Privacy and Cookie Notice

Pathways Digital values your privacy. This Privacy Notice ("Notice") describes how Pathways Digital collects, stores, uses, and discloses your Personal Data. "Personal Data" means any information relating to an identified or identifiable individual. "Pathways Digital" in this Notice refers to the relevant Pathways Digital company(ies) processing your Personal Data.

This Notice governs Pathways Digital's collection and processing of your Personal Data in the context of your interactions with Pathways Digital, including where you visit Pathways Digital's website ("Site"), receive marketing communications, do business with Pathways Digital on behalf of your organization, or are a user of a Pathways Digital service procured by your Organization and Pathways Digital collects and processes Personal Data related to your use of such service.

This Notice does not apply where your Personal Data is submitted to Pathways Digital's Services for processing by Pathways Digital on behalf of your Organization. In that context, Pathways Digital will process your Personal Data pursuant to the terms of the Data Processing Agreement in place between your Organization and Pathways Digital. This Notice does not govern Pathways Digital's collection and processing of Personal Data in the context of employment or candidacy for employment.

What Information Does Pathways Digital Collect About You and Why?

Pathways Digital may ask you to provide Pathways Digital with Personal Data about yourself in order to provide services to you. If you choose not to provide Personal Data that Pathways Digital has asked for, it may delay or prevent Pathways Digital from providing services to you. Pathways Digital may collect the following categories of Personal Data about you:

personal and business identifiers and contact information such as name, job title, company name, contact, shipping and billing information, phone number, email address, photographs, and contact preferences;
internet or other electronic network activity, i.e. technical data such as domain name, browser type and operating system, web pages you view; links you click; your device's IP address; login data e.g. username, account number, password; the length of time you visit Pathways Digital's Site; the URL or the webpage that led you to Pathways Digital's Site;
performance and usage data about your use of Pathways Digital's Services; information you provide to Pathways Digital to receive technical assistance or during customer service interactions; your interests, demographics, experience with Pathways Digital's Services, contact preferences and what you enter into any 'free text' boxes in Pathways Digital's forms;
commercial information, i.e. transactional data including credit card and payment data, transaction history; and
Personal Data disclosed by you on message boards, chat features, blogs and other services or platforms to which you are able to post information and materials (including third-party services and platforms). Pathways Digital also may record its telephone or other communications with you, to the extent permitted by applicable law.

Personal Data may be required to determine access eligibility for certain restricted parts of Pathways Digital's Site or services. Personal Data about you collected on-line may be combined with information provided off-line or collected from trusted third party sources.

Information Pathways Digital Collects Directly From You. Pathways Digital collects Personal Data about you when you visit Pathways Digital's Site, register or subscribe for Pathways Digital's services, purchase Pathways Digital's products or services, request marketing or publications to be sent to you, give Pathways Digital feedback on Pathways Digital's products, services or Site, sign up for an event or webinar, have phone calls with sales representatives, or when you contact customer support.

Information Pathways Digital Collects From a Third Party. Pathways Digital also may collect Personal Data about you from third party sources, such as someone authorized by you to act on your behalf, third-party services that you use that utilize or interact with Pathways Digital's services, or where your Personal Data is provided to us by an event partner. Pathways Digital may also collect your Personal Data from other sources as and when permitted by applicable laws, such as public databases, joint marketing partners, and social media platforms.

Information Pathways Digital Collects Automatically, including via Cookies and Similar Tracking Technologies. Pathways Digital may automatically collect information about your use of Pathways Digital's Site, or services through cookies, web beacons, and other technologies. Pathways Digital may combine this information with other information that Pathways Digital has collected about you. Please see Pathways Digital's Cookie Notice section later in this document.

How Does Pathways Digital Use Your Information?

Pathways Digital uses the information collected about you as appropriate and relevant for the following commercial purposes:

to register you as a new customer;
to enable you to order products or services
to provide services to you, including programs, online services and customer support;
to allow you to make requests, and register for customized communications programs;
to customize the content and information that Pathways Digital may send or display to you;
for marketing and promotional purposes;
to assist Pathways Digital in advertising Pathways Digital's products and services on third-party websites;
to follow up with you after conferences and events;
to post testimonials on Pathways Digital's online properties and, subject to your consent, to use your name with your testimonial;
to interact on third-party social networks (subject to that network's terms of use);
to provide online communities and blogs;
to facilitate the delivery of education and training

Such information may include among others, your name, location and business contact information, information related to the Services you are using, preferences you have selected while visiting the Site, message content and network identifiers related to contacting Pathways Digital or using the Site.

