Privacy Policy

Effective Date: January 16, 2025

This Privacy Policy describes how Pathstream Inc. collects, uses, and discloses Personal Data when you use our website(s), products, services and applications (the “Services”). Please read the following to learn how we treat your Personal Data.

Remember that your use of Pathstream Inc.’s Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

You may print a copy of this Privacy Policy here. If you have a disability and would like to receive a copy of our Privacy Policy in an alternative format, you may do so by contacting privacy@pathstream.com.

 

Table of Contents

• What this Privacy Policy covers
• Personal Data
• How we share your Personal Data
• Tracking tools, advertising, and opt-out
• Data security and retention
• Personal data of children
• Your Privacy choices
• Data subject rights
• Other state law Privacy Rights
• Changes to this Privacy Policy
• Contact Information

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.
 

Personal Data

Categories of Personal Data We Collect

The following chart details the categories of Personal Data that we collect and have collected over the past twelve (12) months.  The information we collect depends on the way you interact with our Services, as described further under “Categories of Sources of Personal Data.”  For example, if you visit our website, we may collect certain information automatically such as your IP address, cookies, or similar identifiers.  If you use our “Find Your Employer” functionality, we may collect your contact information and information about your current employment, and if you apply for a job using our careers page, we may collect information about your current and prior work history.
 

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

• You
  • When you provide such information directly to us.
    • When you create an account or use our interactive tools and Services.
    • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
    • When you send us an email or otherwise contact us.
       
  • When you use the Services and such information is collected automatically.
    • Through Cookies and Similar Technologies (defined in the “Tracking Tools, Advertising, and Opt-Out” section below).
    • If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
    • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
    • We collect information about your interaction with the Services, including the resources that you access, pages viewed, how much time you spent on a page, and how you reached our website. We also log the details of your visits to our website and information generated in the course of using our website, such as mouse movements, clicks, page visits, text entered, how long you spent on a page, and other details of your actions on our website.
       
• Third Parties
  • Vendors
    • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
    • We may use vendors to obtain information to generate leads and create user profiles.
  • Advertising Partners 
    • We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements, or communications.
  • Social Networks
    • If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.
• Information from Schools. We may receive Personal Data from the school you have registered with pursuant to the consent you have granted to your school.  Where we receive Personal Data from a school, Pathstream Inc. acts as a “school official,” or receives Personal Data as “directory information,” under the Family Educational Rights and Privacy Act (“FERPA”) and consistent with 34 C.F.R. §99.31(a), and shall protect student data accordingly. You have the right to refuse to share your data with us. If you would like to do so, you may contact us at any time at privacy@pathstream.com.

Our Commercial or Business Purposes for Collecting Personal Data

• Providing, Customizing and Improving the Services
  • Creating and managing your account or other user profiles.
    Processing orders or other transactions; billing.
  • Providing you with the products, services, or information you request.
  • Meeting or fulfilling the reason you provided the information to us.
  • Providing support and assistance for the Services.
    Improving the Services, including testing, research, internal analytics, and product development.
  • Personalizing the Services, website content, and communications based on your preferences.
  • Doing fraud protection, security, and debugging.
  • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
• Marketing the Services
  • Marketing and selling the Services. 
  • Showing you advertisements, including interest-based or online behavioral advertising. 
• Corresponding with You
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Pathstream Inc. or the Services.
  • Sending emails and other communications according to your preferences or that display content that we think will interest you.
• Meeting Legal Requirements and Enforcing Legal Terms
  • Fulfilling our legal obligations under applicable law, regulation, court order, or other legal process, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities.
  • Protecting the rights, property, or safety of you, Pathstream Inc., or another party.
  • Enforcing any agreements with you.
  • Responding to claims that any posting or other content violates third-party rights.
  • Resolving disputes.
     

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
 

How We Share Your Personal Data

We disclose your Personal Data to the following categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” or “sharing” of your Personal Data. For more information, please refer to the “Data Subject Rights” section below.

• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
  • Payment processors.
  • Advertising networks.
  • Security and fraud prevention consultants.
  • Hosting and other technology and communications providers.
  • Analytics providers.
  • Staff augmentation and contract personnel.
  • Support and customer service vendors.
     
• Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:
  • Advertising networks.
  • Marketing providers.
     
• Business Partners. These parties partner with us in offering various services. They include:
  • Educational institutions that you have a relationship with.
  • Businesses that you have a relationship with.
  • Companies that we partner with to offer joint promotional offers or opportunities
     
• Parties You Authorize, Access or Authenticate.
  • Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services).
  • Social media services (if you intentionally interact with them through your use of the Services).
  • Third parties you access through the Services.
  • Other parties authorized by you.
     

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified, or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified, or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build, and improve the Services, and promote our business, provided that we will not share such data in a manner that could identify you.
 

Tracking Tools, Advertising and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies and Similar Technologies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, analyze trends, learn about our user base, and operate and improve our Services, as well as for marketing and advertising. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own cookies on your device(s). Please note that the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies.Performance/Analytical Cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google, Inc. (“Google”) uses cookies in connection with its Google Analytics services that utilize Cookies. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
• Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”

You can decide whether or not to accept Cookies through your internet browser’s settings. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.  To explore what settings are available to you with respect to Cookies and Similar Technologies, look in the “preferences” or “options” section of your browser’s menu.  Alternatively, if your browser or another add-on offers you the ability to use Global Privacy Control (GPC) or similar technologies recognized for the purpose under law to communicate your privacy preferences to us, we honor such signals.  To find out more information about cookies, including information about how to manage and delete cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.

