically: When you access PATH2’s Site, PATH2 automatically collects industry-standard non-identifying information, such as usage data and device data. PATH2 collects and uses this type of information to help us understand how users interact with the Site, to provide you with a more relevant experience, to analyze spending behavior, and to enhance the services we offer. We may also collect this information with our affiliates to monitor the attractiveness of our Site, to improve its performance or content, and to ensure that it is working properly.
INFORMATION WE SHARE
Whenever we share your personal information with a third-party, that party will be required to protect your information in accordance with our Privacy Notice. We (or our partners on our behalf) may share your personal information as required or permitted by law:
● With any PATH2 affiliate who may only use the personal information for the purposes described in this Privacy Notice;
● With our partners to provide services for us and who are required to protect your personal information, including:
○ data processing contractors that provide computer services on our behalf
○ web hosting or web development firms that host or develop parts of our Site
○ service providers that will fulfill your requests
○ billing firms that process your orders
○ mailing firms that will assist us with our mailings
○ marketing firms that will assist us with direct marketing
○ data analytics firms that help us conduct customer research and analyze users’ interactions with our Site
● With relevant business partners:
○ which you have elected to participate
● With a purchaser of PATH2 or any of the PATH2 affiliates (or their assets)
● To comply with legal orders and government requests, or as needed to support auditing, compliance, and corporate governance functions
● To combat fraud or criminal activity, and to protect our rights or those of our affiliates, users, and business partners, or as part of legal proceedings affecting PATH2 or our business partners
● In response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries where we operate
● With your consent.
We do not share your personal information with Third-Party Ad-Servers.
We encourage business partners to adopt and post privacy policies. However, their use of personal information obtained through PATH2 is governed by their privacy policies and is not subject to our control.
We may also disclose non-identifiable information:
● for the same reasons we might share personal information
● with business partners for their own analysis and research
● to facilitate targeted content and ads
● to facilitate your participation in a joint program or activity on the Site.
You can always review, correct, update, or change your personal information at any time, or opt out of our direct marketing efforts, by changing the relevant settings in your profile or account (if available), or contacting us at email@example.com.
Some web browsers may transmit “Do Not Track” (“DNT”) signals to the Site and other online services with which the browser communicates. There is no standard that governs what, if anything, websites should do when they receive these signals. Currently, we do not alter our data collection and use practices in response to DNT signals. If and when a standard for responding is established, we may revisit our Privacy Notice on responding to these signals. PATH2 does not knowingly allow other parties to collect personal information from users on our Site.
Mobile Device Data: You may manage how your mobile device and mobile browser share certain device data with PATH2 by adjusting the privacy and security settings on your mobile device. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
PATH2 does not solicit any information from children under 14 years of age. PATH2 will not knowingly collect personal information from children without insisting that they seek prior parental consent if required by applicable law. PATH2 will only use or disclose personal information about a child to the extent permitted by law, to seek parental consent pursuant to local law and regulations or to protect a child.
If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personal information to us please contact us at firstname.lastname@example.org. A parent or guardian of a child under the age of 13 may review and request deletion of such child’s personal information as well as prohibit the use thereof.
PATH2 has implemented commercially reasonable security measures that are appropriate to the nature of the information that we collect and are designed to safeguard that information from unauthorized access, destruction, use, modification, or disclosure. To the extent we utilize third-party service providers, such Amazon Web Services, to store your personal information, those third-party service providers are obligated to also protect your personal information.
Only PATH2 and PATH2 authorized entities are allowed to access information stored on our servers. Unauthorized accessing of PATH2 information stored on our servers is a violation of the law.
Notwithstanding the above, no data transmission or storage system can be guaranteed to be fully secure. As a result, while we strive to protect information transmitted on or through the Site, we cannot and do not guarantee or warrant the security of any information you transmit on or through the Site, and you do so at your own risk.
The safety and security of your information also depends on you. Where you have chosen a password for access to certain parts of our Site, you are responsible for keeping this password confidential. You should not share your password with anyone. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us of the problem by contacting us at email@example.com.
LINKS TO OTHER WEBSITES
To the extent PATH2’s Site contains links to other websites, PATH2 is not responsible for the privacy practices or the content of other websites. We encourage you to review the privacy policies or statements of these third-party websites to learn more about the ways they may collect, use, or otherwise process your information.
The Site is intended for United States residents. Your personal information will be collected and stored in the United States, and subject to the laws of the United States. If you reside in a country outside the United States, please note that the data protection and privacy laws of the United States may not be as protective as the laws in your country. You agree that the laws of the United States will govern the processing of your personal information, including any obligations of security and third-party sharing.
QUESTIONS AND COMMENTS
If you have any questions or comments about PATH2’s Privacy Notice please email your questions or comments to firstname.lastname@example.org.