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Pathlitics Privacy Policy

Last modified: February 14, 2023

Introduction

Pathlitics LLC (“Company” or ”We”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.pathlitics.org or any of our related services, such as the Company mobile application, along with any related software or Company servers (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy is incorporated under our Terms of Use available at www.pathlitics.org/terms. Capitalized terms not defined here shall have the meanings assigned to them in the Terms of Use.

This policy applies to information we collect:

  • On this Website.

  • In email, text, and other electronic messages between you and this Website.

  • Through mobile and desktop applications you download from this Website or any third- party application store, which provide dedicated non-browser-based interaction between you and this Website.

  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy and/or the Website.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Company or any third party; or

  • Any third party, including through any application or content (including advertising) that may link to or be accessible from the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

PLEASE NOTE THAT (I) PATHLITICS PARTNERS WITH SCHOOLS AND OTHER SPONSOR ORGANIZATIONS TO PROVIDE SERVICES THAT BENEFIT OUR USERS AND AS PART OF THOSE SERVICES WE MAY SHARE CERTAIN INFORMATION ABOUT YOUR INTERESTS WITH YOUR SCHOOL OR THE ORGANIZATION OR ENTITY THAT PROVIDED YOU WITH REGISTRATION INFORMATION ABOUT THE WEBSITE; AND (II) INFORMATION YOU POST TO THE WEBSITE WILL BE VIEWABLE BY OTHER USERS OF THE WEBSITE AND IT IS UP TO YOU HOW MUCH PERSONAL INFORMATION ABOUT YOURSELF YOU WISH TO DISCLOSE IN THE CONTENT YOU POST. THE INFORMATION YOU CHOOSE TO DISCLOSE IS AT YOUR DISCRETION AND, OTHER THAN WITH RESPECT TO INFORMATION WE SHARE WITH YOUR SCHOOL AND/OR SPONSORING ORGANIZATION, IF YOU WISH TO REMAIN ANONYMOUS WE RECOMMEND THAT YOU DO NOT REVEAL YOUR NAME, ADDRESS OR OTHER PERSONAL DETAILS ABOUT YOURSELF WHEN POSTING INFORMATION ON THE WEBSITE.

If you registered for the website independently of any invitation, link or registration code provided by your school or another of our partner organizations, we will not share information about you with your school or any organization outside of your specific authorizations, provided that information you publicly post to the Website may be seen by other users as described herein.

Users Under the Age of 13

Our Website is not intended for children or anyone under 13 years of age. No one under age 13 may provide any information to the Website. We do not knowingly collect personal information from users under 13. If you are under 13, do not use or provide any information on this Website, register on the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@pathlitics.org.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State Privacy Rights for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information by which you may be personally identified, such as name, e-mail address, telephone number or other information or identifiers from which a person can be identified (“personal information”). Personal information does not include data that is about you but does not identify you individually, such as aggregate data about the number of users that have reviewed or commented on a particular school or business. 

We collect this information:

  • Directly from you when you provide it to us.

  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

  • From third parties, such as Company partner organizations, for example, your school’s guidance counselor to the extent your school is a Website member or has partnered with Company.

  • From online service providers such as Google Analytics.

Information You Provide to Us 

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, applying for a Unit, posting User-Provided Materials, or requesting further services. We may also ask you for information when you report a problem with our Website.

  • Records and copies of your correspondence (including email addresses), if you contact us.

  • Details of transactions and payments you carry out through our Website. You may be required to provide financial information before placing an order through our Website or receiving payments from Company.

  • Your search queries on the Website.

You also may provide User-Provided Materials to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties. This means that among other things, your User-Provided Materials will be visible to other users of the Website, including users from your school, employer or other partner organization.  Your User-Provided Materials are posted on and transmitted to others at your own risk. Please note we cannot control the actions of other users of the Website with whom you may choose to share your User-Provided Materials. Therefore, we cannot and do not guarantee that your User-Provided Materials will not be viewed by unauthorized persons. 

Information We Collect Through Automatic Data Collection Technologies 

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  •  Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.

