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Privacy Policy

1. INTRODUCTION
Pathways Global Limited (“We”, “Us”, “Our”) are committed to protecting and respecting your privacy.
This policy (together with our Terms of Website Use https://www.growthpathways.com/terms-of-use and any other documents referred to) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us including any information you may provide through our site when you purchase a product or service or sign up to any of our free content.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

By providing us with your data, you warrant to us that you are over 13 years of age.

Pathways Global Ltd is the data controller and we are responsible for your personal data. Our registered office is 2nd Floor, The Gallais Building, 54 Bath Street, St Helier, Jersey, JE1 1FW and our main trading address is 1st Floor, The Gallais Building, 54 Bath Street, St Helier, Jersey, JE1

To contact us, please telephone our customer service line +44 20 3962 1238 or email support@growthpathways.com.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at support@growthpathways.com.


2. INFORMATION WE MAY COLLECT FROM YOU
Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may collect and process the following types of personal data about you:

  • Information you give us. You may give us information about you by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you subscribe to our services, place an order on our site, participate in blogs or other interactive services on our site, and when you report a problem with our site. The information you give us may include;
    • Identity Data which may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
    • Contact Data which may include your billing address, delivery address, email address and telephone numbers.
    • Financial Data which may include your bank account and payment card details.
    • Transaction Data which may include details about payments between us and other details of purchases made by you.
    • Profile Data which may include your purchases or orders, your interests, preferences, feedback and survey responses.
    • Marketing and Communications Data which may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
  • Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
    • Technical Data which may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
    • Usage Data which may include information about how you use our website, products and services including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

Sensitive Data
We DO NOT collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.


3. HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you through a variety of different methods including:

  • Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
    • order our products or services;
    • create an account on our site;
    • subscribe to our service or publications;
    • request resources or marketing to be sent to you;
    • enter a competition, prize draw, promotion or survey; or
    • give us feedback.
  • Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our https://www.growthpathways.com/cookie-policy for further details.
  • Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from analytics providers such as Google Analytics based outside the European Union (“EU”);
    • Search Information providers such as Google Search based outside the EU;
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Swipe based outside the EU.
    • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when legally permitted. The most common uses of your personal data are:

  • Where we need to perform the contract between us.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at support@growthpathways.com.

If we do not have the personal data about you that we need to meet our statutory or contractual obligations, we may not be able to provide you with products or services.

Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at support@growthpathways.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing
To register you as a new customer (a) Identity
(b) Contact		 Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us		 (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
 (a) Performance of a contract with you
(b) Necessary for our legitimate interests to recover debts owed to us
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
 (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
 (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services
To enable you to partake in a prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
 (a) Performance of a contract with you
(b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
 (a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure and understand the effectiveness of our advertising (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
 Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage		 Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile		 Necessary for our legitimate interests to develop our products/services and grow our business


Marketing communications
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

We will get your express opt-in consent before we share your personal data with any third party for their marketing purposes.

You can ask us to stop sending you marketing communications at any time by following the opt-out links on any marketing message sent to you OR by emailing us at support@growthpathways.com at any time.

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.


5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with third parties set out below;

  • Service and platform providers who provide IT, CRM and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • Government Bodies including the Comptroller of Income Tax in Jersey, Jersey Customs & Immigration Service, the Jersey Financial Services Commission and other regulators and authorities based in Jersey, Channel Islands and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you
  • Analytics and Search Engine providers that assist us in the improvement and optimisation of our site.
  • Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.
  • Subsidiary companies owned by us.
  • If we are under a duty to disclose or share your personal data in order to comply with an legal obligation, or in order to enforce or apply our Website Terms and Conditions of Use and other agreements; or to protect the rights, property, or safety of Pathways Global Limited, our customers, or others. This includes exchanging information with other companies and organisation for the purposes of fraud protection and credit risk reduction.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.


6. INTERNATIONAL TRANSFERS
Countries outside of Jersey and the EU do not always offer the same levels of protection to your personal data, so Jersey law has prohibited transfers of personal data outside of Jersey and the EU unless the transfer meets certain criteria.

Many of our third parties service providers are based outside Jersey and the EU so their processing of your personal data will involve a transfer of data outside Jersey and the EU.

Whenever we transfer your personal data out of Jersey and the EU, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

  • We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission or the Office of the Information Commissioner in Jersey which give personal data the same protection it has in Jersey and the EU; or
  • Where we use providers based in the United States (the “US”), we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
    If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

7. DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed without authorisation. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


8. DATA RETENTION
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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.


9. YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

If you wish to exercise any of the rights set out above, please email us at support@growthpathways.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Office of the Information Commissioner, the Jersey supervisory authority for data protection issues (https://oicjersey.org/guidance/) We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.


10. THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.


11. COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please read our https://www.growthpathways.com/cookie-policy.


12. CHANGES TO OUR PRIVACY POLICY
Any changes we may make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes. This privacy policy was updated JUNE 2020.