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The Pathway Initiative customer privacy notice​

This privacy notice tells you what to expect us to do with your personal information.

We have a joint controller relationship with akn for the purpose of website and email hosting, and to facilitate communication between staff and students..

We also have a joint controller relationship with Formspree for the purpose of storing data given through form submissions..

Contact details​

Email​

[email protected]

What information we collect, use, and why​

We collect or use the following information to provide services and goods, including delivery:

  • Names and contact details
  • Purchase or account history
  • Account information
  • Records of meetings and decisions

We collect or use the following information for the operation of customer accounts and guarantees:

  • Names and contact details
  • Account information, including registration details
  • Information used for security purposes

We collect or use the following information to prevent crime, prosecute offenders, or defend against legal action:

  • Names and contact information

We collect or use the following information for service updates or marketing purposes:

  • Names and contact details
  • Marketing preferences
  • Website and app user journey information
  • Records of consent, where appropriate

We collect or use the following information for research or archiving purposes:

  • Website and app user journey information

We collect or use the following information for recruitment purposes:

  • Contact details (eg name, address, telephone number or personal email address)

Lawful bases​

Our lawful bases for collecting or using personal information to provide services and goods are:

  • Consent
  • Legitimate interest:
    • We use personal information to respond to enquiries and/or applications you send us.

Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are:

  • Consent
  • Legitimate interest:
    • We use personal information to respond to enquiries and/or applications you send us.

Our lawful bases for collecting or using personal information to prevent crime, prosecute offenders or defend against legal action are:

  • Contract
  • Legitimate interest:
    • We use personal information to respond to enquiries and/or applications you send us, and filter this information to fight against spam.

Our lawful bases for collecting or using personal information for service updates or marketing purposes are:

  • Legitimate interest:
    • We use personal information to notify tutees and other involved parties to changes in our service (e.g a cancelled lesson)

Our lawful bases for collecting or using personal information for research or archiving purposes are:

  • Legitimate interest:
    • We use personal information to understand our reach across age demographics/countries etc.

Our lawful bases for collecting or using personal information for recruitment purposes are:

  • Consent
  • Legitimate interest:
    • Where applications for recruitment are sent, we review them.

Where we get personal information from​

  • People directly

How long we keep information​

[Insert information about how long you store personal information here.]

[You said you didn't have a retention schedule, or you weren't sure. Once you've downloaded or copy and pasted this privacy notice, you can fill the information in above. You must not publish the privacy notice without it.

For more information, see our guidance on how long you should store information (opens in a new window).]

[Paste your retention schedule here.]

[You said you had a retention schedule, but it wasn't available online. You can paste it above - you must not publish the privacy notice without it.]

Who we share information with​

Data processors​

Formspree

This data processor does the following activities for us: They store form submissions.

akn

This data processor does the following activities for us: They handle website and email hosting

Others we share personal information with​

  • Organisations we need to share information with for safeguarding reasons
  • Relevant regulatory authorities
  • Organisations we’re legally obliged to share personal information with
  • Emergency services (where necessary)
  • Publicly on our website, social media or other marketing and information media (where appropriate)

Sharing information outside the UK​

Where necessary, our data processors may share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place. Please contact us for more information.

Your data protection rights​

Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal data.

Your right to rectification - You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal data in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal data in certain circumstances.

Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.

Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent.

You don’t usually need to pay a fee to exercise your rights. If you make a request, we have one calendar month to respond to you.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

How to complain​

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

Last updated​

11 July 2024