Privacy Policy

1. Introduction

This Privacy Notice describes how PathBuilder, LLC ("PathBuilder," "we", "us" or "our") handles personal data that we collect through our websites and mobile applications that link to this Privacy Notice (collectively, the "Service"), as well as through our marketing and other activities described in this Privacy Notice. Use of the Service is subject to our SaaS Services Agreement.

California residents: See our California privacy notice for information about your personal information and privacy rights.

If you have any questions or concerns about our use of your personal data, please contact us.

2. Scope of this Privacy Notice

PathBuilder provides businesses with a cloud-based employee development hub that their employees use for goal setting and development plans. The Service is not intended for use by individuals for personal, family, household, or other consumer purposes, and the personal data covered by this Privacy Notice pertains to individuals acting in a business or commercial capacity. This Privacy Notice does not apply to personal data about PathBuilder personnel or job candidates, or to personal data that PathBuilder processes on behalf of customers in our capacity as a processor or service provider.

3. Personal Data We Collect

The personal data we collect from you, either directly or indirectly, will depend on how you interact with us and with our Service. We collect personal data about you from the following sources:

Information you provide to us

Personal data you may provide to us through the Service, at our online or offline events, through our promotions and surveys, when visiting our offices, or otherwise includes:

• Contact data: Your full name, professional title, organization name, email address, mailing address, phone number, social media handle, and other contact details.
• Account data: Your full name, email address, the password for your Service account, your country, and any other information you choose to add to your Service profile or associate with your account, such as your avatar, industry, country, pronouns, birthdate, personal goals, professional goals, or hobbies.
• Transaction data: Any payment card data or banking details you chose to use to pay for the Service, and information about your transactions with us.
• Communications data: Information in your communications with us, including when you communicate with us through the Service, social media, events, or otherwise; respond to surveys; provide feedback; or post to our blogs/forums.
• Security data: Security camera footage of our offices, facilities and event spaces.
• Referral data: Contact details of friends or contacts that you refer to us or that refer you.

Information automatically collected

As you navigate the Service, our communications, and other online services, we, our service providers, and our advertising partners may automatically collect information about you, your computer or device, and your browsing actions and usage activity, such as:

• Device data: Technical information about your computer or mobile device, including operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type, IP address, unique device identification numbers or other identifiers, language settings, mobile device/cellular carrier, radio/network information, and general location information associated with IP address.
• Usage data: Page and screen views, search terms, authentication details, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages/screens, information about your activity on a page/screen, access times and duration of access, whether you have opened our emails or clicked links within them, and other functional information on Service performance.

Cookies and other technologies

Some of the information we collect automatically is captured using cookies and other technologies as described in our Cookie Notice.

Third party sources

We combine personal data we receive from you or collect automatically when you use the Service with personal data we obtain from other sources, such as:

• Our business contacts who share details about their professional contacts and friends
• Public sources, including government records and social media
• Data brokers who provide contact details and biographical details
• Authentication services you can use to log into the Service
• Social media accounts that you connect to the Service

4. How We Use Your Personal Data

We use your personal data for the following purposes or as otherwise described in this Privacy Notice or at the time of collection:

• Service delivery: To register your Service account, manage and administer your Service account, provide the Service and to communicate with you about our Service.
• Business operations: To administer and maintain our Service and our IT systems and to operate our business.
• Research and development: For research and development purposes, including to analyze and improve the Service and our business.
• Marketing: As permitted by applicable law, to send you marketing emails or contact you by phone about our and/or our partners' products, services or events.
• Targeted advertising: Our third-party advertising partners may use cookies and similar technologies to collect information about your use of the Service.
• Compliance and protection: To comply with applicable laws, lawful requests, and legal process, and to protect our, your or others' rights, privacy, safety, or property.

5. How We Share Your Personal Data

We may share your personal data with the following categories of recipients:

• Affiliates: Corporate affiliates that we control, are controlled by, or with which we are under common control.
• Service providers: Third parties that provide services on our behalf or help us operate the Service or our business.
• Payment processors: Third party payment processors, such as Stripe, that collect your payment card data.
• Authentication services: When you log into the Service using third party credentials.
• Advertising partners: Third party advertising companies for targeted advertising purposes.
• Other users and the public: Other users of our blogs and forums to which you post content.
• Professional advisors: Lawyers, auditors, and bankers where necessary.
• Authorities and others: Law enforcement, government authorities, and private parties as we believe necessary.
• Business transferees: Parties to business transactions involving a corporate divestiture, merger, consolidation, acquisition, etc.

6. Your Choices

• Access or update your information: You may review and update certain Service account information by logging into your account.
• Opt-out of marketing communications: You may opt-out of marketing emails at any time by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us.
• Request deletion: You may request deletion of your information by contacting us with your request.
• Cookies: Most browsers let you remove or reject cookies. See our Cookie Notice for more information.
• Do Not Track: We currently do not respond to "Do Not Track" signals.

7. Other Sites and Services

The Service may contain links to or integrations of websites and other online services operated by third parties. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or other online services operated by third parties, and we are not responsible for their actions.

8. Security and Retention

We use technical and organizational safeguards designed to protect the personal data we collect and process about you. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal data.

We retain personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

9. International Data Transfers

We are headquartered in the United States and may use service providers that operate in the United States and other countries other than the country in which you are resident. These countries may have data protection laws that differ from those of your country.

10. Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child under 18 from whom you believe we have collected personal data in a manner prohibited by law, please contact us.

11. Changes to this Privacy Notice

We reserve the right to modify this Privacy Notice at any time. If we make material changes to this Privacy Notice, we will notify you by updating the date of this Privacy Notice and posting it on the Service or other appropriate means.

12. How to Contact Us

If you have questions or concerns about this Privacy Notice or our practices, please contact us at help@PathBuilderapp.com or by mail to: PathBuilder, LLC, c/o Hagenauer Law, 230 Fulton Street East, Grand Rapids, Michigan 49503.

13. California Privacy Notice

This notice describes our collection, use and disclosure of personal information of California residents in our capacity as a "business" under the California Consumer Privacy Act ("CCPA") and their rights with respect to their personal information.

Information Practices

The following describes our practices currently and during the past 12 months:

Sales and Sharing of Personal Information

Our use of the targeted advertising services described above may constitute the "sharing" or "sale" of personal information under the CCPA. We do not have actual knowledge that we have sold the personal information of California residents under the age of 18.

Your Privacy Rights

As a California resident, you have the following rights under the CCPA:

• Right to know: You can request information about the categories of personal information that we have collected.
• Right to access: You can request a copy of certain personal information that we have collected about you.
• Right to deletion: You can request that we delete personal information that we collected from you.
• Right to correction: You can request that we correct inaccurate personal information that we have collected about you.
• Nondiscrimination: You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

Exercising Your Rights

You may submit requests to exercise your rights by contacting us. We need to verify your identity to process your requests. We may require you to provide identifiers we can match against information we have collected from you previously.

14. Notice to European Users

Our Services are intended for use only in the United States and are not directed to individuals located outside of the United States, including in the European Economic Area (EEA). We do not knowingly collect or process personal data of individuals in the EEA.