Pathways Digital uses the information collected about you as appropriate and relevant for the following business purposes:

to better understand how users access and use Pathways Digital's Site, products, and services and for other research and analytical purposes, including data analysis, audits, fraud monitoring and prevention, developing new products or improving existing ones, enhancing, improving or modifying the Site, identifying usage trends, determining the effectiveness of Pathways Digital's promotional campaigns and operating and expanding Pathways Digital's business activities;
to manage Pathways Digital's relationship with you which may include notifying you about changes to Pathways Digital's terms or this Notice;
for compliance with applicable law, including laws outside your country of residence;
to comply with legal process;
to enforce Pathways Digital's contracts;
to protect Pathways Digital's operations or those of any of Pathways Digital's affiliates;
to defend against or pursue legal claims;
to protect Pathways Digital's employees, rights, privacy, safety, security, property, facilities and/or that of Pathways Digital's affiliates or others;
to facilitate the delivery of Services.
to provide quality control related and staff training
to protect Pathways Digital's employees, Services, Site and facilities
to the extent necessary and proportionate to prevent fraud and ensure network and information security

Such information may include among others, your name, location and business contact information, information related to the services you are using, preferences you have selected while visiting Pathways Digital's website, messages content and network identifiers related to you contacting Pathways Digital or using Pathways Digital's websites.

De-Identified Data. Pathways Digital will not attempt to re-identify de-identified data unless it is reasonably necessary for security or fraud prevention purposes.

Sensitive Personal Data. Pathways Digital will only process any special categories of Personal Data ("Sensitive Personal Data") relating to you for specific purposes outlined above or in relevant supplemental notices, because either: 1. You have given Pathways Digital your explicit consent to process that information; or 2. The processing is necessary to carry out Pathways Digital's obligations under applicable law; 3. The processing is necessary for the establishment, exercise or defense of legal claims; or 4. You have made the information public.

Legal Basis of Processing

In order to collect, use and otherwise process your Personal Data for the above listed commercial and business purposes, Pathways Digital may rely on the following legal bases as appropriate and relevant in the specific context:

Pathways Digital's legitimate interest in providing the Sites and making the Services available to you, provided Pathways Digital's interest is not outweighed by the risk of harm to your rights and freedoms.
Your consent, where Pathways Digital has obtained your consent to process your Personal Data for certain activities. You may withdraw your consent at any time by using the contextual preference tools available in the communications or in the user interfaces of the products and services Pathways Digital provides to you. Absent those, please contact Pathways Digital as explained below. However, please note that your withdrawal of consent will not affect the lawfulness of any use of your Personal Data by Pathways Digital based on your consent prior to withdrawal.
To fulfill any contractual obligations, such as where you have purchased a product or service from Pathways Digital.
For compliance with Pathways Digital's legal obligations where applicable laws require Pathways Digital to process your Personal Data.

Legal Basis of Processing Of Personal Data For The Purposes Of Fraud Prevention And Network and Information Security as part of Pathways Digital's Services

Pathways Digital processes Personal Data for fraud prevention and network and information security purposes when providing Services. Pursuant to applicable privacy legislation, organizations have a recognized legitimate interest in collecting and processing Personal Data to the extent necessary and proportionate for preventing fraud and ensuring network and information security. Network and information security means the ability of a network or of an information system to resist events, attacks or unlawful or malicious actions that could compromise the availability, authenticity, integrity and confidentiality of stored or transmitted data, or the security of the related services offered by, or accessible via those networks and systems.

The Personal Data Pathways Digital processes for the prevention of Fraud includes, but is not limited to:

Information related to electronic means of payment and related entitlements;
Information related to electronic payment transactions;
Contextual signals and indicators of suspected fraud;
Verification information to confirm or dispel suspected fraud; and
Evidence of suspected, detected and/or confirmed fraud.

The Personal Data Pathways Digital processes for network and information security purposes include, without limitation, network traffic data related to Cybersecurity Threats such as:

sender email addresses (e.g., of sources of SPAM);
recipient email addresses (e.g., of victims of targeted email cyberattacks);
reply-to email addresses (e.g., as configured by cybercriminals sending malicious email);
filenames and execution paths (e.g., of malicious or otherwise harmful executable files attached to emails);
URLs and associated page titles (e.g., of web pages broadcasting or hosting malicious or otherwise harmful contents); and/or
IP addresses (e.g., of web servers and connected devices involved in the generation, distribution, conveyance, hosting, caching or other storage of Cybersecurity Threats such as malicious or otherwise harmful contents).

