EXPLORING PATHS, INC
Privacy Policy
Last modified: May 18, 2020
Exploring Paths, Inc. and its subsidiaries and/or affiliates, including EP Ventures, LLC (collectively, “Exploring Paths,” “we,” “us” or “our”), respect your privacy and are committed to protecting it through compliance with this policy (the “Privacy Policy”).
This Privacy Policy describes how we look after your personal data when you visit our website (regardless of where you visit it from) and the types of information we may collect from you or that you may provide when you visit our website www.exploringpaths.com and any affiliate sites including social media outlets (collectively, our “Site”) and our practices for collecting, using, maintaining, protecting, processing and disclosing that information (collectively, “Your Data”). Exploring Paths is the controller and responsible for the information we collect from you.
This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below.
1. PURPOSE OF THIS PRIVACY POLICY AND MORE ON EXPLORING PATHS
2. AUTHORIZED USERS OF THE SITE
3. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
4. INFORMATION YOU PROVIDE TO US
5. INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES
6. THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES
7. HOW WE USE YOUR INFORMATION
8. DISCLOSURE OF YOUR INFORMATION
9. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
10. ACCESSING AND CORRECTING YOUR INFORMATION
11. DATA SECURITY
12. CHANGES TO OUR PRIVACY POLICY
13. INTERNATIONAL TRANSFER
14. CONTACT US
IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, DO NOT USE ANY OF THE SERVICES.
1. PURPOSE OF THIS PRIVACY POLICY AND MORE ON EXPLORING PATHS.
This privacy policy aims to give you information on how Exploring Paths collects and processes Your Data through your use of our Site. We are the controller and responsible for Your Data.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
If you have any questions about the Privacy Policy or our privacy practices, please contact our data privacy manager in the following ways:
Exploring Paths, Inc.
300 Delaware Avenue, Suite 210-A
Wilmington, DE 19801
+1.302.219.3833
You have a right to make a complaint at any time. We would, however, appreciate the chance to deal with your concerns so please contact us in the first instance.
This Privacy Policy applies to information we collect:
· On this Site.
· In email, text, and other electronic messages between you and this Site.
· Through mobile and desktop applications you download from the Site, which provide dedicated non-browser-based interaction between you and this Site.
· When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.
· When you use our Services as defined in the Terms of Service available to you at www.exploringpaths.com/terms-of-service (the “Terms”).
It does not apply to information collected by:
· Us offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates, subsidiaries and Merchants); or
· Any third-party (including our affiliates, subsidiaries and Merchants), including through any application or content (including advertising) that may link to or be accessible from or on the Site.
Terms not otherwise defined herein have the meaning set forth in the Company’s Terms of Service found at www.exploringpaths.com/terms-of-service Exploring Paths provides Services to individuals. We may be a Data Processor (as defined below) or Data Controller (as defined below) and Data Processor simultaneously.
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Site. By accessing or using this Site, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to our Privacy Policy). Your continued use fo this Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
2. AUTHORIZED USERS OF THE SITE
This Site is offered and available to users subject to the Company’s Terms of Services, www.exploringpaths.com/terms-of-service, who are 18 years of age or older, and reside in the United States or any of its territories or possessions; or youth over the age of 13 who have received permission from a parent or legal guardian. If you are under the age of 18, you must ask your parent or guardian for permission to use this Site. If you are under 13, you must ask your parent or legal guardian create an account and ask your parent or legal guardian to create a sub-account for you.
Children’s COPPA Privacy Notice. We do not knowingly collect personally identifiable information from children under the age of thirteen. The first page of our intake form for prospective new subscribers is a request for a first name and age. If a prospective new subscriber lists his or her age as under 13, then we will direct that prospective new subscriber to ask his or her parent or legal guardian to subscribe and to create a sub-account for the child under 13. If you believe we might have any information from or about a child under 13, please contact us at support@exploringpaths.com For further detail regarding our interactions with children under 13, please see our COPPA Privacy Notice available here.
3. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
We may collect several types of information from and about users of our Site and you may provide us with certain information at your discretion, which may include information:
· by which you may be personally identified, such as name, postal address, e-mail address, age, gender, your use of our Services, telephone number and any other identifier by which you may be contacted online or offline ("personal information");
· that is about you but individually does not identify you; and/or
· about your internet connection, the equipment you use to access our Site and usage details.
We collect this information:
· Directly from you when you provide it to us including through our rendering of the Services.
· Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies including tracking technologies such as GPS used in conjunction with your use of our Services.
· From third parties, for example, our business partners including Merchants.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We do not require you to provide any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal identifiable information. Unfortunately, no data transmission over the internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that (a) there are security and privacy limitations inherent to the internet which are beyond our control; and (b) security, integrity and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.
Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through a public message board, this information may be collected and used by others.
