Path Privacy Policy

PATH respects your privacy. PATH offers mapping, GPS navigation, community based services and safety information to users of https://www.pathcommunity.co (the “Website”) and/or users of PATH’s mobile application (the “Application”) (collectively referred to as the “Services”). When you use our services, you’re trusting us with your information. We understand this is a big responsibility and work hard to protect your information and put you in control. 

This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, and delete your information. This 

In this Privacy Policy, the term “personal information” means information which you provide to us which personally identifies you, such as your name, email address or billing information, and, in certain circumstances, your location and route information or other data which can be reasonably linked to such information by PATH. 

You can adjust your Privacy Settings in the PATH app and choose which personal information we may collect about you and how your information is used. 

User Accounts & Accessing the Services 

Please note that when you use our Services , PATH will set up an account (the “Account” or “PATH Account”). PATH will collect and use your information, including meta-data (as described below), in accordance with this Privacy Policy. 

● PATH will link all of your information with your registered Account. This includes information received from all devices and browsers which you have chosen to sign in ; 

● When using the Services, your approximate location and other information you may choose to contribute will be visible to other users associated with this Account. 

● PATH may also establish and require from time to time additional or different means of identification and authentication for logging in and accessing the Services or for accessing certain features or designated sections of the Services.

● Your login details are your responsibility. You are fully accountable for any use or misuse of your Account and personal details as a result of conveying your login details to someone else. You must maintain your login details in absolute confidentiality and avoid disclosing them to others. If you set a password, make sure that you change your password frequently and at least once every six months. 

Information that is being collected 

Information you create or provide to us: 

● Account Information: information required when setting up an Account, such as your name, email address or other contact data. Bear in mind that false, incorrect, or out-dated information may impair PATH’s ability to provide you with the Services and to contact you when necessary. PATH will explicitly indicate the fields for mandatory completion. If you do not enter the requisite data in these fields, you may not be able to register your Account or to be provided with certain safety services. 

● Information that you choose to share with PATH, including a username you have chosen, reports associated with your username, phone number, “home” or “work”, other “favorites”, destinations you may travel to, search queries, and information pertaining to your friends and family. 

● Information from your social networks which you choose to connect to your PATH Account: you may choose to connect your PATH Account to your social network account(s). If you choose to do so, you may choose to share with PATH and/or other users information from your social network accounts, such as your Facebook profile photo or other personal information shared by you. 

You may also provide additional information that will be used to personalize the Services and enhance your experience with the Services. For example, if you provide us with your “home” and “work” information, we may provide you with what we think is the preferred route between those locations. 

Information we collect as you use our services 

We collect information about your activity in the Services, which we use to provide you with the Services of PATH, including features which are meant to personalize your experience. The activity information we collect may include:

● Detailed location, travel and route information. Location and route information is collected for example in the form of GPS signals (combined with a time-stamp), IP address and other information from sensors and receivers on or around your device,on which the Application is installed and activated. This location and route information is saved to a route history of all of the journeys you have made while using the Application. The types of location data we collect depends in part on your device and account settings. For example, depending on your selected device settings and/or your account settings we may collect information about your location and travel (or lack thereof) also while you are not using the app, in order to be able to tell you when to leave for planned drives, notify you about bad traffic in your area, provide you parking assistance, analyze how effective our ads are and more; 

● Terms or venues you searched; 

● Your views and interactions with content and ads; 

● Your activity on third-party sites and apps that you chose to link to your PATH account or that you interact with through the Service. 

Why PATH collects data 

PATH may use information collected from or provided by you for the following purposes: Provide our services 

We use your information to deliver our services. For example: 

● Use your location and route information and/or search query history to provide navigation services, best route choices, safety alerts; and 

● To share your submissions with other users of the Services and to facilitate communication between you, PATH and other users. 

Maintain & improve our services 

● We also use your information to ensure our services are working as intended, such as tracking outages or troubleshooting issues you report to us. And we use your information to improve the service or to develop new features or services. For example, PATH may use your route information to improve the accuracy of its mapping and navigation data. 

