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PATHABLE, INC. PRIVACY POLICY

Last Updated: April 24, 2019

Welcome to the Web site of Pathable, Inc., a Delaware corporation (‘Pathable,’ ‘we,’ or ‘us’).  This privacy policy describes our collection of personal information from users of our Web site at pathable.com (the ‘Site’), and in connection with our online social networking and event management service (the ‘Service’ and, together with our Site, our ‘Services’), as well as our use and disclosure of that information. By using our Services, you consent to the collection and use of personal information in accordance with this policy.

*Personal Information *‘Personal information,’ as used in this policy, is information that specifically identifies an individual, such as an individual’s name, address, telephone number, or e-mail address. Personal information also includes information about an individual’s activities, such as information about his or her activity on our Services, and demographic information, such as date of birth, gender, geographic area, and preferences, when any of this information is linked to personal information that identifies that individual.

Personal information does not include ‘aggregate’ or other non-personally identifiable information. Aggregate information is information that we collect about a group or category of products, services, or users that is not personally identifiable or from which individual identities are removed. We may use and disclose aggregate information, and other non-personally identifiable information, for various purposes.

Collection of Information
Passive Information Collection

When you visit and use our Services, some information is automatically collected, such as your IP address, browser type, system type, the content and pages that you access on our Services, ‘referring URL’ (i.e., the page from which you navigated to our Services), the pages or areas you navigate to our Services, and from which you leave our Services, as well as the time you spend using our Services.

We collect this information passively using technologies such as standard server logs and cookies. We use passively-collected information to administer, operate, and improve our Services and our other services and systems, and to provide services and content that are tailored to you. If we link or associate any information gathered through passive means with personal information, we treat the combined information as personal information under this policy. Otherwise, we use information collected by passive means in non-personally identifiable form only.

Also, please be aware that third parties may set cookies on your hard drive or use other means of passively collecting information about your use of their services or content. We do not have access to, or control over, these third-party means of passive data collection.

Collection of Voluntarily Provided Information

We collect personal information that our users provide to us in a variety of ways on our Services. For instance, when you register to attend an event that is making use of our Services, create or update a profile on our Services, post information for other event attendees, request help or support, or otherwise communicate with us, we collect the personal information that is provided to us. By these methods, we may collect personal information such as name, e-mail address, city, state, other demographic information, photographs, ‘tags’ that you specify, and your interests, experiences, and preferences.

Information from Other Sources

We may receive information about you, including personal information, from third parties (e.g., the producer of the event you are attending), and may combine this information with other personal information we maintain about you. If we do so, this policy governs any combined information that we maintain in personally identifiable format.

Use of Personal Information

We use personal information to provide services and information that you request; to enhance, improve, operate, and maintain our Services, and our other programs, services, and systems; to prevent fraudulent use of our Services; to provide customized information and content, and otherwise to customize the Services; to maintain a record of our dealings with you, and for other administrative purposes.

For example, when you register for an event on our Services, we maintain your name, email address, and other personal information that you provide in connection with that event, in order to prepopulate certain user profile fields if you register for another event using our Services.

We may also use personal information you provide to deliver text messages, telephone calls, and other communications placed by event hosts and other users of our Services to you using voice and text calling services, and e-mail, “push notification” and direct Web-based messaging, that may be offered on our Service (‘Contact Features’).  Contact Features may, for example, allow event hosts to place telephone calls to, and to send text messages, email messages, and Web-based direct messages to, registered attendees of their events, and may allow event attendees to use those methods to contact other Service users who are registered for the same events.  Our Contact Features use ‘masking’ controls that prevent display of the telephone numbers and email addresses of the Service users on both ends of messages sent to a user’s telephone number or email address using the Contact Features.  We may also offer other privacy controls that allow you to limit some or all forms of communications that you may receive by way of our Contact Features.  Some messages that you send using Contact Features for a particular event (e.g., ‘tagged’ messages) may be displayed to all registered attendees for that event, but others generally are not accessible to users other than the sender and recipient. The system will always explicitly inform you that your message can be viewed by any authenticated user through the use of the word “public” (or its localized equivalent) when posting messages. We have the right, but not the obligation, to access and review messages sent using Contact Features.  We do not, however, actively monitor or screen those messages in the regular course of offering our Services.

*Disclosure of Personal Information * Owing to the nature of the Service, we disclose the personal information that you provide to us in connection with your registration for and participation in an event, including contact information, to the person or entity producing the event (‘Event Host’), as well as to persons authorized to access our Service on the Event Host’s behalf.  Additionally, as described below in the ‘Personal Information Available to Third Parties’ section below, personal information that you include in an event profile, a comment to a conversation thread, a user profile, or in any other information you post to portions of our Services that are accessible to other users (each, a ‘Submission’) may be made available to other users of our Service, as well as to the Event Host(s) for the event and his or her authorized users.  Event Hosts and their authorized users may use personal information that they obtain from your use of the Services for various purposes.  For example, Event Hosts may print event badges generated with our Service, containing your name and other personal information that you have provided, for you to wear at the Event Host’s event.  The use and disclosure by Event Hosts and their authorized users of such personal information is governed by the Event Host’s own privacy policies, and you are encouraged to check with each Event Host regarding its policies governing its use and disclosure of personal information. We do not have control over Event Hosts’ use of personal information that you provide in connection with that Event Host’s event.

