Pathstream, Inc.
Privacy Statement
Last Updated: August 27, 2024
Thank you for visiting our website. Pathstream is on a mission to give everyone access to a meaningful career through our online training and career resources platform (the “Services“).
This Privacy Statement is intended to inform you about our policies and procedures regarding the collection, use and disclosure of information from individuals by Pathstream, Inc. (“Pathstream,” “we” or “us”) at www.pathstream.com and any other websites, features, applications, widgets or online services that are owned or controlled by Pathstream and that post a link to this Privacy Statement (collectively, the “Site”).
We value your privacy and protect your personal information as described in greater detail below. This Privacy Statement is for informational purposes and sets forth our policy with respect to the collection, use and disclosure of business information that we collect when engaging with prospective and existing corporate or institutional employees or individual users of our Services (the “Authorized Users“).
By accessing or using the Site, you consent to the information collection, disclosure and use practices described in this Privacy Statement. Certain features or services referenced in this Privacy Statement may not be offered on the Site at all times.
We do not sell or share your information with third parties, other than sharing your information with our service providers who support the internal operations of our company or who help us provide our products and services to our Customers.
YOUR RIGHTS
As an Authorized User, you have a right to:
- Confirm whether we process your personal information.
- Access and delete certain personal information.
- Data portability.
- Opt-out of personal data processing for targeted advertising and sales.
- Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
- Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.
If you would like to exercise your rights, please contact us by email at [email protected] or phone at (650) 437-5825 and provide us with your contact information. If you are an Authorized User because your employer has a contractual relationship with us, you may need to contact your employer to exercise your rights.
We will only use personal information provided in a verifiable opt-out request to verify the requestor’s identity or authority to make the request. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer opt-out request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You do not need to create an account with us to exercise your opt-out rights. We will only use and retain personal information provided in an opt-out request to review and comply with the request.
INFORMATION COLLECTION
Information We Collect from You
Whether you are using Pathstream products or services individually or as part of your employer’s contractual relationship with Pathstream, we consider you an “Authorized User,” and we may collect personally identifiable information from directly from you, from your Company and when you choose to provide it to us.
If you access our services through your employer, the use of your information by Pathstream is subject to our agreement with them; however, if you are or become an individual Authorized User, Pathstream can decide how the information you provide is collected and used, including what is shared with us for our use, subject to you exercising your rights as noted above.
We collect contact information from Authorized Users, including name, address, email address, telephone number, mobile telephone number or geolocation information. Pathstream will also collect information about your course registration, course progress, quiz scores, learning goals and other training-related information to enable us to generate a learning plan and support your learning goals and achievements.
When you engage with our chatbots, we may use generative AI Tools and technology to assist with our review and analysis of information that you share with us. Although your information may be shared with AI service providers, it will not be used to train any large language learning models and will only be used to enable us to provide the Services to you. While the use of generative AI can enhance our work, it is not a substitute for our expertise and judgment when providing our services.
When you voluntarily disclose information about yourself in the information that you submit to the Site (e.g., personal information such as your name, phone number and personal web address) such as when you communicate with other Students or course authors or experts, or other public posting on the website, including when interacting with other course participants, or course authors or experts, this information will be publicly available, can be collected and used by third parties and may result in unsolicited messages from others. Such activities are beyond our control. Please refrain from disclosing personal information on this website that you intend to keep private.
If you share any information that includes “educational records” as defined by the Family Educational Rights and Privacy Act (FERPA), you are responsible for (i) procuring all necessary consents to share such information with Pathstream in compliance with FERPA and (ii) ensuring that the sharing of such information with Pathstream complies with FERPA.
Information Received from Third Parties
We also may receive information about you from third parties, such as your employer or higher education institution. If you provide us with personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. If we combine the information we receive from others with Personal Information we collect through the Site, we will treat the combined information as Personal Information as described in this Privacy Statement.
