Pathspark Privacy Policy

 

Last revised: October 24, 2018

Pathspark, Inc. (“Pathspark,” “we” or “us”) respects your privacy, and we understand the importance of the information you entrust to us.  This policy (“Privacy Policy”) describes our policies and practices concerning the information we collect from you when you visit our website (pathspark.com) (the “Site”) or use the services available on or through the Site and any related mobile or desktop application we have developed or may develop (collectively, the “Service”). This policy describes the types of information we collect, how we retain, use and protect that information, and with whom we share it.  It also explains what your rights and options are as they pertain to that information.  By using our Service, you consent to our collection and use of your information as described in this Privacy Policy.

1.  WHAT INFORMATION DO WE COLLECT?

            We collect two basic types of information:

(a)  Personally identifiable information (“PII”):  PII is information that identifies you as an individual, such as your name, email address, phone number, credit card information, username, and password. You voluntarily provide this information when you establish an account. To establish your account we only ask you to provide your name (first and last), email address, and phone number.  You will then create a username and password, which we will store.  We may then ask you to provide payment details (i.e., credit card). Once your account is established, you will be prompted to add certain personal details to enable us to match you with a suitable career coach (“Coach”), such as your industry, profession, age, gender, career goals, etc.  We will also ask you to provide additional contact details, such as your Facebook Messenger™ address, to enable Coaches to get in touch with you.  This additional information is voluntary, and any information you elect to add to your profile will be viewable by other members (i.e., Coaches).  Any forms you complete, and communications between Coaches and you that take place on our platform, are also elements of PII that we may collect.  Also, if you choose to link your social networking accounts to your profile, you are granting us permission to access and use certain information about you as permitted by the social network.  For example, if you link your Facebook account, it may provide us with access to whatever information you choose to include in your public profile, such as friends’ names, pictures, genders, user IDs, connections, and any other shared content.  Finally, when you log on to your account, we will record your IP address and/or unique mobile device identifier and may tie it to your specific account. Under ordinary circumstances, an IP address recorded in isolation is not PII.  However, it may become PII when combined with other information, as in this case.

(b)  General Information:  General information consists of information that is anonymous in nature and does not identify you as an individual.  We use cookies to collect general information.  A “cookie” is a type of software used to gather and store visitor information.  The general information we collect includes your computer IP address (when not tied to your particular account), unique mobile device identifier, browser type, ISP or carrier name, and the URL of the last webpage you visited before visiting our Site.

Note that messaging applications like Facebook Messenger, SMS texting services available through a user’s mobile phone service provider, and other messaging services, may collect PII or general information about you. We have no control over these services, and you are advised to review their privacy policies.

2.  HOW DO WE USE THE INFORMATION WE COLLECT?

We use the PII we collect from and about you to enable us to provide you with our Service.  For example, we use your email address to contact you in response to customer service requests, or for other matters regarding your account.  We use your phone number and Facebook Messenger address to enable you to interact with Coaches.  We may also use PII to verify your identity and eligibility for our Service, and to otherwise perform functions associated with our Service. We use the general information we collect to give us insight into how our users use our Site and our Service, and to improve our Service.

 

3.  HOW DO WE SHARE INFORMATION?  

We will not share the information you provide to us with any third parties for marketing purposes.  We may share information with third parties in the following ways: 

(a)  We will share your contact information with one or more Coaches with whom you have been matched for the purpose of putting you in contact with them.  We will only share as much of your information as may be required for this purpose.

(b)  With your consent, we may share certain activities you have engaged in when using the Service with educational institutions that we may work with for research purposes. Note that we will always obtain your consent before doing so.

(c)  If requested or required by law enforcement authorities, courts, or regulators, we may disclose any information we have about our users. We also may disclose your PII to exercise or protect our legal rights or defend against legal claims 

(d)  We sometimes contract with other companies and individuals to perform functions or services on our behalf, such as hosting the Site, sending email messages, and monitoring Site activity.  We necessarily have to share your PII with such third parties as they require to perform their functions.

(e)  In some cases, we may choose to buy or sell assets. In these business transfers, customer information, including PII, is typically one of the business assets that are transferred.  Moreover, if all or substantially all of our business assets were acquired, or in the unlikely event that we go out of business or enter into bankruptcy, customer information (including your PII), would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any assets may continue to be used according to your PII as set forth in this policy.

