Privacy Policy

Last updated: 16 Feb 2024

This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through pathway.cc or any of the respective subdomains of pathway.cc website (“Site”). In this Privacy Policy “Pathway”, “we”, “us” or “our” means PATHWAY RESEARCH SOLUTIONS LTD, a private limited company registered in London, England with company number 14925007 and having its registered office at 8690 Paul Street, London, England, EC2A 4NE. When we collect, store, and use your personal information, we do so in accordance with the Data Protection Act 2018 and the UK General Data Protection Regulation UK GDPR. Additionally, for our operations or interactions involving the European Union, we adhere to the European Union General Data Protection Regulation EU 2016/679 (the GDPR).

Personal Information

The types of personal information or personal data we may collect about you include:

• your name;
• your contact details, including phone number;
• information about your company or team;
• your role within the company or team;
• your credit card information or details (stored securely with our third party payment service provider);
• your age and/or date of birth;
• your demographic information, such as age or gender;
• your preferences and/or opinions;
• information you provide to us through surveys;
• your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries, and/or browsing behavior;
• information about your access and use of our Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using, and the domain name of your Internet service provider;
• additional personal information that you provide to us, directly or indirectly, through your use of our Site, through being asked to participate in a survey by a business you are connected with, associated applications, associated social media platforms and/or accounts from which you permit us to collect information;
• files and assets provided to us by you (e.g. prototypes, image files, audio files, video files) either through direct upload or accessed through API integrations approved by you;
• any other personal information requested by us and/or provided by you or a third party.

We may collect these types of personal information directly from you or from third parties.

Collection and Use of Personal Information

We may collect, hold, use and disclose personal information for the following purposes:

• to enable you to access and use our Site;
• to provide full access to our service by collecting data around how users interact with Test Assets including, but not limited to, clicks, interactions, screen and component transitions, content, and prototype data;
• to contact and communicate with you;
• to contact you regarding user research participation opportunities;
• to provide our business clients with feedback regarding their products and services, where you have chosen to participate in user research;
• for internal record keeping and administrative purposes;
• for analytics, market research, and business development, including to operate and improve our Site;
• for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;
• to comply with our legal obligations and resolve any disputes that we may have.

Additional Limits on the Use of Your Google User Data

Pathway’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Disclosure of Personal Information to Third Parties

We may disclose personal information to:

• third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors, and payment systems operators;
• our employees, contractors, and/or related entities;
• our existing or potential agents or business partners;
• payment systems operators;
• sponsors or promoters of any competition we run;
• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
• credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
• courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights;
• third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you. This may include parties located, or that store data, outside of the UK;
• third parties to collect and process data, such as Google Analytics or other relevant businesses. This may include parties that store data outside of the UK.

Where we disclose your personal information to third parties, including data processors, we will request that the third party handle your personal information in accordance with this Privacy Policy.

Our Responsibilities as a ‘Controller’ under the GDPR

Controllers are defined by the GDPR as natural or legal persons, a public authority, agency, or other body to which personal information or personal data has been disclosed, whether via a third party or not, and who determines the purposes and means of processing personal information. We are a controller under the GDPR as we collect, use, and store your personal information to enable us to provide you with our goods and/or services.

As a controller, we have certain obligations under the GDPR when collecting, storing, and using the personal information of EU citizens. If you are an EU citizen, your personal data will:

• be processed lawfully, fairly, and in a transparent manner by us;
• only be collected for the specific purposes we have identified in the ‘collection and use of personal information’ clause above and personal information will not be further processed in a manner that is incompatible with the purposes we have identified;
• be collected in a way that is adequate, relevant, and limited to what is necessary in relation to the purpose for which the personal information is processed;
• be kept up to date, where it is possible and within our control to do so (please let us know if you would like us to correct any of your personal information);
• be kept in a form which permits us to identify you, but only for so long as necessary for the purposes for which the personal data was collected;
• be processed securely and in a way that protects against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

Our Responsibilities as a ‘Processor’ under the GDPR

Where we are a processor, we have contracts containing certain prescribed terms in our contracts with controllers (such as businesses that ask us to help them conduct surveys testing their products and services). Depending on the circumstances, we can be a controller or processor or controller and processor.

In addition to our contractual obligations with controllers (where we are solely a processor) and our legal obligations under the GDPR as a controller (where we are both a controller and processor), as a processor we also have the following responsibilities under the GDPR:

• not to use a sub-processor without the prior written authorisation of the data controller;
• to co-operate with supervisory authorities;
• to ensure the security of its processing;
• to keep records of processing activities;
• to notify any personal data breaches to the data controller;
• to employ a data protection officer and appoint (in writing) a representative within the European Union if required by the GDPR.

Your Rights and Controlling Your Personal Information

Choice and Consent

Please carefully read this Privacy Policy. By providing us with personal information, you consent to the collection, storage, use, and disclosure of your personal information in accordance with this Privacy Policy. If you are under 16 years old, you must have your parent or legal guardian's permission to access and use the Site. Your parent or guardian must also consent to you providing us with your personal information. Providing personal information is optional, but not doing so may impact your use of this Site and the products/services offered on or through it.

Information from Third Parties

If we receive personal information about you from a third party (such as from a business you are connected with, where that business would like you to participate in a survey or interview), we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict

You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below, or use the functionality provided on your member dashboard (if you are a member) to control how we process your personal information.

Access and Data Portability

You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party (data portability).

Correction

If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details below (or use the functionality on your member dashboard, if you are a member). We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

Complaints

If you believe that we have breached any UK Data Protection policies or an article of the GDPR and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint.

Unsubscribe

To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Storage and Security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic, and managerial procedures such as the pseudonymization and encryption of personal information, to safeguard and secure personal information and protect it from misuse, interference, loss, and unauthorized access, modification and disclosure. We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorized disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Cookies and Web Beacons

We may use cookies on our Site from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our Site or our Sub-brand Sites with personal information, this information may be linked to the data stored in the cookie. We may use web beacons on our Site or our Sub-brand Sites from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behavior and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

Links to Other Websites

Our Site may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy. We will notify you if we amend this Privacy Policy, by contacting you through the contact details you have provided to us. Any amended Privacy Policy is effective once we notify you of the change. For any questions or notices, please contact our Privacy Officer at:

Pathway Research Solutions LTD
8690 Paul Street, London, England, EC2A 4NE
privacy@pathway.cc