Information Collected From Other Sources
We may obtain information about you from other sources, including social networks that you use to connect with us. If you use a third party service to login, link to us, or communicate with us (such as a social network or third party video chat), we may receive certain information about you from the third party based on your registration and privacy settings on those third party services. This information may include name, user name, demographic information, updated address or contact information, interests, and publicly-observed data, such as from social media and online activity.
Social Media
The Site also may permit additional interactions between it and a third party website, service, or other content provider, such as enabling you to “like” or share content to a third party social media service (such as Facebook), or to share content from a third party social media service to our Site. If you choose to “like” or share content, or to otherwise share information from or via our Site with a third party site or service, that information may be publicly displayed, and the third party may have access to information about you and your use of our Site (and we may have access to information about you from that third party). Please note that your relationship with any social media service is governed solely by your agreement(s) with such social media service and your interactions with third parties through social media or similar features are governed by the respective privacy policies of those third parties. You may also be able to modify your privacy settings with these third party social media websites.
You can choose to access certain third party social media websites and services through our site (such as Facebook). When you do so, you are sharing information with those sites, and the information you share will be governed by their privacy policies. You may also be able to modify your privacy settings with these third party social media websites.
Information Collected Automatically and cookie policy
As is true of most web sites, we and our third party service providers, including advertisers, analytics, and third party content providers, may automatically collect certain information from you as a Site visitor, Authorized Representative or Customer Representative whenever you access or interact with the Site. This information may include, among other information, the browser and operating system you are using, the URL or advertisement that referred you to the Site, the search terms you entered into a search engine that led you to the Site, areas within the Site that you visited, and other information commonly shared when browsers communicate with websites. When service providers receive this information, they are not permitted to use the information collected on our behalf except to help use conduct and improve our business.
We may use cookies, web beacons, pixel tags, log files, or other technologies to automatically collect certain information when you use our Site or interact with our emails and online or mobile advertisements. For example, we may automatically collect certain non-personal information from you such as your mobile device identifier or MAC address, embedded scripts, browser type, operating system, device model, software version, Internet Protocol (“IP”) address or other device identifier (“Device Identifier”) for any device (computer, mobile phone, tablet, etc.) used to access the Site, mobile or ISP carrier information, referring/exit pages and the domain name from which you accessed the Site. We also may collect information about your use of the Site including the date and time you access the Site, the areas or pages of the Site that you visit, the amount of time you spend using the Site, the number of times you return, whether you open forward or click-through emails and ads, and other usage data so that we can understand the statistical use trends of our Site in order to make improvements. We may also use this information we automatically collect to communicate with you by email and social media. This information may be stored and used with your personal information attached to it.
Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the device used to access the Site. If such information is linked to your Personal Information, we will treat it as Personal Information under this Privacy Statement.
We may also use third-party tools or services, such as Google Analytics, to assist us with analyzing and improving the Site. These service providers are not permitted to use the information collected on our behalf except to help use conduct and improve our business.
In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes and we may use third parties to perform these services on our behalf.
Choices About How We Use and Disclose Your Information and EEA/UK/Switzerland and California Do Not Track Disclosures.
You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Site or take full advantage of all of our offerings. Check the “Help” menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences.
On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising. Note that our systems may not recognize Do Not Track headers or requests from some or all browsers.
- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
- Disclosure of Your Information for Third-Party Advertising. Pathstream does not share your personal information with unaffiliated or non-agent third parties for online or offline promotional purposes.
- Promotional Offers from Us. If you do not wish to have your email address used by us to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions or click the unsubscribe link.
- Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email to [email protected] or call us at (650) 437-5825.
Third Party Analytics Providers, Ad Servers and Similar Third Parties
Pathstream works with (or may in the future work with) network advertisers, ad agencies, analytics service providers, and other vendors to provide us with information regarding traffic on the Site, including pages viewed and the actions taken when visiting the Site; to serve our advertisements on other web sites, within mobile apps and elsewhere online; and to provide us with information regarding the use of the Site and the effectiveness of our advertisements. Our service providers may collect certain information about your visits to and activity on the Site as well as other web sites or services, they may set and access their own tracking technologies on your device (including cookies and web beacons), and may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the Site or other online websites and services.