Depending on the context in which such data is collected, it may contain Personal Data concerning you or any other data subjects. In such cases Pathways Digital will process the Personal Data concerned only to the extent necessary and proportionate to the purposes of detecting, blocking, reporting and mitigating the Fraud or Cybersecurity Threat of concern to you, and to all organizations relying on Pathways Digital's products and services to secure their payment transactions and information networks and systems. When processing Personal Data in this context, Pathways Digital will only seek to identify data subjects:

to the extent that it is an inherent part of the Services Pathways Digital provides to its customers and is indispensable to the prevention of the Fraud and/or the remediation of the Cybersecurity Threat concerned, or
if and as required by law.

If you believe that your Personal Data was unduly collected or is unduly processed by Pathways Digital for such purposes, please refer to the "Your Rights" and "Contact Pathways Digital" sections below. Please be aware that if it is determined that Personal Data concerning you is processed by Pathways Digital because it is critical for the prevention of, or the detection, blocking or mitigation of Cybersecurity Threats, then in certain cases the legitimate interest to pursue such processing may be compelling enough to override access, objection, rectification or erasure requests related to the data concerned

To Whom Does Pathways Digital Disclose Your Information And Why?

Pathways Digital may disclose Personal Data collected about you as follows:

Service Providers. Data Pathways Digital collects about you may be disclosed to third party vendors, service providers, contractors or agents who perform functions on Pathways Digital's behalf.

Personal data collected through and for the purposes of user-requested alerts and service notifications, including but not limited to short code text messages, will not be disclosed, shared, sold or rented to any affiliated or unaffiliated third parties for marketing purposes.

Business Transfers. Personal Data Pathways Digital has collected about you may be transferred to another company as part of a merger, acquisition or divestiture by or of that company.

Consent. Pathways Digital may disclose your personal information to other recipients for any purpose with your consent.

Legal Obligations and Rights. Pathways Digital may disclose your Personal Data to any legally entitled recipients: (i) in connection with the establishment, exercise or defense of legal claims; (ii) to comply with laws or to respond to lawful requests or legal process; (iii) for fraud or security monitoring purposes (e.g., to detect and prevent cyberattacks); (iv) to protect the rights of Pathways Digital or its employees; or (v) as otherwise permitted by applicable law.

If Pathways Digital discloses your Personal Data, to the extent reasonably practicable and permissible, Pathways Digital will require its recipients to comply with adequate privacy and confidentiality requirements, and security standards.

When you visit a Pathways Digital Site, cookies, if any, will be used in accordance with Pathways Digital's Cookie Notice & Policy (see below), and in line with your cookie choices made in the cookie management tool. Pathways Digital does not sell your Personal Data for money, however use of some cookies may constitute "selling" or "sharing" Personal Data under the California Privacy Rights Act. If you do not wish Pathways Digital to "sell" or "share" your data in the meaning of the California Privacy Rights Act, you may use the Do Not Sell or Share button available in the website's cookie management tool at any time to turn off cookies. If Pathways Digital recognizes the Global Privacy Control (GPC) signal or Do Not Track signal from your browser, Pathways Digital will disable non-essential cookies. See Pathways Digital's Cookie Notice & Policy section below for more information.

What About Links To Other Websites?

Pathways Digital's Site and services may contain links to third party websites for your convenience. Any access to and use of such linked websites will cause you to leave the Site. Third party websites, even if potentially serving content co-branded by Pathways Digital, are not governed by this Notice, but instead are governed by their own privacy notices. Pathways Digital recommends that you check the privacy notices of every third party website you visit before providing any Personal Data. Pathways Digital does not control those third party websites and are not responsible for their content or their privacy practices. Thus, Pathways Digital does not endorse or make any legal representations about them. If you decide to access any of the third party websites linked from Pathways Digital's Site, you do so entirely at your own risk.

How Does Pathways Digital Secure Your Personal Data?

Pathways Digital has implemented administrative, technical, physical, electronic, and managerial procedures to safeguard and secure the information Pathways Digital collects from loss, misuse, unauthorized access, disclosure, alteration, and destruction and to help maintain data accuracy and ensure that your Personal Data is used appropriately. Where Personal Data is processed by service providers on behalf of Pathways Digital, Pathways Digital has implemented a comprehensive process requiring those service providers to also comply with applicable data protection laws.

How Long Does Pathways Digital Retain Your Personal Data?

Pathways Digital will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Notice and/or in applicable supplemental notices, unless a longer retention period is required by law.

Your Rights

Depending on your country or state of residence you may have some or all of the rights described below with respect to your Personal Data. To exercise your rights, you may:

make use of the self-serve tools available in the products or services you are using; or
submit your privacy request

It is Pathways Digital's legal obligation to validate any request Pathways Digital receives before responding.

