- Information Collection and Use
- Personally Identifiable Information:
When you sign up to the Services, update your account details, or make other use of our services, we may ask you for personally identifiable information (“Personal Information”). The Personal Information can be used to contact you or identify you and it may include, but not limited to, your name, your email, your phone number. We may use the Personal Information, either by itself or in conjunction with other information, for the following purposes:
- To create your account, let you log in to the account, administer your account, monitor your account, provide customer service and contact you with information, alerts and suggestions that are related to your account.
- For billing-related purposes.
- To email you updated about our services. You can opt-out of these at any time.
- Profile Information:
We ask questions about you, your medical condition and your experience of pain. This is used so that we can:
- Provide you with educational sessions related to your medical condition
- Provide you with education sessions that relate to the level of pain you’re experiencing
- Analyze the effectiveness of our services for your particular condition
- Collect and analyze statistical or aggregated information which is not personally identifiable.
- Log Data:
- When you use the Services, our servers or servers of third party services automatically record information that your browser sends (“Log Data”). This Log Data may include, but not limited to, information such as your computer, Internet Protocol address (“IP”), pages that you visit and the time spent on those pages, actions that you take and other statistics. We may use this information, either by itself or in conjunction with other information for the following purposes:
- Monitor, analyze and improve the use and functionality of the Services, the Services’s technical operation and the match of the Services functionality to your needs and preferences.
- Cookies and Web Beacons
- Aggregate Information and Non-Identifying Information
We may share aggregated information that does not include any Personal Information with third parties for any purpose, including but not limited to industry analysis, research and business transactions.
- Transfer of Business
We may sell or transfer some or all of our assets, including your Personal Information, in connection with a merger, acquisition, consolidation, joint venture, reorganization or sale of assets. Such transactions would be covered by a confidentiality agreement.
- Service Providers
We may employ third party companies and individuals to facilitate our Services, to perform certain tasks which are related to the Services or to provide audit, legal, operational or other services for us. These tasks include, but not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. When needed we may disclose information, including Personal Information, to such third parties but we will try to limit the Personal Information disclosed to the minimum necessary to perform their task.
- International Transfer
Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.
- The Personal Information of Children
The Services are not directed to children. We do not knowingly allow or solicit anyone under the age of 18 to participate independently in any of the Services. We do not knowingly collect Personal Information from children. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, please contact us at [email protected]. If we become aware that a user of the Services is under the age of 18 and has provided us with Personal Information without verifiable parental consent, we will delete such Personal Information from our files.
- Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials to enforce and comply with the law. We will disclose any information, including Personal Information, to government or law enforcement officials as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of ourselves or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
We may disclose information, including Personal Information, to take precautions against liability. You should also be aware that Providers may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities.
- Data Retention
You may review, update, correct or delete the Personal Information in your Account by contacting us or by editing it online. If you would like us to delete your Personal Information or any other information from our system, please contact us with such request. We are not responsible for removing information from the third parties that you have already shared information with.
- European Union Users
Data protection law in Europe requires a “lawful basis” for collecting and retaining personal information from citizens or residents of the European Economic Area. Our lawful bases include:
- Performing the contract we have with you: We need your personal data to comply with our contractual obligation to deliver the Services.
- Legitimate interests: This is a technical term in data protection law which essentially means we have a good and fair reason to use your data and we do so in ways which do not hurt your interests and rights. We sometimes require your data to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom or interests.For example, we use identity, device, and location information to prevent fraud and abuse and to keep the Services secure. We may also send you promotional communications about our Services, subject to your right to control whether we do so.We analyze how users interact with our Site so we can understand better what elements of the design are working well and which are not working so well. This allows us to improve and develop the quality of the online experience we offer all our users.
- Data Protection Authority
Subject to applicable law, if you are a citizen or resident of the European Economic Area, you also have the right to (i) object to Pathways’ use of your personal information and (ii) lodge a complaint with your local data protection authority or the United Kingdom Information Commissioner’s Office, which is Pathways’ lead supervisory authority in the European Union.
United Kingdom Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire
SK9 5AF, United Kingdom
Telephone: +0303 123 1113
Fax: 01625 524510
- Contacting us
Last Updated: May 21, 2018