Information about Interest-Based Advertisements

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors, and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services, and/or services of third parties. For more information about Interest-Based Ads, including details on how to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit http://www.networkadvertising.org/choices/ or www.aboutads.info/choices. Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website http://www.youronlinechoices.eu/.

 

Data Security and Retention

We use a combination of physical, technical, organizational and administrative security measures to protect Personal Data we collect through the Services. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure, and we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

We retain Personal Data about you for as long as you have an open account with us, for as long as needed to fulfill the particular purpose for which it was collected and as directed by you, or as otherwise necessary to provide you with our Services. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation (including the fulfillment of a legitimate interest). We may further retain information in an anonymous or de-identified aggregated form where that information would not identify you personally.

 

Personal Data of Children

As noted in the Terms of Use, we do not knowingly market to, collect, or solicit Personal Data from children under 16; if you are a child under 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16, we will delete that information as quickly as possible. A parent or legal guardian of a child under the age of 16 may review and request deletion of such child’s Personal Data as well as prohibit the use of that information. If you believe that a child under 16 may have provided us Personal Data, please contact us at privacy@pathstream.com.
 

Your Privacy Options

You may have certain choices when it comes to how we collect and use your Personal Data:

• Email Marketing. If at any time you no longer wish to receive marketing communications from us, you can click the unsubscribe link at the bottom of any email or email us at privacy@pathstream.com.
• SMS Marketing. Consent to receive automated marketing text messages is not a condition of any purchase. You can opt-out of receiving commercial text messages via by responding to any of our text messages with any of the following replies: STOP, END, CANCEL, UNSUBSCRIBE, or QUIT. If you opt-out, we may still send you messages regarding the status of your orders and other service-related communications.

Data Subject Rights

Residents of certain states may have the rights outlined in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@pathstream.com.

Access

You may have the right to request certain information about our collection and use of your Personal Data. Upon request, we will provide you with the following information:

• The categories of Personal Data that we have collected about you.
• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting, sharing, or selling your Personal Data.
• The categories of Personal Data about you that we have disclosed, shared, or sold.
• The categories of third parties with whom we have disclosed, shared, or sold your Personal Data.
• The specific pieces of Personal Data that we have collected about you.
• A copy of the Personal Data that we have collected about you in a portable format.
   

Deletion and Correction

You may have the right to request that we correct inaccurate Personal Data and to request, in certain circumstances, that we delete any that we have collected directly from you.
 

Right to Opt Out of Personalized Advertising and Sale to Third Parties

You may have the right to opt out of the use and disclosure of your Personal Data for the purposes of selecting or delivering advertising based on your activity over time and across different online platforms, as well as the right to opt out of certain disclosures that are considered “sales” under applicable state laws.  See the “Personal Data Sale and Sharing Opt-Out and Opt-In” section below for additional details.

Right to Opt Out of Automated Decisionmaking 

Residents of certain states have the right to opt-out of automated profiling in certain instances where such processing would produce legal or other similarly significant effects.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

• Phone: (650) 437-5825
• Email: privacy@pathstream.com

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

If you are a resident of certain states, and we deny your request, you have the right to appeal our decision. You can request further review by emailing privacy@pathstream.com or calling (650) 437-5825.

Personal Data Sales Opt-Out and Opt-In

As described in the “Tracking Tools, Advertising, and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. Under certain state laws, sharing your data through third party Cookies for online advertising may be considered a “sale” or “sharing” of information. You can opt out of these sales by following the instructions in this section.

We sell and/or share your Personal Data to the following categories of third parties:

• Advertising networks
• Marketing providers

Over the past 12 months, we have sold and/or shared the following categories of your Personal Data to categories of third parties listed above:

• Profile or Contact Data
• Professional or Employment-Related Information
• Web Analytics or other similar network activity information
• Consumer Demographic Data
• Device Data
• Other Identifying Information that You Voluntarily Choose to Provide

You can opt-out of the sale of your Personal Data using the following methods:

• Complete the online form: www.pathstream.com/delete-my-data
• Email: privacy@pathstream.com

Your can opt-out of the sharing of your Personal Data for purposes of cross-context behavioral or targeted advertising by following the instruction provided in the “Tracking Tools, Advertising, and Opt-Out” section above.

Once you have submitted an opt-out request, we will not ask you to reauthorize the sale or sharing of your Personal Data for at least 12 months.

To our knowledge, we do not sell or share the Personal Data of minors under 16 years of age.
 

We Will Not Discriminate Against You for Exercising Your Data Subject Rights

We will not discriminate against you for exercising any of the rights described above. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights. However, we may offer different tiers of our Services as allowed by applicable data privacy laws with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
 

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84 (“Shine the Light Act”), California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@pathstream.com.
 

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at privacy@pathstream.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
 

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on the www.pathstream.com website, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.
 

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such use, please do not hesitate to contact us at:

• Phone: (650) 437-5825
• Website: www.pathstream.com
• Email: privacy@pathstream.com
• Mailing Address: 580 Market St. Suite 400, San Francisco, CA 94104