Privacy Notice

  1. Introduction
    1. We are committed to safeguarding the privacy of our website visitors.
    2. We are acting as a data controller with respect to the personal data of our website visitors; in other words, we determine the purposes and means of the processing of that personal data.
    3. In this policy, "we", "us" and "our" refer to MyPathway Solutions Ltd. For more information about us, see Section 11.
  2. How we use your personal data
    1. In this section we have set out:
      1. the general categories of personal data that we may process;
      2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
      3. the purposes for which we may process personal data; and
      4. the legal bases of the processing.
    2. We may process data about your use of our website ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our website usage logs and Google Analytics. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website.
    3. We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of communicating with you, and offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is our legitimate interests, namely communicating with enquirers, and marketing and supporting our goods and/or services.
    4. We may process information that you provide to us for the purpose of subscribing to our newsletters ("notification data"). The notification data may be processed for the purposes of sending you the newsletters. The legal basis for this processing is consent.
    5. We may process information relating to our relationships with customers and prospective customers, including contact information ("customer relationship data"). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers and/or prospective customers, communicating with customers and/or prospective customers, keeping records of those communications and promoting our products and services. The legal basis for this processing is our legitimate interests, namely [the proper management of our customer relationships and marketing our goods and/or services.
    6. Please do not supply any other person's personal data to us, unless we prompt you to do so.
  3. Providing your personal data to others
    1. We may disclose any of the personal data described in Section 2 to our website and email hosts insofar as reasonably necessary for the proper operation of our website and receiving your enquiry.
  4. International transfers of your personal data
    1. Personal data held by ADI may be subject to transfer outside of the UK. In all such cases, it is transferred to a trusted partner company who use the data solely to provide services to us; they process the data only as instructed by us, and they make no access to, or use of, the data for their own purposes. Your data is at all times protected to the same level as if it had remained within the UK.
    2. ADI uses the following international data processors:
      1. Insightly, based in the USA, which provides our customer relationship management system;
      2. Eventbrite, based in the USA, which provides event booking and management services;
      3. Mailchimp, based in the USA, which provides email-based marketing communications services; and
      4. Google, based in the USA, which provides analytics services allowing us to monitor the usage of our website.
    3. See section 9 for further information regarding Google Analytics and the cookies it uses
  5. Retaining and deleting personal data
    1. This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
    2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
    3. We will retain your personal data as follows:
      1. enquiries you make via the website are immediately emailed to our sales and marketing staff; they are not stored on the website at all.
      2. usage data will be retained for a maximum period of 4 years
  6. Amendments
    1. We may update this policy from time to time by publishing a new version on our website.
    2. You should check this page occasionally to ensure you are happy with any changes to this policy.
  7. Your rights
    1. In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
    2. Your principal rights under data protection law are:
      1. the right to access;
      2. the right to rectification;
      3. the right to erasure;
      4. the right to restrict processing;
      5. the right to object to processing;
      6. the right to data portability;
      7. the right to complain to a supervisory authority; and
      8. the right to withdraw consent
    3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
    4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
    5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed]. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
    6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
    7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
    8. You have the right to object to our processing of your personal data for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose.
    9. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
    10. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
    11. You may exercise any of your rights in relation to your personal data by written notice to us.
  8. About cookies
    1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
    2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
    3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
  9. Cookies that we use
    1. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://policies.google.com/privacy. The relevant cookies are: _ga, _gat and _gid.
  10. Managing cookies
    1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
      1. https://support.google.com/chrome/answer/95647 (Chrome);
      2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
      3. https://www.opera.com/help/tutorials/security/cookies/ (Opera);
      4. https://support.microsoft.com/en-gb/help/17442/windows-internetexplorer-delete-manage-cookies (Internet Explorer);
      5. https://support.apple.com/kb/PH21411 (Safari); and
      6. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
  11. Our details
    1. This website is owned and operated by MyPathway Solutions Ltd.
    2. We are registered in England and Wales under registration number 14441550, and our registered office is at 2 Stone Buildings, Lincoln’s Inn, London WC2A 3TH.
    3. You can contact us:
      1. by post, to the postal address given above;
      2. using our website contact form;
      3. by telephone, on the contact number published on our website from time to time; or
      4. by email, using the email address published on our website from time to time
  12. Data protection officer
    1. Our data protection officer can be contacted by writing at the above address or by email: ukgroup@vitalhub.uk

This document was created using a template from SEQ Legal.