Provide personalized services, including content and ads 

● We use the information we collect to operate the Services and to customize your experience with the Services. For example, PATH may use your “home” and “work” and other “favorites”

information (if you choose to provide such information) or route history to offer routes based on how you’ve chosen to travel between favorite destinations in the past. 

● We may also use the information to provide you with support and handle requests and complaints. 

Measure performance 

● We use data for analytics and measurement to understand how our services are used. For example, we analyze data about your usage of the Services to do things like optimize product design. 

Communicate with you 

● We also use your information to send you updates, notices, announcements, users’ requests and additional information related to the Services (including through push notifications, email address and SMS); 

● We may also use your information to conduct surveys and questionnaires; And if you contact PATH we may keep a record of your request in order to help solve any issues you might be facing. 

To protect PATH, our users, the public and for Legal reasons 

We may also use and process your information and content, using different technologies to the following purposes: 

● To enforce the Terms of Use or Privacy Policy; 

● To contact you when PATH believes it to be necessary; 

● To comply with any applicable law and assist law enforcement agencies under any applicable law, when PATH has a good faith belief that PATH’s cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards and procedures; 

● To detect abuse and illegal activity; to detect and prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services; 

● To handle breakdowns and malfunctions; 

● To take any action in any case of dispute, or legal proceeding of any kind between you and the Services, or between you and other users or third parties with respect to, or in relation with the Services; 

● For purposes provided under this Privacy Policy and Terms of Use; 

● To help improve the safety and reliability of our Services. This includes detecting, preventing, and responding to security risks, and technical issues that could harm PATH, our users, or the public;

We’ll ask for your consent before using your information for a purpose that isn’t covered in this Privacy Policy. 

Sharing your information 

When PATH shares your information 

PATH does not sell, rent or lease your personal information to third parties. 

PATH will not share your personal information with others, without your permission, except for the following purposes and to the extent necessary in PATH’s good-faith discretion: 

● As necessary for the facilitation and operation of the Services; 

● If PATH reasonably believes that you have breached the Terms of Use or is investigating potential breach of the Terms of Use, or believes that you abused your rights to use the Services, or performed any act or omission that PATH reasonably believes to be violating any applicable law, rules, or regulations. PATH may share your information in these cases, with law enforcement agencies and other competent authorities and with any third party as may be required to handle any result of your wrongdoing; 

● If PATH is required, or reasonably believes that it is required by law to share or disclose your information; 

● In any case of dispute, or legal proceeding of any kind between you and PATH, or between you and other users with respect to, or in relation with the Services; ● In any case where PATH reasonably believes that sharing information is necessary to protect against harm to the rights, property or safety of PATH, our users, or the public as required or permitted by law, including to prevent imminent physical damage or damage to property; 

● To detect, prevent, or otherwise address fraud, security, or technical issues; ● If PATH organizes the operation of the Services within a different framework, or through another legal structure or entity, or if PATH is acquired by, or merged into or with another entity, or if PATH enters bankruptcy, provided however, that those entities agree to be bound by the provisions of this Privacy Policy, with respective changes taken into consideration; 

● To collect, store, hold and manage your personal information through cloud based or hosting services or a third party or a party affiliated or connected to

PATH, as reasonable for business purposes, which may be located in the European Union and the U.S.A., potentially countries outside of your jurisdiction. 

Integration with social networks 

You may choose to share information between your PATH account and your social network account (such as Facebook). Through this option, you may choose to have personal information and other content about you available from social networks, transmitted and shared through the Services. Similarly, you may choose to have personal information and other content about you available from PATH, including your location and route information, transmitted to and shared through your social network account. 

By setting your PATH Account to integrate with social networks, including by signing onto PATH by using your social network account, you agree to share information (including personal information) between PATH and such social networks, for the purposes provided under this Privacy Policy. 

The social network’s use of information made available by PATH is governed by that social network’s privacy policy and controlled by the social network, not by this Privacy Policy or PATH. 

When you connect to the social network account through the Services for the first time or otherwise make the Services interact with your social network account, you will be asked by the social network to permit the social network to share your personal information stored on such social network with PATH. We collect your information from your social network account only in accordance with the permissions granted by you (such as your name, email address, list of friends, profile picture and other information available via the applicable social network). 

You understand and agree that the Services may access, make available and store such information so that it is available on and through your PATH Account, until your PATH Account is deleted.