4. INFORMATION YOU PROVIDE TO US
The information we collect on or through our Site may include:
· Information that you provide by filling in forms on our Site. This includes information provided at any time during any registration to use our Site and information provided at the time of subscribing to our Services, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Site.
· Records and copies of your correspondence (including email addresses), if you contact us.
· Your responses to surveys that we might ask you to complete for research purposes.
· Details of transactions you carry out through our Site.
· Your search queries on the Site.
· Information that you provide to us including to our Merchants.
You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Site, or transmitted to other users of the Site or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. Your User Contributions may be accessible by the general public and are being disclosed at your own risk.
5. INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES
As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
· Details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.
· Information about your computer and internet connection, including your IP address, operating system, and browser type.
· Information that identifies a device's location (geolocation information).
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
The information we collect automatically is statistical data and may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:
· Estimate our audience size and usage patterns.
· Store information about your preferences, allowing us to customize our Site according to your individual interests.
· Speed up your searches.
· Recognize you when you return to our Site.
The technologies we use for this automatic data collection may include:
· Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.
· Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies.
· Web Beacons. Pages of our Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
· Geolocation Information. Information that identifies a device's location.
We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us. Please see additional information on our Cookie Policy at [LINK].
From time to time, we may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or general communication. In order to improve our Services, we may receive a notification when you open an email from us or click on a link therein.
We may store your date on servers provided by third party hosing vendors with whom we have contracted.
6. THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES
Some content or applications, including advertisements, on the Site are served by third-parties, including advertisers, ad networks and servers, content providers, application providers and our Merchants. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. Google has outlined how they use your data here: How Google Uses Your Data
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
We may keep track of the websites and other pages you use within our Site or through our Site in order to determine which Services are the most popular and we may use tracking technologies including GPS to determine which Services you utilize. This data could be used to deliver customized content and advertising within our site to our customers whose behavior indicates they are interested in a particular subject are or Service and/or for purposes of measuring the use of our Services and for contest purposes.
7. HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information:
· To present our Site and its contents to you.
· To render Services to you.
· To provide you with information, products, or services that you request from us.
· To fulfill any other purpose for which you provide it.
· To provide you with notices about your account if applicable, including expiration and renewal notices.
· To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
· To notify you about changes to our Site or any products or services we offer or provide though it.
· To allow you to participate in interactive features on our Site.
· In any other way we may describe when you provide the information.
· For any other purpose with your consent.
We may also use your information to contact you about our own and third-parties' (including our Merchants) goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile if applicable.
We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
8. DISCLOSURE OF YOUR INFORMATION
Do not submit your information if you do not want it collected, used and disclosed.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this Privacy Policy:
· To our subsidiaries and affiliates including our Merchants.
· To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
· To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Site users is among the assets transferred.
· To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties including our Merchants to keep personal information confidential and use it only for the purposes for which we disclose it to them. To fulfill the purpose for which you provide it. For any other purpose disclosed by us when you provide the information. With your consent.
We may also disclose your personal information:
· To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
· To enforce or apply our terms of service, www.exploringpaths.com/terms-of-service or terms of sale and other agreements, including for billing and collection purposes. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
9. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
Do not submit your information to us if you do not want it collected, used and disclosed.
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
· 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. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. 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. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, do not submit your information.
· Promotional Offers from the Company. If you do not wish to have your email address and/or contact information used by the Company to promote our own or third parties' products or services, you can opt-out by checking the relevant box located on the form on which we collect your data if applicable or any other opt-out method we provide to you or by sending us an email stating your request to support@exploringpaths.com If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
· 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 contacting us at support@exploringpaths.com
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
10. ACCESSING AND CORRECTING YOUR INFORMATION
You can review and change your personal information by logging into the Site and visiting your account profile page.
You may also send us an email at support@exploringpaths.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Site users. Proper access and use of information provided on the Site, including User Contributions, is governed by our terms of service found at www.exploringpaths.com/terms-of-service
11. DATA SECURITY
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Any payment transactions will be encrypted.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.
Unfortunately, the transmission of information via the internet is not completely 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.
We may retain and use Your Data as necessary to comply with our legal obligations, or resolve disputes. We will try to delete Your Data within the time limits imposed by applicable law, if any upon request. If we have no justifiable business need to process Your Data, we will either delete or anonymize it, or, if this is not possible, for example, in case Your Data has been stored in backup archives, then we will securely store Your Data and isolate it from any further processing until deletion is possible.
Retention requirements can vary by country, so we generally apply the retention periods as follows: We retain any information collected via cookies, such as behavior data, including but not limited to clear gifs, flash cookies, webpage counters and other technical or analytics tools up to one year from expiry of the cookie or the date of collection. Your Data used for marketing purposes is stored indefinitely until you unsubscribe. Once you are unsubscribed from marketing communications, we add your contact information to our suppression list to ensure we respect your unsubscribe request. As required by applicable law, we will inform you that a call will be recorded if it is, and any telephone calls with you may be kept for a period of up to six years.
