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This privacy notice aims to provide information to you on how Path collects and processes your personal data, as the data controller, through your use of Path’s websites or our services, including any data you may provide, through any of the following websites, when you sign up to our newsletter, purchase a product or service, communicate with us or take part in a survey, pursuant to the provisions of the General Data Protection Regulation 2016/679 (GDPR). The present Privacy Notice covers any processing of personal data that takes place through any of the following websites owned and operated by Path:,,

The above websites are not intended for children.

Path respects your privacy and gives top priority to its requirement to comply with the applicable regulatory and legal framework on the protection of individuals with regard to the processing of their personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects to you.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice regarding the products and service that you purchase or that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

1. Who we are

Path Group Ltd, a private limited company, registered in the Companies House, headquartered in 35 Grafton Way, London, W1T5DB, United Kingdom, is the Data Controller of your personal data that you submit while using any of Path’s websites.

2. What personal data can be processed

Personal data is any data relating to a person who is identified or who can be identified (such as a name, an identification number, or an online identifier).

Personal data you provide

You may give us personal data about you by registering to Path and using our Services, or interacting with our websites, or by corresponding with us via email, phone or otherwise. Examples of personal data you may provide us include:

  • Identification data (first name, maiden name, last name, marital status, title, date of birth and gender, national ID or Passport number)
  • Contact data (billing address, delivery address, email address and telephone numbers)
  • User Profile data (username, password, purchases or orders made by you, feedback and survey responses)
  • Financial and Payment data (credit/debit card number, bank account number, account beneficiary)
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and/or our third party partners and your communication preferences

It is noted that you are required to inform Path timely for any possible change on the aforementioned data.

Personal data we collect from you

When you use our websites we may collect information such as:

  • Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to interact with or access our websites.
  • Usage Data  includes information about how you use our websites, products and services including your interests and preferences, through the use of Cookies and/or other tracking tools. Please see our cookie policy for further details.
  • Public Data related to you which are publicly accessible either electronically or otherwise.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We may collect any Special Categories of Personal Data about you (this 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) in cases where you provide us with such data to facilitate any special request you have in connection with the services and/or products provided to you.

We do not collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you or on your behalf (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us or a third party where we are acting as an agent but we will notify you if this is the case at the time.

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  1. Where we need to perform the contract we are about to enter into or have entered into with you
  2. 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.

  3. Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.



To register you as a new user or customer and to allow you to log in to your user account.

(a) Identity

(b) Contact

Performance of a contract with you

We process your personal data to the extent necessary for the proper provision of our Services to you and to fulfill the obligations we undertake to you by accepting our Terms and Conditions of Service. Specifically, we process your personal data for the following purposes:

  • Fulfilment of requests placed by you or on your behalf

  • Manage payments, fees and charges

  • Notify you about changes to our terms or privacy policy

  • Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

In addition, we process your personal data for the following purposes:

  • tailor the content and the services that you’re offered through the Website,

  • improve your experience and make our services better for you,

  • assess how you use the website and analyse that data,

  • take action if we need to defend our legal rights under the Terms and Conditions of Use if you would breach any laws or regulations or our Terms and Conditions of Service,

  • resolve potential requests/complaints of yours,

  • perform research and trend analysis to optimise your experience,

  • create content using some personal data will enable us to engage with you in a more personal way,

  • improve Path’s products and services according to your interests, your preferences and your overall transactional activity.

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

The processing of your personal data lies with the legitimate business interest of Path to constantly shield and continuously improve its products and services to meet the needs of its customers.

We also process your personal data in compliance with the obligations of the national legal and regulatory environment.

The processing of your personal data is necessary for Path to comply with the applicable legal and regulatory framework.

Finally, to the extent that a legal ground described above would not apply to processing of your personal information by us, we will seek your consent for such specific purpose in accordance with applicable law.

The processing of your personal data may be based on your explicit and up-to-date consent.

4. Recipients with whom your data can be shared

Recipients of the data that Path is obliged or entitled to disclose, by law or regulation or court order or in the context of lawful operation of the data subjects’ business and contractual relationship with Path, may be third parties (natural or legal persons), public authorities, services or other bodies, such as:

a. Third parties, natural or legal persons, acting by order and on behalf of Path where they help us to run our service or the technology systems that are needed to operate our App and services, including the following categories:

  • i. Contact center services and Customer relation management companies,
  • ii. Analysis and market research and product promotion companies,
  • iii. Data storage providers to safely and securely store your data,
  • iv. Email services e.g. to send you regular updates or communication,
  • v. Website and app analytics,
  • vi. Social Media Platforms via anonymised campaign-IDs so that we can provide relevant content to you on Social Media.

b. Supervisory, Judicial, Independent and Other Authorities at national and European level to meet Path’s obligation under law or regulation or court judgment.

In the event of data being transferred to third parties within the scope of data processing activities, then such third parties are obliged to adhere to the applicable legal and regulatory framework including the General Data Protection Regulation (2016/679) and have been contractually obliged to comply with all legal and regulatory requirements.

