We want to make sure you understand what personal information we may collect about you when you interact with PATH-managed websites (“PATH,” “we,” “us”, and “our”), how we use your personal information, and how we keep it safe.
If you have come to this notice from a data-collection form, please be aware that by completing the form and submitting your information, you are agreeing to the data-use policies outlined in this notice.
This Privacy Notice explains:
- What personal information we collect about you
- How we use your personal information
- How long we keep your personal information
- That we may share your personal information with others and transfer it
- How we protect your personal information
- Your rights regarding your personal information
- What to do if you don’t want to provide us with your personal information
- How to contact us
- Notification of changes to this privacy notice.
If you have any questions, please get in touch via one of the methods set out in the Contact Us section below.
1. What personal information we collect
When you browse PATH-managed websites, information may be collected by us including the following:
Information you voluntarily provide to us, such as:
- your name and contact information
- your email address
- employment-related information if you apply for a position with PATH or ask to be added to our employment database
- payment information if you choose to donate to PATH
In addition, we may automatically gather technical information, for instance through the use of Google Analytics, cookies, or other technology, such as:
- anonymous analytics and activity data that does not identify you, but records information about your visits to a PATH website, including the URL from which you originated, the browser and operating system you use, the IP address and associated geographic location of the computer you are using, access times, pages viewed, and click actions on the site
- social media tracking pixels that allow us to create advertising on platforms (such as Facebook and Twitter) that is targeted to individuals who have visited our site(s).
We may combine information that we have collected from various sources.
2. How we use your personal information
Our websites include forms that allow users to submit personal information to us, for example email sign-up forms, donation forms, and job application forms.
We may use the personal information that you voluntarily submit to us in order to contact you with any or all of these:
- email messages and newsletters about PATH’s work and operation
- information about job application status or available job postings
- solicitation of donations, acknowledgment and thank you emails for donations
- receipts and tax documents
- event invitations
- press releases
- important notices and updates, such as changes to our terms and policies, security alerts and administrative messages
- personal responses to your specific requests
- confirmation of or updating of your contact information
We may use both mechanically collected anonymous data, and information you voluntarily submitted, in order to improve our day-to-day operations, including:
- to comply with applicable laws, regulations, and guidance
- to comply with demands or requests made by regulators, governments, courts, and law enforcement authorities
- to investigate and take action against illegal or harmful behavior of users
- for internal purposes such as auditing, data analysis, and research to help us deliver and improve our PATH digital platforms and content
- to monitor and analyze trends, usage, and activities in connection with our work and to understand which parts of our digital platforms are of the most interest and to improve the design and content of our platforms
- to improve our communications to you, including posting targeted social media content that is only promoted to users who have visited our websites or specific pages or sections, or taken specific actions on the site(s)
3. How long we will keep your personal information
We will keep your personal information for the period required by law and where we need to do so in connection with legal action or an investigation involving PATH. Otherwise, we keep your personal information:
- for as long as needed to provide you with access to services or information you have requested; or
- where you have contacted us with a question or request, for as long as necessary to allow us to respond to your question or request.
We may share your personal information with the following trusted third parties:
- our agents and suppliers, including those who provide us with technology services such as data analytics, hosting, email and direct mail services, and technical support;
- our professional advisors, auditors, and business partners; and
- regulators, governments, and law enforcement authorities.
Your personal information may be processed by PATH and PATH’s trusted third-party suppliers outside of your home country. Data privacy laws in the countries to which your personal information is transferred may not be equivalent to, or as protective as, the laws in your home country.
5. How we protect your personal information
We use a variety of security measures and technologies to help protect your personal information from unauthorized access, use, disclosure, alteration, or destruction, in line with applicable data protection and privacy laws. For example, when we share your personal information with external suppliers, we may put in place a written agreement which commits the suppliers to keep your information confidential, and to put in place appropriate security measures to keep your information secure.
The transmission to us of information via the internet or a mobile phone network connection may not be completely secure and any transmission is at your own risk.
Websites that we do not own or control
From time to time we may provide links to websites, domains, or mobile applications that are not owned or controlled by us. This Privacy Notice does not apply to those websites. The presence of links to such external or third-party websites does not represent PATH’s endorsement of, or affiliation with, them. If you choose to use those websites, please check the legal and privacy statements posted on each website or mobile application you access to understand their privacy practices.
6. Your rights regarding your personal information
Data privacy laws provide you with a number of rights over your personal information.
You may be entitled to:
- ask us for access to the personal information we hold about you;
- request the correction and/or deletion of your personal information;
- request the restriction of the processing of your personal information, or object to that processing;
- withdraw your consent to the processing of your personal information (where PATH is processing your personal information based on your consent);
- request the transfer to another organization, in a machine-readable form, of the personal information that you have provided to us; and
- complain to your local data protection authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal information.
If you would like to exercise your rights, please let us know by getting in touch with us as set out in the How to contact us section below.
7. What to do if you don’t want to provide us with your personal information
Automatic data collection
As described above, PATH web sites may automatically gather certain kinds of data about visitors. Web browser tools may allow users to limit the amount of data your browser transmits to us. We do not currently provide a way to opt out of anonymous analytics and data collection on our sites, except to exit the site.
Voluntary provision of information
By voluntarily providing your personal information, such as email address, job application, donation details, and other form submission on the site, you are agreeing to the terms and uses outlined in this privacy notice. If you wish to donate to PATH anonymously, contact us at email@example.com.
8. How to contact us regarding privacy
If you have questions or requests regarding this Privacy Notice, or if you would like to exercise your rights, please contact us using the contact information below.
Attn.: Chief Communications Officer
P.O. Box 900922
Seattle, Washington 98121 USA
For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and/or we may need to verify your identity before implementing your request. Verification may require that we ask you to provide other personal information. If we are unable to verify your identity or the validity of your request, we may not be able to implement your request for security reasons.
We will endeavor to comply with your request as soon as reasonably practicable. In some cases, we may need to retain certain information where important public interests require it, such as the safety and security of individuals, the rights and freedoms of others, the integrity of audit, investigation, arbitral or judicial processes, and/or record keeping or legal purposes.
9. Notification of changes
We reserve the right to modify this PATH Websites and Web Data Privacy Notice at any time. We encourage you to stay informed by reviewing updates to this Privacy Notice periodically.
Page last updated March 28, 2019