  • Store information about your preferences, allowing us to customize our Website according to your individual interests.

  • Speed up your searches.

  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

  • Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers, including, but not limited to Google Analytics. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

Information About You We May Receive from Third Parties

We may receive personal data about you from various third parties and public sources including, but not limited to:

  • Your school to the extent your school is a Website user or partner organization of Company

  • A Company partner organization, such as an advocacy organization or independent college counselor, with which you have a relationship and which has referred you to Company or the Website

  • third party payment processors

  • analytics providers such as Google

  • advertising networks such as Google, Bing, Facebook and Instagram

 

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.

  • To provide you with information, products, or services that you request from us.

  • To fulfill any other purpose for which you provide it.

  • To provide you with notices about your account.

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

  • To notify you about changes to our Website or any products or services we offer or provide though it.

  • To allow you to participate in interactive features on our Website.

  • In any other way we may describe when you provide the information.

  • For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please check or un-check the relevant box located on the form on which we collect your data. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.

  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Website users is among the assets transferred.

  • To fulfill the purpose for which you provide it.

  • For any other purpose disclosed by us when you provide the information.

  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

  • To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

  • Promotional Offers and Marketing Messages from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking or un-checking the relevant box located on the form on which we collect your data, or at any other time by changing your account settings or sending us an email stating your request to support@pathlitics.org. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a purchase, payment, product service experience or other transactions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah may have additional personal information rights and choices. Please see Your State Privacy Rights for more information

Accessing and Correcting Your Information

You may be able to review and change elements of your personal information by logging into the Website and visiting your account profile page.

You may also send us an email at support@pathlitics.org to request access to, correct or delete any personal information that you have provided to us. In some instances we may not be able to delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User-Provided Materials from the Website, copies of your User-Provided Materials may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Access and use of information provided on the Website, including User-Provided Materials, is governed by our Terms of Use.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

California Consumer Privacy Act

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to access and control Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a federal privacy law.

Categories of Personal Information Collected and Disclosed

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. During the 12 months leading up to the effective date of this Privacy Policy, we collected or may have collected the information described below from and about users. We may use any and all of the information for any of the purposes described in this policy, unless limitations are listed. The categories we use to describe the information are those enumerated in the CCPA.  We may disclose this data to third parties as described in this Privacy Policy

        _____

Your Rights And Choices under the CCPA

i. Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of Personal Information we collected about you.

  • The categories of sources for the Personal Information we collected about   you.

  • Our business or commercial purpose for collecting or selling that Personal information.

  • The categories of third parties with whom we share that Personal Information.

  • The specific pieces of Personal Information we collected about you (also called a data portability request).

  • The categories of third parties to whom the consumer’s Personal Information has been sold and the specific categories of Personal Information sold to each category of third party.

ii. Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

iii. Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, send an email to support@pathlitics.org.

 

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

When you submit your request, we will take steps to attempt to verify your identity. We will seek to match the information in your request to the Personal Information we maintain about you. As part of our verification process, we may ask you to submit additional information, use identity verification services to assist us, or if you are registered customer, we may ask you to sign in to your account as part of our identity verification process. Please understand that, depending on the type of request you submit, to protect the privacy and security of your Personal Information, we will only complete your request where we are satisfied that we have verified your identity to a reasonably degree of certainty.

 

iv. Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

v. Non-Discrimination

We will not discriminate against you for exercising any of your applicable CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

vi. Opt Out of the ‘Sale’ of Your Personal Information

As defined under the CCPA, Company does not sell your information.  

Rights for Users in Other States

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

  • Confirm whether we process their personal information.

  • Access and delete certain personal information.

  • Data portability.

  • Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

  • Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.

  • Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights please send an email to support@pathlitics.org. To appeal a decision regarding a consumer rights request send an email to legalnotices@pathlitics.org.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted by Company or our applicable payment processor using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

755 West Lancaster Avenue #1015, Bryn Mawr, PA 19010; inquiries@pathlitics.org; (856) 376-0758.

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