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Privacy

Pathway First Limited Privacy Statement – (2025-04-29)

Introduction

This privacy statement explains the personal data we collect, why we collect it, who we share it with, how we use it and how we protect it.

Personal data we collect directly from you

When we collect personal data directly from you through our website, our email newsletter, on social media platforms, on landing pages, from surveys, conferences and over the phone, we use the data you provide for the following purposes:

To fulfil our contract with you or your employer to provide you with services you have requested, and in particular: –
- Maintaining our own records and databases
- Monitoring use of our products and services to ensure usage is in accordance with our terms and conditions of use
- Informing our business customers and prospective customers about our products and services
- Service providers that help determine your location based on your IP address in order to customise certain products to your location
- Publicly available sources
- Information generated by your usage of our products and services
- Information generated by the use of cookies on our website (see our separate Cookies Policy)
- Name and contact data, including first and last name, job title, email address, work postal address, work phone and if provided mobile ‘phone and similar contact data
- Demographic, including country, city and preferred language

For our own legitimate interests in: –
- To issue credentials, including passwords to allow you to access and operate your account
- To contact you about your subscription and to provide customer support services to you
- To carry out credit checks, to invoice you or your employer for any services you subscribe to and to collect payments due

Other sources of personal data

We also receive personal data from other sources which include:
- Service providers that help determine your location based on your IP address in order to customise certain products to your location
- Publicly available sources
- Information generated by your usage of our products and services
- Information generated by the use of cookies on our website (see our separate Cookies Policy)

The data we collect in this way includes the following:
- Name and contact data, including first and last name, job title, email address, work postal address, work phone and if provided mobile ‘phone and similar contact data
- Demographic, including country, city and preferred language

We use this personal data for the following purposes: –
- For our own legitimate interests in monitoring usage of our services and improving the service provided to our customers;
- Sending journalists press releases of interest
- Informing relevant prospective customers about our products and services

Who has access to your personal data?

We do not sell your personal information to third party companies. With the exception that we do collect the name, position and email of senior industry personnel for publication in our paid-for services.

We transfer personal data to the following categories of recipients: –
- Companies who we appoint under contract to host our services
- Companies or individuals who we appoint to provide services to us which include processing personal data
- Actual or potential business partners who need access to personal data to evaluate or carry out a business relationship or to conclude a transaction with us

Security and Safeguards

The safeguards we have put in place to ensure that our contractors and other third parties keep your personal data secure and confidential and use it only as authorised by us are as follows: –

We require all third parties to whom we disclose personal data to enter into a contract with us that includes confidentiality obligations
We carry out such due diligence as is reasonably necessary in relation to the technical and organisation measures used by our suppliers to ensure that personal data is processed securely
We may use data processors located outside the European Economic Area only after taking such steps as are required to ensure that personal data they process on our behalf receives protection equivalent to that provided in the EEA. Our processors are either certified as compliant with the EU-U.S. Privacy Shield Framework where they are located in the USA or have entered into an agreement with us containing the model clauses approved by the European Commission as providing contractual protection equivalent to that provided by the data protection regulations applicable in the EEA. To learn more about the Privacy Shield program, please visit www.privacyshield.gov

Retention period for personal data

We retain personal data for the following periods: –

For customers’ users we retain data while we are contracted. Post termination we will retain information in the same way as other prospective customers as follows.

For prospective customers we retain data for up to three years post receipt, renewed consent or customer contract termination.

For recipients of our e-news service we retain required personal data while they are receiving the service. Bouncing (invalid) emails and related personal details are retained for up to one year.

After that time, unless there is a need to retain that data for purposes connected with protecting our interests or those of third parties we will erase all data other than that needed to comply with our statutory obligations.

Identity of the data controller

The person who is the data controller and responsible for deciding how personal data is processed and for what purpose at Pathway First Limited, a company registered in England and Wales with its registered office Amington House, 95 Amington Road, Tyseley, Birmingham, B25 8EP, Pathway First Limited T/A Pathway Group. The individual responsible for data protection at Pathway First Limited is the Data Protection Officer.

Your rights

You have the following rights in relation to your personal data;

You have the right at any time to withdraw that consent at any time by using the ‘unsubscribe’ button at the bottom of one of our marketing emails or by replying to the email
You have the right to update and correct the personal information we hold about you. You also have the right to request from us all personal information that we hold that relates to you, to request restriction of the processing of that data and to request that we delete that data or object to continued processing where it is excessive or no longer required for the purpose for which it was collected. Where allowed by applicable law there may be an administrative charge for supply of copies of data and we may also require you to provide us with appropriate identification before we comply with this request. You may also have the right to data portability
If you have a complaint about the way in which we use your personal information you have the right to complain to the Information Commissioner www.ico.gov.uk

Changes to this Privacy Policy

This Privacy Statement will be updated from time to time to reflect changes in our business.

Contacting us

If you have any questions about anything in this Privacy Statement, please contact us at the below email, mail or telephone number.

The Data Protection Officer
Pathway First Limited
Amington House, 95 Amington Road, Tyseley, Birmingham, B25 8EP, Pathway First Limited T/A Pathway Group

Tel: 0121 7070 550
Email: info@pathwaygroup.co.uk

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