Update effective date: January 1, 2020
PathFactory Inc. and its affiliates (“PathFactory“, “Us” or “We“) provides an intelligent content platform which helps marketing and sales organizations educate prospects and customers faster and more efficiently by delivering more of the content people need about you and your products or services whenever and wherever they click.
What types of information does PathFactory collect about its users?
Other Information. “Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. This might include, for instance, browser and device information; App usage data; information collected through cookies, pixel tags, and other technologies; pages visited; content downloaded; demographic information and other information provided by you; or aggregated information. We use this information to facilitate our operation of the Sites and for other purposes described below.
IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever you access the Sites, along with the time of the visit and the page(s) that you visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. PathFactory uses IP Addresses to calculate usage levels of the Sites, help diagnose problems with its servers, administer the Sites, and monitoring the regions from which you navigate to PathFactory’s Sites.
How does PathFactory collect information?
Personal Information. We and our service providers may collect Personal Information in a variety of ways, including without limitation:
- Through the Sites: We may collect Personal Information through the Sites, e.g., when you request a free trial or demo, register for a webinar, contact us, subscribe to our email newsletter, download content (e.g. whitepapers), or register to use our Sites.
- Offline: We may collect Personal Information from you offline, such as when you attend one of our events, during phone calls with sales representatives, or when you contact customer service.
- Through You: PathFactory may collect information such as your location or your preferred means of communication when you voluntarily provide it. Unless combined with Personal Information, this information does not personally identify you or any other user of the Sites. Note that there is no legal obligation for you to provide us with personal information and any information collected by us will be provided by you at your own will and with your consent.
- Information From Other Sources: In order to enhance our ability to provide relevant marketing, offers, and services to you, we may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, as well as from other third parties.
Other Information. We and our service providers may collect Other Information in a variety of ways, including:
Through Your Browser or Device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Sites (such as the Apps) you are using.
Through Cookies and Other Similar Technologies: We may use a technology called “cookies” in operating and managing the Site. A cookie is a piece of information that the computer that hosts the Site gives to your browser when you access the Site. Our cookies help provide additional functionality to the Site and help us analyze usage of the Site accurately. On most web browsers, you will find a help section on the toolbar. Please refer to this section for information on how to receive notifications when you are receiving a new cookie and how to turn cookies off.
By Aggregating Information: Aggregated Personal Information does not personally identify you or any other user of the Sites (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).
How does PathFactory use personal information?
We may use Personal Information:
- To respond to your inquiries and fulfill your requests, such as to send you newsletters.
- To send administrative information to you, for example, information regarding the Sites and changes to our terms, conditions, and policies.
- To communicate with you and provide you with related customer service.
- To send you marketing communications that we believe may be of interest to you.
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Sites and services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
- As we believe to be necessary or appropriate: (a) under applicable law, that may include laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including without limitation public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect PathFactory rights, privacy, safety or property, and/or those of our employees, our agents, our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
How will PathFactory share personal information it receives?
Third-Party Business Partners:
PathFactory partners with a variety of businesses and works closely with them to market or sell products or services. In certain situations, these businesses operate within or cooperatively with the Sites. We may disclose Personal Information to our partners for the purposes described above. Some of our third-party business partners may co-sponsor events and other offerings with PathFactory. We may share Personal Information with these co-sponsors when you sign up for events or offerings to allow our partners to send you marketing communications and information that may be of interest to you, as permitted under applicable law.
Agents and Service Providers:
We contract with other companies and people to perform tasks on our behalf and may share your Personal Information with them to provide products or services to you, or to otherwise communicate with you, such as to provide marketing or offers on our behalf. Examples may include removing repetitive information from customer lists, analyzing data, providing marketing assistance, and performing analysis related to our products or services. We may also provide your Personal Information to agents and service providers to verify or compile aggregate usage data that we provide to our partners. When we share this information in this way, we seek to require the agent or service provider to maintain the privacy, confidentiality and security of the Personal Information.
PathFactory Blog and Social Media Pages:
Personal Information may also be disclosed by you through the Sites, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including, without limitation, our PathFactory Blog, and the Social Media Pages). This information may appear in public ways, such as through search engines or other publicly available platforms, and may be “crawled” or searched by third parties. Please do not post any information that you do not want to reveal to the public at large.
Protection of PathFactory and Others:
We may release Personal Information when we believe that release is necessary or appropriate (a) under applicable law, that may include laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including without limitation public and government authorities outside your country of residence; (d) to enforce or apply our conditions of use and other agreements; (e) to protect our operations or those of any of our affiliates; (f) to allow us to pursue available remedies or limit the damages that we may sustain; and (g) to protect the rights, privacy, property, or safety of PathFactory, our employees, our agents, our affiliates, our users, or any other person or entity. This release for protection purposes may include without limitation exchanging information with other companies and organizations for fraud protection and credit risk reduction.
How does PathFactory use and disclose other information?
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.
In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we do, we will treat the combined information as Personal Information for as long as it is combined.
How does PathFactory secure personal information about me?
We have implemented organizational, technical, and administrative measures to protect Personal Information within our organization, including security controls to prevent unauthorized access to our systems. While we take reasonable steps to secure your Personal Information from loss, misuse, interference and unauthorized access, modification and disclosure, you should be aware no security procedures or protocols are ever guaranteed to be 100 percent secure from intrusion or hacking, and there is therefore always some risk assumed by sharing Personal Information online.
