Privacy Policy

1. Who We Are

Path Community Inc Ltd, a company registered in England and Wales under company number [Company Number], whose registered office is at [Registered Office Address] (“Path Community”, “we”, “us”, “our”) is the data controller responsible for your personal data.

This Privacy Policy explains what personal data we collect from you, how and why we use it, who we share it with, and what rights you have, in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Data Protection Contact: [Name / “Path Community”], email [Contact Email]. ICO Registration Number: [ICO Registration Number, if applicable].

2. Personal Data We Collect

We collect the following categories of personal data:

Data you give us directly

• Account details: name, email address, phone number, password.
• Payment and billing information (processed by our payment provider — we do not store full card details).
• Profile and membership information, such as your Pathway progress, goals, and responses to check-in forms.
• Content you post or share in community spaces, group calls, WhatsApp groups, forms and coaching sessions.
• Correspondence when you contact us, for example by email or support chat.

Data we collect automatically

• Technical data: IP address, browser type, device information, and general location derived from your IP address.
• Usage data: pages visited, features used, time spent on the Service, referral source.
• Cookies and similar technologies (see Section 8).

Special category data

Personal development and coaching content may occasionally touch on sensitive topics (for example, mental health, relationships, or family circumstances) that you choose to share. We only process this data on the basis of your explicit consent, given by voluntarily sharing it, and we take extra care to protect it. You are never required to share more than you are comfortable with.

3. How We Use Your Data and Our Legal Basis

We use your personal data for the following purposes:

• To create and administer your membership account — necessary to perform our contract with you.
• To process payments and manage billing — necessary to perform our contract with you, and to comply with legal obligations (e.g. accounting and tax records).
• To provide coaching content, community access, events and support — necessary to perform our contract with you.
• To personalise your experience and track your progress through the Pathways — necessary to perform our contract with you.
• To send you service-related communications (e.g. billing notices, changes to these policies) — necessary to perform our contract with you and for our legal obligations.
• To send you marketing communications about Path Community — based on your consent, which you can withdraw at any time.
• To moderate community spaces and enforce our Terms and Conditions — based on our legitimate interests in maintaining a safe community, balanced against your rights.
• To improve and develop the Service, and for analytics — based on our legitimate interests in understanding how the Service is used.
• To detect, prevent and investigate fraud, abuse or security issues — based on our legitimate interests and legal obligations.

4. Who We Share Your Data With

We do not sell your personal data. We share personal data only where necessary, with:

• Service providers who support our operations, such as website hosting, membership/community platforms, WhatsApp (Meta), payment processors, email and marketing tools, and analytics providers.
• Our coaches and facilitators, to the extent necessary to deliver coaching and community support to you.
• Professional advisers, such as accountants, auditors and lawyers, where necessary.
• Regulators, law enforcement or other third parties where we are required to do so by law, or to protect the rights, safety or property of Path Community, our members or others.
• A buyer or successor, in the event of a sale, merger or reorganisation of our business, subject to appropriate safeguards.

Where we share data with processors, we have agreements in place requiring them to protect your data and use it only for the purposes we specify.

5. International Transfers

Some of our service providers may be based, or store data, outside the UK, including in the United States (for example, providers of hosting, email, WhatsApp/Meta, or analytics services). Where this happens, we ensure appropriate safeguards are in place, such as the UK International Data Transfer Agreement, the EU Standard Contractual Clauses (as extended to the UK), or reliance on an adequacy decision, so that your data continues to receive an appropriate level of protection.

6. Data Retention

We keep your personal data for as long as necessary to provide the Service and for the following periods thereafter:

• Account and membership data: for the duration of your membership, and for up to [6] years afterwards to meet legal, accounting and dispute-resolution obligations.
• Financial and billing records: for up to 6 years, as required by HMRC.
• Marketing consent records: until you withdraw consent, plus a reasonable period to evidence compliance.
• Community content and coaching notes: for the duration of your membership, and securely deleted or anonymised within a reasonable period after you leave, unless we are required to retain it for legal reasons.

After these periods, we securely delete or anonymise your data.

7. Your Rights

Under UK data protection law, you have the right to:

• Access the personal data we hold about you.
• Rectify inaccurate or incomplete data.
• Erasure of your data in certain circumstances (the “right to be forgotten”).
• Restrict or object to our processing of your data in certain circumstances.
• Data portability, to receive your data in a structured, machine-readable format.
• Withdraw consent at any time, where we rely on consent (this will not affect processing carried out before withdrawal).
• Complain to the Information Commissioner’s Office (ICO) at ico.org.uk, or by calling 0303 123 1113, if you believe we have not handled your data properly.

To exercise any of these rights, contact us at [Contact Email]. We will respond within one month, as required by law.

8. Cookies and Similar Technologies

Our website and platform use cookies and similar technologies to make the Service work, remember your preferences, and understand how the Service is used. These may include:

• Strictly necessary cookies, required for the Service to function (e.g. keeping you logged in).
• Analytics cookies, which help us understand usage and improve the Service.
• Marketing cookies, used to measure and improve our advertising (e.g. via Meta/Facebook Pixel), only set with your consent.

You can manage your cookie preferences via the cookie banner on our website, or through your browser settings. For more detail, see our [Cookie Policy], if published separately.

9. How We Keep Your Data Secure

We use appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse or alteration, including access controls, encryption of data in transit, and limiting access to personal data to those who need it. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Children

The Service is intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with personal data, please contact us and we will take steps to delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or the law. We will post the updated policy on our website with a revised “last updated” date, and where changes are material, we will notify you directly (for example, by email).

12. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at: Email: mike@pathcommunity.co.uk