Privacy Policy

Path Childhood Development, LLC, a limited liability company (“Company” or “we” or “us” or “our”) is publishing this Privacy Policy for its users (“user” or “you”) that use our mobile application located at www.path-app.com and on the Apple App Store, including other media forms, media channels, mobile Application or mobile application related or connected thereto (collectively, the “Application”). The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Application, about the types of information that Company may gather about or collect from you in connection with your use of the Application. It is also intended to explain the conditions under which Company uses and discloses that information, and your rights in relation to that information. Changes to this Privacy Policy are discussed at the end of this document.

Notice to Users Outside the United States

The Application is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Application from other jurisdictions, please be advised that you may be viewed as transferring your personal information to us in the United States, and by using our Application, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the Application and your agreements with us. Any persons accessing our Application from any jurisdiction with laws or regulations governing the use of the Internet (including personal data collection, use and disclosure), different from those of the jurisdictions mentioned above may only use the Application in a manner lawful in their jurisdiction. If your use of the Application would be unlawful in your jurisdiction, please do not use the Application. Further, note that your jurisdiction may offer a more limited or different level of protection with respect to the privacy of your data.

BY USING OR ACCESSING THE APPLICATION, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.

GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION

Users of the Application Generally

“Non-Personally Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally Identifying Information,” by contrast, is information such as an email address that, without more, can be directly associated with a specific person. 

Mobile Device Additional Terms

• Mobile Device. If you use a mobile device to access the Application or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system, and version information.

 • Social Media. We provide you the option to connect your account on the Application to your account on some social networking sites for the purpose of logging in, uploading information or enabling certain features on the Application. When logging in using your social network credentials, we may collect the Personally Identifying Information you have made publicly available on the social networking site. We may use hyperlinks on the Application which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. We let users log in using Email/Password, Sign in with Google, and Sign in with Apple. 

• Geo-Location Information. Unless we have received your prior consent, we do not access or track any location-based information from your mobile device at any time while downloading or using our mobile application.

• Push Notifications. We send you push notifications if you choose to receive them, you know when someone has sent you a message or for other service-related matters. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings. We send users push notifications when they receive a collaboration invite, when a child has new memories uploaded, when a user’s subscription expires, and a reminder to resubscribe or save their memories to their device before they are deleted (for lapsed subscribers).

Analytics

We collect user data to provide the Application’s services, analyze feature popularity, and identify and fix issues within the Application. This data helps us improve the user experience by understanding how users interact with the Application and ensuring that any technical problems are quickly resolved.

Aggregated and Non-Personally Identifying Information

We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on the Application and on Applications of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our shareholders the number of visitors to the Application and the most popular features or services accessed. This information does not contain any Personally Identifying Information and may be used to develop Application content and services that we hope you and other users will find of interest and to target content and advertising.

You may at any time review or change your Non-Personally Identifying Information by going to your account settings or contacting us using the contact information below. Upon your request, we will deactivate or delete your account and contact information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your account activity and accordance with our deactivation policy and applicable law.

Mobile Device Additional Terms

•  Mobile Device. If you use a mobile device to access the  or download any of our , we may collect device information (such as your mobile device ID, model and manufacturer), operating system, and version information.

SOCIAL MEDIA AND THIRD-PARTY LOGINS 

We may use hyperlinks on the Application which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. If you do not use these buttons, none of your data will be sent to the respective social network’s plugin provider. So for example, when you click on the Facebook’s “Like” button on the Application, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Application. Settings regarding privacy protection can be found on the Applications of these social networks and are not within our control.

COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION 

Application Registration

As defined above, Personally Identifying Information is information that can be directly associated with a specific person. Company may collect a range of Personally Identifying Information from and about Application users. Much of the Personally Identifying Information collected by Company about users is information provided by users themselves when (1) registering for our service, (2) logging in with Google or Apple, (3) participating in polls, contests, surveys or other features of our service, or responding to offers or advertisements, (4) communicating with us, (5) creating a profile or (6) signing up to receive newsletters. Users of the Application are under no obligation to provide Company with Personally Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Application features.

BY REGISTERING WITH OR USING THE APP, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.

Online Postings

Certain Personally Identifying Information collected from users may be disclosed as a matter of course as a result of your use of the Application. We may provide areas on the Application where you can post reviews and other information relating to your activities on the Application. Such postings are governed by our Terms of Use. In addition, such postings may appear on other Applications or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information. USERS ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR VOLUNTARY DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION.

Company Communications

We may occasionally use your email address and username to send you notifications regarding new services offered by the Application that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. We send you push notifications if you choose to receive them, letting you know when someone has sent you a message or for other service-related matters. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings. Generally, you may opt out of such emails at the time of registration or through your account settings, though this may not opt you out of all emails, such as notices about your account, including service announcements and administrative messages.

Use of Personally Identifying Information

Company uses the Personally Identifying Information in the file we maintain about you, and other information we obtain from your current and past activities on the Application (1) to deliver the products and services that you have requested; (2) to manage your account and provide you with customer support; (3) to communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, our affiliate companies or other third parties; (4) to develop and display content and advertising tailored to your interests on the Application and other sites; (5) to resolve disputes and troubleshoot problems; (6) to measure consumer interest in our services; (7) to inform you of updates; (8) to customize your experience; (9) to detect and protect us against error, fraud and other criminal activity; (10) to enforce our Terms of Use; and (11) to do as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems.