How can I correct or remove information about me?
If you feel that any Personal Information about you that has been collected and stored by PathFactory is incorrect, or if you would like Personal Information about you to be removed from our systems, please notify us at email@example.com so that we may consider and respond to your request in accordance with applicable law. You may also request access to your Personal Information held by PathFactory, by sending a written request to firstname.lastname@example.org.
For your protection, we may only respond to requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before reviewing your request. We will try to satisfy your request as soon as reasonably practicable, subject to applicable law.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
For how long will PathFactory retain my personal information?
What choices do I have?
You can always opt not to disclose information. However, if you elect to do so, we may be limited in responding to your inquiry or providing services to you.
You may opt-out of receiving marketing messages from PathFactory by sending an email to email@example.com, or by unsubscribing through the unsubscribe or opt-out link in an email sent by us.
Third party sites
Similarly, please note that we are not responsible for the collection, use and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, Blackberry, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or the Social Media Pages.
Your data privacy rights
Depending on where you are located and/or live, you may exercise certain data privacy rights, and we will facilitate the exercise of those rights.
European Privacy Rights
If you are a resident or are otherwise located in the territory of Europe, this section provides additional details about the personal data we collect about you, and your rights granted by the EU General Data Protection Regulation (“GDPR”).
Subject to certain limitations, the GDPR provides you the following privacy rights:
- Transparency and the right to information. Through this policy we explain how we use and share your personal information. However, if you have questions or concerns you can contact us any time at firstname.lastname@example.org.
- Right of access, objection, restriction of processing, erasure, and portability. You can make a request to access, object, restrict, erase, or transfer any of your personal data here. You also have the right to withdraw your consent at any time when we process your personal data based on your consent.
Right to opt-out to direct marketing. You have the right to opt-out at any time to receiving marketing materials from us by contacting us at email@example.com
- Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according to the GDPR, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
Legal Basis for Processing (EEA and Switzerland only)
Our legal basis for collecting and using the personal data described in this policy will depend on the type of information and the context in which we collect it.
However, we will normally collect personal data from you only in the following circumstances:
- Where we have your express consent to do so
- Where we need the personal data to perform a contract with you
- Where the processing is in our legitimate interests and is not overridden by your data protection interests or fundamental rights and freedoms
In some cases, we may also have a legal obligation to collect personal data from you to protect your vital interests or those of another person (for example, to prevent, investigate or identify possible wrongdoing in connection with the Site or to comply with legal obligations).
If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will identify such basis for processing at the relevant time and let you know if the provision of your personal information is mandatory or not (as well as the possible consequences associated with not providing such information).
If we collect and use your personal data in reliance on our legitimate interests (or those of any third party), this interest will typically be to operate our Site, communicate with you in relation to your account or the Site, to solicit information from you, including through surveys, to share aggregated information with providers of listed products or services and other licensees of our research and report offerings, to measure interest in and improve our offerings and Site, to engage in marketing activities, and to otherwise customize your experience with PathFactory.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at firstname.lastname@example.org.
California Privacy Rights
If you are a resident of California, this section provides additional details about the personal information we collect about you, and your rights under the California Consumer Privacy Act, or “CCPA.”
Subject to certain limitations, the CCPA provides you the right to request:
- That we provide you access to details on the categories or specific pieces of personal information we collect (including how we use and disclose this information);
- That we delete any of your personal information;
- To opt out of any “sale” of your personal information that may occur; and
- To not be discriminated against for exercising any of the above rights.
If you would like to submit a request to exercise your California privacy rights under the CCPA, you may do so here. We will verify your request using information associated with your account, including your email address. Further identification may be required. You may also designate an authorized agent to act on your behalf.
Nevada Privacy Rights
If you are a resident of Nevada, Nevada law (SB 220), permits customers in Nevada to opt-out of the sale of certain kinds of personal information. A sale under Nevada law is the transfer of this personal information to third parties for monetary consideration so these third parties can then re-sell or license the sold information. PathFactory does not sell your personal information to third parties as defined in Nevada law. If you are a Nevada resident and wish to obtain information about our compliance with Nevada law, please contact us as at email@example.com.
We ask that you not send us or disclose any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Sites or via other means.
International Transfer of Data
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Sites or disclosing information to us you consent to the transfer of information to countries outside of your country of residence, including without limitation the United States of America, Canada, India, Ireland, Israel, Japan, and the United Kingdom, which may have different data protection rules than those of your country of residence or the country in which you were located when you initially provided the information in question.
The Site is a general audience site and does not offer services directed to individuals under 18 years of age.
No one under the age of 18 may provide any information to or on the Site. We do not knowingly collect personal information from individuals under 18.
If you are under 18, do not use or provide any information on this Site or on or through any of its features, do not register on this Site, use any of the interactive or comment features of this Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. Should an individual whom we know to be under the age of 18 send personal information to us, we will delete or destroy such information as soon as reasonably possible. If you believe we might have this type of information, please contact us.
Your privacy is important to us. If you have any questions, concerns, or complaints regarding the way we collect and handle your information, please contact us by email at firstname.lastname@example.org or by mail at 174 Spadina Avenue, Suite 600, Toronto, Ontario, Canada M5T 2C2 ATTN: Privacy Group. Because email communications are not always secure, please do not include credit card information or other sensitive information in your emails to us.
PathFactory will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.