While we may use a variety of service providers to perform advertising services, some of these companies are members of NAI or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You may also want to visit or http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program. Please note that opting out through these mechanisms does not opt you out of being served advertising, and you will continue to receive generic ads while online.
Your Choices and Opting Out
We strive to provide you with choices regarding the personal information you provide to us or that we collect about you as a Company Representative.
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information, and you must update any changes through your online account.
- In order to opt-out of receiving communications from us by email, or to access, delete or modify your information, please email us at: [email protected] or by telephone at (650) 437-5825.
- You may opt-out of receiving marketing e-mails from us by following the opt-out instructions provided in those e-mails.
- We reserve the right to send you service-related emails even if you voluntarily opt-out of email notifications.
Please note that we reserve the right to send you certain communications relating to your use of the Site (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt-out from receiving marketing communications.
Accessing, Modifying or Deleting Your Information
We may not accommodate a request to change or delete information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We will use commercially reasonable efforts to honor your request; however, your Personal Information may remain in our archives and information you update or delete, may persist internally or for our administrative purposes. It is not always possible to completely remove or delete information from our databases.
INFORMATION USE
Pathstream may use information collected through the Site for the following purposes:
- To facilitate your access to and use of our site and services
- To improve the content of our websites
- To customize the content and/or layout of our page for each individual visitor
- To process information requests
- To communicate with you and send you online and offline marketing communications
- To enable us to publish your reviews to the Pathstream community
- To respond to your questions and comments and provide Company service to you
- To measure interest in and improve our products, services, and website
- To notify you about special offers and products or services available from us that may be of interest to you
- To solicit information from you, including through surveys
- To improve the content and functionality of our websites or our services and for internal business purposes
- To develop new programs, products or services
- To enforce this privacy statement
- To resolve disputes or troubleshoot problems
- For other administrative and analytical purposes such as information systems management, marketing, Company-relations correspondence,
The usage information we collect helps us to improve our Site, services and to deliver a better and more personalized experience by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our services according to your individual interests.
- Speed up your searches.
- Recognize you when you use the Site.
Combination of Information
We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Site as well as information collected offline or from third party sources to help us tailor our communications to you and to improve our Site or services.
INFORMATION SHARING AND DISCLOSURES
We may disclose Personal Information to third parties in our discretion as otherwise described in this Privacy Statement.
In particular, we may share the information we have collected about you for the following purposes:
- With service providers we use to support the internal operations of our products or services and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential. We may employ third party companies and individuals to perform services on our behalf, such as to host the Site, perform Site-related functions (e.g., without limitation, maintenance services, database management, data analytics, web analytics and online advertising, payment processing, fraud detection and improvement of our product or service features) or to assist us in analyzing how our Site is used. These service providers may have access to your Personal Information in order to perform these tasks on our behalf subject to the privacy policies of those third parties. If we use a service provider that uses artificial intelligence or machine learning (the “AI Tools”) to support our Services, the AI Tools and services will not use your identifiable information to train its model or platform.
- With our affiliated companies, in connection with delivering services and information to you and with other parties in connection with the arrangement of travel services, such as hotels and providers of transportation.
- With your consent or at your direction, such as when you request that we share information about you with a third party, such as your credentials or transcript, and we will typically do so under those circumstances.
- As necessary if we believe that there has been a violation of our rights or the rights of any third party, or this Privacy Statement
- When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
- To respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, national security or law enforcement, as permitted by law, or otherwise as required by law.
- Pathstream may transfer and disclose information, including your Personal Information and Device Identifier (including IP addresses), to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Site policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, Site visitors or the public. We may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies, in our discretion.
- For internal and affiliate purposes.
- Pathstream may share information, including Personal Information, with its parents, subsidiaries, and affiliates, primarily for business and operational purposes. We may sell, transfer or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due diligence process with any potential acquiring entity). In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through the Services in a manner that is consistent with this Privacy Statement.
- as described to you at the point of collection.
We also may share aggregate or anonymous non-personal information with third parties for their marketing or analytics uses.