Email and Marketing. In most instances, Pathways Digital gives you options with regard to the Personal Data you provide, including choices with respect to marketing materials. You may manage your receipt of marketing and non-transactional communications by: (i) clicking on the "unsubscribe" link in marketing emails; or (ii) checking certain boxes on Pathways Digital's preference center which can also be found on certain forms Pathways Digital uses to collect Personal Data.

Access. You may request information regarding Personal Data that Pathways Digital collects and holds about you and the source(s) of that information. To access your Personal Data, return to the product, service or web page where you originally entered it and follow the instructions in your user interface or on that web page. If you cannot access your information in this way, please submit your request through the appropriate Request Intake Form indicated above.

Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages particularly of the Site for a limited period of time. If you request a change to or deletion of your Personal Data, Pathways Digital may still need to retain certain information for record-keeping purposes, and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase, you may not be able to change or delete the Personal Data provided until after the completion of such purchase). Some of your information may also remain within Pathways Digital's systems and other records where necessary for compliance with applicable law.

You can request a copy of any Personal Data Pathways Digital holds about you, and of which you don't already have a copy. This service is usually free of charge, although Pathways Digital has the right to charge a ‘reasonable fee' in some circumstances;

Rectification. You have the right to request that Pathways Digital rectifies any inaccuracies in relation to the Personal Data Pathways Digital holds about you;

Erasure. In some circumstances, you have the right to request the erasure of your Personal Data or object to the further processing of your information;

Restriction of Processing. In some circumstances, you have the right to require Pathways Digital to restrict processing of your Personal Data;

Objection. You have the right to object to any direct marketing or to other processing of your Personal Data based on Pathways Digital's or on third parties' legitimate interests, unless such interests are compelling enough to override your objection;

Not to be discriminated against for exercising any of your other privacy rights. You may exercise any of your rights in this section without Pathways Digital discriminating against you in any way. Note however that you may be subject to differentiated treatment if and to the extent that the exercise of your rights materially impacts Pathways Digital's ability to provide certain services to you. Such differentiated treatment is objectively justified and does not constitute discrimination.

Withdraw Consent. Where Pathways Digital relies on your consent, you may have the right to withdraw consent to Pathways Digital processing your Personal Data. This will not affect the processing already carried out with your consent;

Not to be subject to decisions based on automated processing. In some circumstances, you have the right not to be subject to decisions based solely on automated processing, and to obtain the human review of any such decisions that significantly affect you (please refer to the earlier section on automated decision making); and

Complain. If you have a complaint, Pathways Digital would appreciate the chance to address your concerns; please contact Pathways Digital using the options provided under "Contact Pathways Digital". You may also lodge a complaint with the supervisory data protection authority in the state where you live, work or where an alleged infringement of applicable data protection law occurred

Competent Supervisory Authorities. Pathways Digital is a business that operates various activities across a number of jurisdictions.

What Choices Do You Have Regarding Pathways Digital's Use Of Your Personal Data?

Pathways Digital will not use or disclose your Personal Data in ways unrelated to the ones described above without first notifying you and offering a choice, unless Pathways Digital reasonably considers that Pathways Digital needs to use it for another reason and that reason is compatible with the original purpose. Please note that Pathways Digital may process your Personal Data without your knowledge or consent where it is required, or to the extent it is permitted by law.

Pathways Digital will provide you the opportunity to opt out of certain Pathways Digital communications. If you have any difficulty exercising your choices, please contact Pathways Digital.

How Can You Contact Pathways Digital?

You may exercise your rights as described in the "Your Rights" section above, or by contacing Pathways Digital directly.

What About Changes To This Privacy Notice?

Pathways Digital may change this Notice from time to time, so please be sure to check back periodically. Pathways Digital will post any changes to this Notice on Pathways Digital's Site. If Pathways Digital makes any changes to this Notice that materially affect Pathways Digital's practices with regard to the Personal Data Pathways Digital has previously collected from you, Pathways Digital will endeavor to provide you with notice in advance of such change by highlighting the change on Pathways Digital's Site, or by sending you an email message to the email address you have provided.

Cookie Notice and Policy

Effective Date: July 1, 2025

Pathways Digital uses cookies and similar technologies on its website and online services (collectively, "Site" or "Sites") so that Pathways Digital can improve your experience by, for example, recognizing you whenever you visit Pathways Digital's Site, providing you personalized information, remembering your marketing and product preferences, and helping you obtain the right information. In this notice, Pathways Digital provides more information about cookies and similar technologies, how Pathways Digital uses them, and how you can control Pathways Digital's use of them. Pathways Digital's processing of your personal data, including any personal data it collects through the user of cookies or similar technologies, is described in this Privacy Notice. Additional terms may apply to online services.