The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you use a mobile device to access our Application, we may collect device information. We do not access or track any location-based information from your mobile device unless we have received your prior consent. We send you push notifications if you choose to receive them for service-related matters. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

Company Disclosures

Company will disclose Personally Identifying Information under the following circumstances: 

• By Law or to Protect Rights. When we believe disclosure is appropriate, we may disclose Personally Identifying Information in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Company, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; to enforce our Terms of Use or other agreements or policies, in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.

• Marketing Communications. Unless users opt-out from receiving Company marketing materials upon registration, Company may email users about products and services that Company believes may be of interest to them. If you wish to opt-out of receiving marketing materials from Company, you may do so by following the unsubscribe link in the email communications, by going to your account settings (if applicable) or contacting us using the contact information below.

• Business Transfers; Bankruptcy. Company may disclose all Personally Identifying Information in its possession to a successor organization in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of Company’s assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personally Identifying Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt-out of it. Personally Identifying Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor organization. 

Employees, Contractors, and Consultants:  Some Company employees and operations contractors, and consultants may have limited access to your Personal Information in the course of providing services to you, including for the purpose of troubleshooting problems and/or resolving complaints. These contractors include vendors and suppliers that provide us with technology, services, and/or content for the operation and maintenance of the App. Access to your Personal Information is limited to the information reasonably necessary for the employee or contractor to perform the function needed to resolve the issue or to provide or improve the service. Currently, only Company employees have limited access to your Personal Information. 

Your Ability to Change Personally Identifying Information; Account Termination

We retain Personally Identifying Information (PII) as long as your account exists. You may delete your account from within the application or request that it be deleted, and we will remove your data from our system to the extent possible. However, please note that we may retain certain PII in our files for specific reasons, including:

• Preventing fraud

• Troubleshooting technical issues

• Assisting with investigations

• Enforcing our Terms of Use

• Complying with legal obligations, as permitted by law

As a result, not all of your PII may be fully removed from our databases in response to a deletion request. Additionally, we may maintain a record of any changes to your information to help investigate suspected fraud or security issues.

We contractually prohibit our contractors, affiliates, vendors, and suppliers from disclosing your Personally Identifying Information, other than in accordance with this Privacy Policy. However, third parties are under no obligation to comply with this Privacy Policy with respect to Personally Identifying Information that you provide directly to those third parties, or that those third parties collect for themselves. These third parties include advertisers, providers of games, utilities, widgets, and a variety of other third-party applications accessible through the Application. We neither own nor control the third-party Applications and applications accessible through the Application. Thus, this Privacy Policy does not apply to information provided to or gathered by the third parties that operate them.

Children's Personally Identifying Information

The features, programs, promotions and other aspects of our service requiring the submission of Personally Identifying Information are not intended for anyone under 16 years of age. We do not knowingly collect Personally Identifying Information from children under the age of 16 other than minor children receiving the service through registration by their parent or legal guardian. If you are under 16 then you may not use or access our Application or services at any time or in any manner.  If you are a parent or guardian of a child under the age of 16 and believe he or she has disclosed Personally Identifying Information to us please contact us at support@path-app.com. A parent or guardian of a child under the age of 16 may review and request deletion of such child’s Personally Identifying Information as well as prohibit the use thereof. 

COLLECTION AND USE OF INFORMATION BY THIRD PARTIES, INCLUDING ANALYTICS PROVIDERS

Company contractually prohibits its contractors, affiliates, vendors and suppliers from disclosing Personally Identifying Information received from Company, other than in accordance with this Privacy Policy. We use third-party services such as Firebase to store and process user data to provide the Application’s services, analyze performance, and resolve technical issues. These services, managed by Google, process data on our behalf and are contractually prohibited from sharing Personally Identifying Information for purposes beyond providing and improving the Application’s services. Data collected through Firebase is used solely for the purposes of maintaining the Application, ensuring performance, and improving the user experience.

SECURITY

We use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse.  However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures. 

We are dedicated to protect all information on the Application as is necessary. However, you are responsible for maintaining the confidentiality of your Personally Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.

PRIVACY POLICY CHANGES

Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Company’s Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Users should regularly check this page for any changes to this Privacy Policy. Company will always post new versions of the Privacy Policy on the Application. However, Company may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information.

CALIFORNIA PRIVACY RIGHTS

You have the right to request that we disclose to you:

the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;

in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:

for sales, the personal information categories purchased by each category of recipient; and

for disclosures for a business purpose, the personal information categories obtained by each category of recipient.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be “portable”, i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.

CONTACT INFORMATION

If you have any questions regarding our Privacy Policy or complaints regarding your privacy rights, please submit your complaint in writing to support@path-app.com.

We will not retaliate against you for filing a complaint.

In addition, you can complain to: 

Federal Trade Commission, Consumer Response Center, 600 Pennsylvania Avenue, NW Washington, DC 20580

Room 509F, HHH Building

Washington, D.C. 20201

For additional information, contact the Federal Trade Commission at 1-877-FTC-HELP (1-877-382-4357) or online at www.ftccomplaintassistant.gov.  

EFFECTIVE DATE

This Privacy Policy is effective as of June 26, 2024, and, was last updated on September 19, 2024.

If we change the terms of this Privacy Policy, then we will post the new Privacy Policy at path-app.com and on our Application. Any new Privacy Policy will apply to all the information that we maintain, including information that was created prior to the change.