(f)  We may reserve and have the right to disclose any information about you or your use of our Site without your prior permission, if we in good faith believe that such action is necessary to: (i) protect and defend the rights, property or safety of our company or related parties, other users of the Site, or the public; or (ii) to enforce our Terms of Service.

4.  HOW DO WE PROTECT YOUR INFORMATION? 

Generally.  We take the security of your personal information seriously and use appropriate technical and organizational measures to protect your personal information against unauthorized or unlawful processing and against accidental loss, destruction or damage.  We encrypt all data using standard SSL encryption. We also limit access to personal information about you to employees and contractors who require access to it to provide our Service.  However, because no security system can be 100% effective, we cannot completely guarantee the security of any information we may have collected from or about you.  In addition, we have no control over the security of other web sites on the Internet that you might visit even when a link may appear to those web sites from our Site.  If you share your computer or use a computer that is accessed by the general public, remember to log off and close your browser window when you have finished your session. 

Payment Information.  We use Stripe, Amazon Payments, and PayPal to process payments.  More information on how those companies collect and safeguard your information may be found at the following links:

https://stripe.com/docs/security/stripe

https://payments.amazon.com/help/201491260

https://www.paypal.com/us/webapps/mpp/ua/privacy-full

 

5.  HOW LONG DO WE KEEP INFORMATION? 

We retain PII for as long as we deem necessary to satisfy a business purpose.  If you elect to cancel your account, you may request that we delete your PII by sending us an email at [EMAIL ADDRESS]. We may also choose to anonymize certain of the information you provide to us so that it can no longer be attributed to you if we would like to retain it for longer periods of time.

6. CAN I CONTROL HOW MY INFORMATION IS USED?  

The best way to control how we use your information is to delete or amend the information by changing your account preferences. Otherwise, we do not currently offer options on the specific use of personal information.

 7.  HOW WE USE TRACKING TECHNOLOGY. 

We employ certain technologies such as Google Analytics or Facebook Pixel that enable us to track your online activities on our Site over time, and to a certain extent across third-party web sites.  We may from time to time share, sell, rent, or trade PII and/or general information with third parties or permit third-party tracking, re-targeting or data analysis across our Site or Service for our promotional purposes (e.g., to serve you more relevant advertisements or promotional offers). These third parties may collect more information than we collect. We offer no response to browser Do-Not-Track requests, but you can, for example, prevent Google Analytics from recognizing you on return visits to this Site by disabling cookies on your browser.

8.  CHILDREN UNDER 13. 

Our Service is not intended for users under the age of 13, and we do not knowingly collect any personal information from children under 13.  If we become aware that someone submitting information is under 13, we will attempt to delete the information as soon as possible.  According to our Terms of Service, all users must be at least 13 to visit our Site or use the Service. 

9.  FOR CALIFORNIA USERS.

In addition to the rights set forth in this Privacy Policy, residents of California ("California Users"), may request information regarding the types of personal information we share with third parties for direct marketing purposes, and the identities of the third parties with whom we have shared such information during the immediately preceding calendar year.  California Users may request further information about our compliance with this law by sending us a message via the email address set forth below.  Please note that we are only required to respond to one request per customer each year concerning this law, and we are not required to respond to requests made by means other than through the Contact Us page on our Site.

10.  CHANGES TO THIS PRIVACY POLICY.  

We reserve the right to amend, alter, or otherwise change this Privacy Policy in our sole and absolute discretion.  If we make any changes regarding the disclosure of Personal Information to third parties, we will inform all registered Users, and post notice of the new or revised Privacy Policy from the privacy link on our Site by updating the “Last revised” date at the top of this policy.  Further use of this Site or the Service following any such change constitutes your agreement to follow and be bound by the amended Privacy Policy.

 11.  QUESTIONS OR COMMENTS?

If you ever have any questions about this Privacy Policy or our collection and use of your personal information, please contact us. We respect your rights and privacy, and will be happy to answer any questions or concerns you might have.   You may direct any such questions to us via the “Contact Us” page on our Site, by emailing as at: info@pathspark.com, or writing to us at: Pathspark, Inc., 245 East 93rd St., No. 17G, New York, NY 10128.