Additionally, we may disclose personal information to third-party service providers (e.g., payment processing and data storage and processing facilities) that assist us in our work. We limit the personal information provided to these service providers to that which is reasonably necessary for them to perform their functions. All such third-parties are required to abide by the same privacy and security standards that we, ourselves, are held to.

We may also disclose personal information if we believe that doing so is legally required or is in our interest to protect other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.

In addition, information about our users, including personal information, may be disclosed as part of any merger, acquisition, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of our business assets. However, such third-parties would be required to abide by the same privacy and security standards to which we, ourselves, are held, or else would not have rights to such information.

*Personal Information Available to Third Parties *

Some features on our Services may allow you to post or submit personal information that is made available to other users of our Services.  For example, if you post a Submission, any personal information that you include with that Submission will be made available to other users of our Services who are registered for that same event, as well as the Event Host(s) for that event, who view it.  You include personal information in any Submissions, and in any messages that you send using Contact Features, at your sole risk.  We cannot control the actions of other users with whom you choose to share information.  We may allow you to select privacy options that limit some third-party access to certain types of Submissions, but no security measures are impenetrable or perfect.

Additionally, even after information posted on our Services is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on our Services.  We cannot warrant or guarantee that any personal information that you provide on and in connection with our Services (including, without limitation, personal information included in Submissions) will not be accessed, viewed, or used by unauthorized persons.

Note that Pathable, Inc. is required by law to disclose personal information to cooperate with lawful requests by public authorities, including to meet national security or law enforcement requirements. Pathable is also subject to the investigatory and enforcement power of the Federal Trade Commission (FTC) and the Department of Transportation.

Choice and Access

Access and control over most personal information that we maintain is available through the user profile editing tools on the Service.  Registered users may modify profile information, and may delete personal information that is not required for registration, at any time by logging into their account and making the applicable changes.  Registered users may also request deletion of their account by sending a request to account-removal@pathable.com. Deleted information may persist in backup copies for a reasonable period of time, but will not be generally available to other users of our Services.

Note too that individuals may, under certain conditions, invoke binding arbitration.

Links

For your convenience, our Services may contain links to other Web sites, products, or services that we do not own or operate.  If you choose to visit or use any third-party products or services, please be aware that this policy will not apply to your activities or any information you disclose while using third-party products or services or otherwise interacting with third parties.

Children Children’s safety is important to us, and we encourage parents and guardians to take an active interest in the online activities of their children.  We do not knowingly collect personal information from children under the age of 13 without obtaining parental consent.

Security We use reasonable security measures that are designed to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please note, however, that no data security measures can be guaranteed to be completely effective. Consequently, we cannot ensure or warrant the security of any personal information or other information. You transmit personal information to us at your own risk.

Principles

Pathable, Inc. complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Pathable, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, Pathable commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Pathable at privacy@pathable.com.

Pathable has further committed to refer unresolved Privacy Shield complaints to International Centre for Dispute Resolution, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.icdr.org/Support for more information or to file a complaint. The services of the International Centre for Dispute Resolution are provided at no cost to you.

Choice

If you are a Pathable Inc. customer and would like to opt-out of getting marketing communications from Pathable Inc. please contact us at support@pathable.com or follow the unsubscribe instructions included in each marketing email. Please note that if you are a trial or paying customer, you can not opt out of service and system generated emails.

Correcting and Updating Your Information

Customers may update or change the personal information they have provided Pathable Inc. by logging into the Service and providing such additional information where applicable. If you are our customer and would like to gain access to, or request deletion of information we have collected as “data controllers,” please contact us at support@pathable.com.

Data Retention

Pathable Inc. will retain personal information we process on behalf of our customers for as long as needed to provide Service to our customers, subject to our compliance with this Policy. We may further retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Onward Transfer

Pathable warrants that it will not transfer any personal information data to any third-party without first ensuring that the third-party is also obligated to adhere to Privacy Shield principles, and if that third-party is acting as a ‘controller’, such as processing or storing the data for you, that Pathable has a contract in place with that third-party obligating them to adhere to the principles of the Privacy Shield and spelling out that the data can only be used for limited, specific purposes.

In cases of onward transfer to third parties of Personal Data received pursuant to the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, Pathable is potentially liable.

Updates to this Policy

We may occasionally update this policy. When we do, we will also revise the ‘last updated’ date at the beginning of the policy. Your continued use of our Services after such changes will be subject to the then-current policy. We encourage you to periodically review this policy to stay informed about how we collect, use, and disclose personal information.

Contacting Us

If you have any questions, comments, or concerns about this privacy policy, please contact us using the following contact information:

Pathable, Inc.
4065 4th Ave NE
Seattle, WA 98105
(866) 809-0252 / +1 (503) 847-2753

info@Pathable.com

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