Introduction
This document sets out the privacy policy of Pathways Digital Pty Ltd (ABN 30 650 409 288) (referred to in this privacy policy as 'we', 'us', or 'our'). For the purposes of applicable data protection law, (in particular, the General Data Protection Regulation (EU) 2016/679 (the "GDPR") and the UK Data Protection Act 2018), your data will be controlled by us.
This privacy policy applies whenever we collect your personal information and/or personal data (your personal data). This includes between you, the visitor to our website or the platform developed and maintained by us (Pathways Platform) (whether directly as our customer or as personnel of our customer or an end-user of our customer), and us, the owner and provider of this website and the Pathways Platform and also where we are directed by a third party to process your personal data. This privacy policy applies to our use of any and all data collected by us or provided by you in relation to your use of the website and Pathways Platform and the provision of our services to you.
We take our privacy obligations seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data in connection with your use of our website and Pathways Platform. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
Types of personal information we collect
The personal data we collect may include the following:
- name
- mailing or street address
- email address
- social media information
- telephone number and other contact details
- age
- date of birth
- job titles and other employment information provided by you or your employer
- display names, profile pictures or other proof of identity documentation (such as passports, drivers licences, and birth certificates)
- credit card or other payment information
- group certificates, payslips, and other income or earnings information
- utility bills including internet services
- information about your business or personal circumstances
- information in connection with any client surveys, questionnaires and promotions you participate in
- when we use analytical cookies, your device identity and type, I.P. address, geo-location information, page view statistics, advertising data and standard web log information
- information about third parties
- any other information provided by you to us via our website and Pathways Platform, in the course of us providing services to you, or otherwise required by us or provided by you
How we collect personal information
We endeavour to ensure that information we collect is complete, accurate, accessible and not subject to unauthorised access.
We may collect personal data either directly from you, or from third parties, including where you:
- register an account to access the Pathways Platform (including where you update your account details)
- provide documentation or other information to complete a transaction via the Pathways Platform
- provide that information through any functionality available on our website and Pathways Platform or any other platform we operate from time to time
- communicate with us via email, telephone, SMS, social applications (such as LinkedIn, Facebook or Twitter) or otherwise
- engage us to perform any other services to you (whether via the website, the Pathways Platform, or directly by contacting us)
- when you or your organisation offer to provide, or provides, services to us
- interact with our website, the Pathways Platform, social applications, services, content and advertising
- invest in our business or enquire as to a potential purchase in our business
We may also collect personal data from you when you make any other use of our website, the Pathways Platform, or our social media pages. This may be done through use of web analytics tools, 'cookies' or other similar tracking technologies that allow us to track and analyse your website usage. For more information, please see our Cookie Policy, which is accessible here: www.pathwaysdigital.io/legal
Use of your personal information
We collect and use personal data for the following purposes:
- to provide you access to features or complete transactions within the Pathways Platform
- to provide services or information to you or a third party user of our services (for example, your employer)
- for record keeping and administrative purposes
- to comply with our legal obligations, resolve disputes or enforce our agreements with third parties
- where we have your consent, including to send you marketing and promotional messages and other information that may be of interest to you. In this regard, we may use email, SMS, social media or mail to send you direct marketing communications. You can opt-out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link)
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for our legitimate interests including:
- to develop and carry out marketing activities and to conduct market research and analysis and develop statistics
- to improve and optimise our service offering and customer experience
- to send you administrative messages, reminders, notices, updates and other information requested by you
- to consider an application of employment from you
- the delivery of our services
Security
We take reasonable steps to ensure your personal data is secure and protected from misuse or unauthorised access. Our information technology systems are password protected, and we use a range of administrative and technical measures to protect these systems. However, we cannot guarantee the security of your personal data.
Links
Our website may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of those linked websites and we suggest you review the privacy policies of those websites before using them.
Your rights
You have various rights with respect to our use of your personal data:
You may, at any time, exercise any of the above rights, by contacting our email address provided below.
How long we keep data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will securely destroy your personal data in accordance with applicable laws and regulations.
However, we may retain copies of personal data which has been de-identified or anonymised so that the data is no longer subject to the applicable data protection law. This privacy policy does not apply to any such anonymised or de-identified data.
If you would like further information about our specific retention periods for your personal data, please contact us using our email address provided below.
Transfers outside the EEA
To provide our services, we may transfer the personal data we collect to countries outside of the UK or EEA which do not provide the same level of data protection as the country in which you reside and are not recognised by the European Commission as providing an adequate level of data protection.
When we do this, we will make sure that it is protected to the same extent as in the EEA and UK as we will put in place appropriate safeguards to protect your personal data, which may include standard contractual clauses.
For more information, please contact us at our email address provided below.
Contact us
We may change this privacy policy from time to time by posting an updated copy on our website and we encourage you to check our website regularly to ensure that you are aware of our most current privacy policy. Where we make any significant changes, we will endeavour to notify you by email.