Controlling your personal information 

You can always review and update certain information by visiting your Account & Login settings (such as your phone, name, photo and more) or the in-app left menu (to update your home, work and favorites). 

If you find that the information associated with your Account is not accurate, complete or updated, then you should make all necessary changes to correct it. Please keep in mind that false, incorrect, or outdated information may prevent you from setting up an Account and impair the ability to provide you with Services. 

Deleting your information 

If you would like us to delete your Account, please use the “Delete Account” function available under the in-app Privacy Setting. On receiving such a request, PATH will use reasonable efforts to delete such information, however please note that information may not be deleted immediately from our back-up systems. We aim to initiate the deletion process immediately after your request. Once we receive your request, your data will no longer be used to personalize your PATH experience. We then begin a process designed to safely and completely delete the data from our storage systems. This process generally takes around 2 months from the time of deletion. As with any deletion process, things like routine maintenance, unexpected outages, bugs, or failures in our protocols may cause delays in the processes and time frames defined in this policy. We maintain systems designed to detect and remediate such issues. 

How PATH retains data we collect 

Some data you can delete whenever you like, some data is deleted automatically, and some data we retain for longer periods of time when necessary. This section describes why we hold onto different types of data for different periods of time. 

● Information retained until you remove it - such as your “Home, “work”, favorites, email address and other account related information. We’ll keep this data in your PATH Account until you choose to remove it and/or update it.

● Data that expires after a specific period of time - in some cases, you don’t need to actively delete your information as we set retention timeframes based on the reason for the data’s collection. ● Information retained until your PATH Account is deleted - we may keep some data for the life of your PATH Account if it’s useful for helping us understand how users interact with our features and how we can improve our services. 

● Information retained for extended time periods for limited purposes - sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. 

Information Security 

PATH considers information security to be a top priority. PATH services are built with strong security features that continuously protect your information. PATH implements systems, applications and procedures to secure your personal information, to minimize the risk of theft, damage, loss of information, or unauthorized access or use of information. For example, we review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems. In addition, we restrict access to personal information to PATH employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations. 

The insights we gain from maintaining our services help us detect and automatically block security threats from ever reaching you. 

However, these measures are unable to provide absolute assurance. Therefore, although PATH takes great efforts to protect your personal information, PATH cannot guarantee and you cannot reasonably expect that PATH’s databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Compliance & cooperation with regulators 

We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it. 

Data transfers 

We store data on servers located around the world and your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. 

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly. 

European requirements 

If European Union (EU) or United Kingdom (UK) data protection law applies to the processing of your information, we provide the controls described in this policy so you can exercise your right to request access to, update, remove, delete, and restrict the processing of your information. 

You also have the right to object to the processing of your information. 

We process your information for the purposes described in this policy, based on the following legal grounds: 

With your consent 

We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. You can manage your settings at any time, including your in-app Privacy Settings. 

When we’re pursuing legitimate interests 

We process your information for our legitimate interests and those of third parties (such as partners including advertisers, in order to report use statistics) while applying

appropriate safeguards that protect your privacy. This means that we process your information for things like: 

● Providing, maintaining, and improving our services to meet the needs of our users ● Developing new services and features that are useful for our users 

● Understanding how people use our services (including how they interact with our ads) to ensure and improve the performance of our services 

● Customizing our services to provide you with a better user experience 

● Marketing to inform users about our services 

● Providing advertising, which keeps many of our services free 

● Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our services 

● Protecting against harm to the rights, property or safety of PATH, our users, or the public as required or permitted by law, including disclosing information to government authorities ● Performing research that improves our services for our users and benefits the public ● Fulfilling obligations to our partners like developers and rights holders 

● Enforcing legal claims, including investigation of potential violations of applicable Terms of Service 

When we’re providing a service 

We process your data to provide a service you’ve asked for under a contract (including our terms of use). 

When we’re complying with legal obligations 

We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to legal process or an enforceable governmental request. 

If you have questions, you can contact PATH and our data protection office at: privacy@path.co.uk. And you can contact your local data protection authority if you have concerns regarding your rights under local law. 

Last modified: 19 November 2021