5. Provisions in the event of any personal data transmission to third countries (cross-border transmission)

In the context of Path’s operations your personal data might be transferred outside of the European Economic Area (EEA). If necessary, such transfer is effected in accordance with the provisions of European legislation on Companies registered in member states within the European Economic Area (EEA) or with the local legal framework as regards Companies registered outside the European Economic Area (EEA). Personal data may only be disclosed to third countries outside the European Economic Area (EEA), if the foreign law provides for an adequate level of data protection. In case the foreign law does not provide an adequate level of data protection, personal data may only be transferred to such country if either the data subject has explicitly consented to the transfer, or if data protection is provided for by an adequate data transfer agreement (i.e. if you, as the data subject, have explicitly given your consent for this transfer). Path ensures, through appropriate procedures, that the required procedures are carried out by the local authorities, as well as that each third party involved ensures the safe processing of personal data transmitted.

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Specifically, we use Mailchimp as an online marketing platform, please read their Privacy Policy available at

We also use Bluehost for website hosting services please read their Privacy Policy available at

6. Data retention period

Path processes your personal data as long as you retain your account with Path. In particular, your data is not being processed beyond the necessary period of time for the purposes described here.

If you delete your Path account or invoke your right to be forgotten, we will use reasonable endeavors to no longer process your data.

We may retain your personal data for a longer period as necessary to:

  • Maintain logs and business records for analysis, security and/or audit purposes, in non-identifiable form.

  • Comply with record retention requirements under the law

  • Deal with any complaints regarding the services provided,

  • Comply with our legal obligations, protect or defend our rights before a Judicial or other competent Authority and enforce our contracts.

7. Yours rights on the protection of your personal data

Following the verification of your identity, you, as a Data Subject, have the following rights:

Right to Information

Path must provide you with any information in relation to the processing of your personal data, including what data Path processes, for which purpose, for how long Path keeps them, in a concise, understandable and easily accessible form, using clear and simple wording.

Right of Access

You have the right to obtain from Path confirmation as to whether or not personal data of yours are being processed, and, if so, you have the right to access to the personal data.

Right to Rectification

You have the right to obtain from Path the rectification of inaccurate or incomplete personal data of yours and the right to have incomplete personal data completed.

Right to ErasureYou have the right to obtain from Path the erasure of your personal data, which can be met if certain conditions are met.
Right to RestrictionYou have the right to obtain from Path restriction of processing under certain conditions.
Right to ObjectYou have the right to object, at any time, to processing of personal data concerning you. Path shall then no longer process your Personal Data unless it demonstrates compelling legitimate grounds for the processing, which override the interests, rights and freedoms of yours or for the establishment, exercise or defense of legal claims.
Right to Obtain Human InterventionYou have the right to ask from Path not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Right to PortabilityYou have the right to ask from Path and receive your Personal Data that you have provided in a structured, commonly-used and machine-readable format or to ask Path to transmit those data to another controller.


In order to further facilitate the exercise of your relevant rights, Path ensures the development of internal procedures so as to respond timely and effectively to your relevant requests.

For issues concerning the processing of your personal data, you may contact us in writing by mail or email (35 Grafton Way, London, W1T5DB, United Kingdom or [email protected]).

In case that you consider that the protection of your data is in any way affected, you may also lodge a complaint with the Information Commissioner’s Office using the following contact details:

Tel: 0303 123 1113

8. Cookies

Path may collect data identification for visitors/users of its websites by using relevant technologies such as cookies and/or Internet Protocol (IP) address tracking. Cookies are small text files that are stored on the hard drive of each visitor/user and do not access any document or file from someone’s computer. They are used to facilitate visitor/user’s access to the use of specific services and/or site pages for statistical purposes and in order to determine the areas that are useful or popular, as well as to assess the effectiveness of the site and to improve the performance of the site. These data may also include the type of browser used by the visitor/user, the type of computer, its operating system, Internet service providers and other information of this kind. In addition, the site’s information system automatically collects information about the visitor/user’s site and about the links to third-party websites he may choose through the use of Path’s websites.

The visitor/user of the websites may be informed in detail about the categories of cookies used on Path ‘s websites through the relevant explanatory screen. Please note that cookies that are technically necessary to make the connection and navigation on the site or to provide the service cannot be deactivated. For the rest categories of cookies, which are optional, the visitor/user of the websites should choose whether they wish to activate them and, if so, provide their consent

If the visitor/user of the websites does not allow the use of optional cookies, then he may lose some additional information/functionality as mentioned in the cookie setup page.

By using optional cookies, Path can leverage the capabilities provided by Google Analytics, including Display Advertising, utilizing the remarketing features to promote its products and/or services in Internet. In particular, third-party vendors, including Google, display advertising messages from Path on various websites on the Internet. Path and third-party vendors, including Google, use cookies (such as the Google Analytics cookie) or third-party cookies (such as DoubleClick cookie) jointly to update, optimize, and serve promotional messages based on previous visits of someone on Path’s websites. Our visitors/users may declare that they do not wish to receive relevant messages and be excluded from future actions in Display Advertising and adjust Google Display Network ads using Ads Settings or activate, if they so wish, the Google Analytics opt-out browser add-on via the link link (looking for a further subscription at the hl = en).

The visitor/user of the Path website may delete the cookies and disable their use by selecting the browser he uses below and following the instructions:

  • Chrome
  • Safari
  • Firefox
  • Internet Explorer

If another browser is used, the user/visitor of the Path website should refer to the relevant information of its provider.

For more information and to customize your cookie preferences, please go to the “Cookies Settings” section of our website.

9. Update-amendment of the said statement on personal data privacy

Path may update, supplement and/or amend this Privacy Statement in accordance with the applicable regulatory and legislative framework. In this case, the updated Statement will be posted on the Path’s website.