YOUR CALIFORNIA PRIVACY RIGHTS
Pursuant to California Civil Code Section 1798.83, California residents who provide us with personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, one time per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses.
If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request to the following email address: [email protected]. You must put the statement “Your California Privacy Rights” in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We will respond to you at your mailing address or, at our option, your e-mail address. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
VISITORS FROM THE EEA, UK, OR SWITZERLAND
If you are a resident of the EEA, UK, or Switzerland, we are a data controller when we collect Authorized User information, although we may also be considered a processor if we provide Services to you in connection with our agreement with your employer.
Our legal basis for collecting and using Authorized User information is to do so with your consent; in performance of a contract or where the collection and use is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question. If you are using our Services through an agreement with your employer, you may contact your employer or us at any time to withdraw your consent to our collection and use of your personal data and to exercise the following rights to:
- Access your personal data or information;
- Delete, or request deletion of, your personal data or information;
- Object to or restrict processing of your personal information;
- Request portability of your personal information;
- Complain to your local data protection authority at any time;
- Object to automated decision making; and
- Update your personal data or information.
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right at any time to withdraw your consent to our collection and use of your personal data and to exercise the following rights. If we are the data controller, you can contact us to exercise these rights. If we are the data processor, you must contact the controller to exercise these rights:
- Access your personal data or information;
- Delete, or request deletion of, your personal data or information;
- Object to or restrict processing of your personal information;
- Request portability of your personal information;
- Complain to your local data protection authority at any time;
- Object to automated decision making; and
- Update your personal data or information
To withdraw consent or exercise these rights, please contact our Privacy Officer at [email protected].
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If we ask you to provide personal data to us to comply with a legal requirement or enter into a contract, we will inform you of this and let you know whether providing us with your personal data is required and if not, the consequences of not sharing your personal data with us.
Similarly, if we collect and use your personal information in reliance on our or a third party’s legitimate interests and those interests are not already listed above (see “Information Use” section), we will let you know what those legitimate interests are.
CHILDREN’S PRIVACY
Pathstream does not knowingly collect personal identifiable information from children under the age of 18 on this Site. If you are under the age of 18, please do not provide your name and address or other contact details or any other personally identifiable information of any kind whatsoever. If you are a parent or guardian of someone under the age of 18 who has provided us information without your knowledge and consent, you may request that we remove this information by contacting us at [email protected].
EXTERNAL LINKS
This website contains links to other websites. We are not responsible for the privacy practices of other websites. This Privacy Statement applies solely to information collected by Pathstream and its affiliates. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We recommend that you examine the privacy statements posted on those other websites to understand their procedures for collecting, using, and disclosing personal information.
SECURITY
The security of your personal information is important to us. We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about You as a Company Representative. In addition, our agreements with Companies include specific security and privacy requirements.
While we make every effort to help ensure the integrity and security of our network and systems, the transmission of information via the internet is not completely secure. Email sent to or from the Services may not be secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
DATA STORAGE AND RETENTION
Your personal information is stored on servers in the United States or in other countries in accordance with the data storage locations of our third party vendors. You understand and agree that we may collect, use, disclose, and otherwise process the information you provide as described in this Privacy Statement. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the United States. We will retain your personal information for as long as it is needed to provide you with the Site, our services, or to fulfill any legal or contractual obligations we may have.
CHANGES TO OUR PRIVACY STATEMENT
We reserve the right to revise this Privacy Statement at any time. When we do, we will post the changes on the Site. If we change the Privacy Statement in a material way, we will provide appropriate notice to you. Your continued use of the Site or our services after any changes or revisions to this Privacy Statement shall indicate your agreement with the terms of such revised Privacy Statement.
Please also feel free to contact us at [email protected]. if you have any questions about our Privacy Statement or the information practices of the Site.
If you need to access this Policy in an alternative format due to having a disability, please contact us at [email protected] or (650) 437-5825.
How you can contact us
If you have questions about this privacy policy, or if you believe that this site is not following its stated Privacy Policy, please contact us at:
(650) 437-5825
Pathstream, Inc.