Cookies. Cookies are unique identifiers that are transferred to your device's hard drive through your web browser for record-keeping purposes.  Some cookies allow Pathways Digital to make it easier for you to navigate Pathways Digital's Site, while others are used to enable a faster log-in process or to allow Pathways Digital to track your activities on the Site. Cookies on the Site may be first-party (set by Pathways Digital's Site) or third-party (set by another website). There are two types of cookies: session and persistent cookies.

Session Cookies. Session cookies exist only during a single online session.  They disappear from your device when you close your browser or turn off your device.  Pathways Digital uses session cookies to allow Pathways Digital's systems to uniquely identify you during a session.  This allows Pathways Digital to process your online transactions and requests and verify your identity as you move through the Site.

Persistent Cookies.  Persistent cookies remain on your device after you have closed your browser or turned off your device.  Pathways Digital uses persistent cookies to track aggregate and statistical information about Pathways Digital's users' activity.

Clear GIFs, pixel tags and other technologies.  Clear GIFS (a.k.a. web beacons, web bugs or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies.  In contrast to cookies, which are stored on your device's hard drive, clear GIFs are embedded invisibly on web pages.  Pathways Digital may use clear GIFs in connection with Pathways Digital's Site to, among other things, track the activities of Site visitors, help Pathways Digital manage content, and compile statistics about Site usage. Pathways Digital and Pathways Digital's third-party service providers also use clear GIFs in emails to customers, to help Pathways Digital measure email response rates, identify when emails are viewed, and determine whether emails are forwarded.

Third Party Analytics. Pathways Digital uses third-party applications to evaluate usage of Pathways Digital's Site. Pathways Digital may use other analytic means to help improve Pathways Digital's services, performance and user experiences.  These applications may use cookies and other tracking technologies to provide their services to Pathways Digital.

What Cookies Are Used on Pathways Digital Sites?

Pathways Digital has categorized cookie use below. Note that some cookies are set and controlled by third parties.

Essential Cookies

Strictly Necessary Cookies. These cookies are necessary for the website to function and cannot be disabled. They are usually only set in response to actions made by you, which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Site will then not work.

Non-Essential Cookies

Performance Cookies. These cookies allow Pathways Digital to count visits and traffic sources so Pathways Digital can measure and improve the performance of the Site. They help Pathways Digital to know which pages are the most and least popular and see how visitors move around the Site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies Pathways Digital will not be able to monitor the Site's performance.

Functional Cookies. These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.

Advertising Cookies. These cookies may be set through Pathways Digital's Site by Pathways Digital's advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not directly store personal data such as an email address, but uniquely identify your browser and device. If you do not allow these cookies, any targeted advertising you experience will not be based on your visit to Pathways Digital's Site.

Social Media Cookies. These cookies are set by a range of social media services Pathways Digital has added to the Site to enable you to share Pathways Digital's content with your networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.

How Are Cookie Settings Controlled?

Using The Privacy Preference Center. The Privacy Preference Center can be utilized to customize your cookie preferences. Locate the Privacy Preference Center by clicking on the cookie icon or on a link in the cookie banner titled either "Cookie Settings" or, for California, "Do Not Sell or Share My Personal Data." In order for your preferences to be taken into account on a future visit they may be stored on your device for that browser. The Privacy Preference Center specifically controls the cookies set by Pathways Digital or a third party. You cannot disable Essential cookies, as these are necessary for the website to function.

Using The Browser. Most web browsers automatically accept cookies. If you prefer, you may be able to change your browser options to block cookies.  The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.  Visitors to the Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.

Using An Opt-out Signal. Some browsers and browser extensions include the ability to transmit signals to websites indicating your preference to opt-out. If Pathways Digital's Site detects the Global Privacy Control ("GPC") signal from your browser, Pathways Digital will opt you out of Non-Essential Cookies. You may confirm in the Privacy Preference Center that you have been opted out of Non-Essential Cookies. Some Site functionality might not work properly without these cookies. The signal applies only to your device and browser; if you visit Pathways Digital's Site from a different device or browser, you will need to reset your GPC settings.

Cookie Expiration Dates. The length of time a cookie will stay on your browsing device depends on whether it is a "persistent" or "session" cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted.

California Residents' rights under the California Consumer Privacy Act/California Privacy Rights Act ("CCPA/CPRA")

Pathways Digital does not sell your personal data. It only shares your personal data as described in this Privacy Notice. However, under California law, some uses of cookies may be considered "selling" or "sharing" of Personal Information. California Residents may opt-out of such "selling" or "sharing" in the Privacy Preference Center.

Updated on June 30, 2025