Opt-in
If you sign up to receive promotional information, marketing offers, or announcements from us, the emails that you will receive will include the capability to opt-out through a link. Transactional and billing communications are not considered “marketing” or “informational” communications.
California Privacy Rights
A business subject to California Civil Code section 1798.83 is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed Your Data information within the previous calendar year, along with the type of Your Data disclosed, for the third parties’ direct marketing purposes. Please note that under California law, businesses are only required to respond to a customer request once during any calendar year. If you are a California resident and would like to make either type of request described above, please contact us at support@exploringpaths.com.
12. CHANGES TO OUR PRIVACY POLICY
It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your account or through a notice on the Site home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this Privacy Policy to check for any changes.
13. INTERNATIONAL TRANSFER
Site visitors from the European Economic Area and United Kingdom and Switzerland (collectively, “EEA”) should consider that many of our external third parties are based outside the EEA so the processing of your personal data will involve transfer of data outside the EEA. If we transfer personal data (including out of the EEA), we ensure a similar degree of protection afforded to ensuring the following safeguards is implemented: Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
This section is designated to interactions with individuals who are in the United Kingdom, Switzerland or the European Economic Area (collectively designated as the “Designated Countries”) at the time of data collection.
We may ask you to identify which country you are in when you interact with us, or we may rely on your IP address to do so. When we rely on your IP address, the terms of this section cannot be applied to any individual that masks or otherwise hides their location information from us, such as using a VPN or a proxy, so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Privacy Policy, the terms in this section shall apply for Designated Countries users.
Site visitors from the EEA should consider that many of our external third parties are based outside the EEA so the processing of your personal data will involve transfer of data outside the EEA. If we transfer personal data (including out of the EEA), we ensure a similar degree of protection afforded to ensuring the following safeguards is implemented: Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EEA and the US. For further details, see Euro Commission: EU-US Privacy Shield.
Exploring Paths is a Data Controller with regard to Your Data that is collected during your interactions (“Interactions”) with our Site and/or Services. As a “Data Controller”, we determine the purpose and the manner in which the Your Data is processed. Any third parties that handle Your Data in accordance with our instructions are our service providers and assist us with serving as “Data Processors.”, while you are a “user”, an individual providing Your Data to us via an Interaction, such as contacting us, signing up for our newsletter(s), using our website, or otherwise accessing or using our services and the resources that we provide.
Exploring Paths is a Data Controller with regard to Your Data that is collected during your Interactions with our Site and/or Services. As a “Data Controller”, we determine the purpose and the manner in which the Your Data is processed. Any third parties that handle Your Data in accordance with our instructions are our service providers and assist us with serving as “data processors.”, while you are a “user”, an individual providing Your Data to us via an Interaction, such as contacting us, signing up for our newsletter(s) or other communications, using our Site, or otherwise accessing or using our Services and the resources that we provide.
If you are located in the EEA, you will only be contacted by electronic means, including email or SMS, based on our legitimate interests, as permitted by applicable law, or the individual’s consent. To the extent we can rely on legitimate interest under the applicable law, we will only send you information about our Services and other materials that are similar to those which were the subject of a previous Interaction with you. Should you not want us to use Your Data in this way please proceed to opting-out on the profile page of your account. You can also opt out, by click an unsubscribe link in your emails, or contact us at EEAsupport@exploringpaths.com. You can object to direct marketing at any time.
When you Interact with us, we provide you with the rights described below:
· We may limit these privacy rights requests (a) where denial of access is required or authorized by law, (b) to protect our rights and properties, (c) when granting access would have a negative impact on others’ privacy, or (d) where the request is frivolous or burdensome. If you would like to exercise your rights under applicable law, please contact us at EEAsupport@exploringpaths.com. We may ask to verify your identity when we receive your request in order to ensure the security of Your Data.
· You may have the right to access Your Data that we hold, and in some limited circumstances, have Your Data provided to you so that you can provide it to another controller.
· You have the right to withdraw your consent for any consent-based processing of Your Data. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
· You have the right to object to the processing of Your Data at any time and as permitted by applicable law if we process Your Data on the legal bases of: consent; contract; or legitimate interests. We may continue to process Your Data if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
· In compliance with the Privacy Policy, we commit to resolve complaints about our collection or use of Your Data. EEA residents should first contact us at EEAsupport@exploringpaths.com
If you have questions, or would like to exercise any of the above rights you may reach our Data Protection Officer (“DPO”) at EEAsupport@exploringpaths.com.
Our legal basis for collecting and using Your Data, as described above, will depend on the type of data being collected, the specific context in which we collect it and the purposes for which it is used.
14. CONTACT INFORMATION
If you are outside of the EEA, to ask questions or comment about this Privacy Policy and our privacy practices, contact us at:
If you are inside the EEA, to ask questions or comment about this Privacy Policy and our privacy, contact us at EEAsupport@exploringpaths.com