PRIVACY POLICY
Effective Date: February 7, 2025
Pathways Foundation, which includes Pathways.org, Pathways Awareness, Pathways Center, Pathways Inclusion in Worship, and TEAM W (collectively, “Pathways.org,” “we,” “us,” “our”), respects your privacy. This Privacy Policy explains our collection and treatment of any personal information we collect about you online or offline, when you visit our websites including www.pathways.org (the “Site”), our mobile application, or otherwise interact with us (collectively, the “Services”). This Privacy Policy also details the choices you can make regarding our use of your personal information.
Please read our Terms of Use for more information about our practices.
Collection of Personal Information
We collect personal information from and about consumers who use our Services, such as when you join the mailing lists for Pathways.org newsletters and other mailings; use our Baby Milestones App; purchase an item online from Pathways.org; make an online contribution to Pathways.org; or register for access to certain pages on the Site. Depending on how you interact with us, we may collect the following categories of personal information about you:
· Identifiers, such as name, email address, mailing address, phone number, username, Internet Protocol address, unique identifiers, and other similar identifiers
· Demographics, such as gender and date of birth of baby, and relationship to baby
· Financial information, such as credit card number, debit card number, or any other financial information that does not allow access or withdrawal of funds
· Internet or Other Personal Information, such as information regarding your interactions with our app, websites, or advertisements, including duration and frequency of visits/sessions
· Health-related information, such as anticipated due date, baby milestones, activities completed, and birth information, such as duration of hospital/neo-natal intensive care unit (NICU) stay for babies born prematurely
· If you log onto the Services with your login credentials from a social networking site (e.g., Facebook or X (formerly, Twitter)) (each a “Social Networking Site”), we may receive from such Social Networking Site personal information such as your name, e-mail, gender, birthday, current city, and profile picture, as permitted by your privacy settings on that Social Networking Site
· Inferences drawn from any of the information listed above
Note that we may ask you to create a username and password to access certain restricted pages of our Services. You are not required to disclose your personal information to us. However, if you choose not to disclose certain personal information to us, we may not be able to process your requests or provide you with access to certain aspects of our Services.
Sources of Personal Information
We collect personal information directly from consumers who interact with us and our Services. We also collect personal information from vendors and third parties that provide information to us. We also collect personal information from vendors and third-party providers of cookies and other tracking technologies used on our Services.
Disclosure of Personal Information
We disclose the categories of personal information listed in the section titled “Collection of Personal Information” as detailed below:
· To our vendors. We disclose personal information to our vendors who process personal information on our behalf, including vendors who provide website hosting, information technology and infrastructure, data analytics and modeling, email delivery, auditing, payment processing, marketing and analytics services, and other services to us. We impose contractual limitations on our vendors’ use of personal information they collect in conjunction with providing services to us.
· To third parties for marketing purposes. We disclose personal information to third parties, such as third-party marketing and analytics providers, and other organizations for marketing purposes.
· To third parties to facilitate our programming and fundraising. We disclose personal information to other third parties to facilitate our programming and fundraising. For example, we may disclose personal information in the following scenarios, and for similar purposes and programs:
If you make a donation by credit card, debit card, PayPal, or other electronic means, personal information will be collected by the third-party payment platform or processor to facilitate your donation.
· To other third parties, at your direction or with your consent. We may disclose your personal information to any other third parties at your direction or with your consent.
We may also disclose your personal information in the following situations:
· Pursuant to a change of control. We may disclose personal information to a successor entity or purchaser upon a merger, consolidation, or other reorganization in which we participate, or a sale of all or a portion of our assets. In this situation, we will seek assurances that the successor entity or purchaser will process personal information collected by us in accordance with this Privacy Policy.
· For legal purposes. We may disclose personal information to protect our rights, defend or pursue a legal claim, investigate or prosecute illegal activities, comply with a subpoena, court order, governmental inquiry, legal process, or other legal obligation, or to protect the rights, property, or safety of us, you, or any other consumers.
To the extent required by applicable law, we will obtain your consent prior to making such disclosures of your personal information.
We may also disclose aggregated or anonymized data to other entities to the extent permitted by law.
Children’s Personal Information
We do not knowingly collect the personal information of anyone under the age of 13. If you are a parent or guardian and believe we have collected personal information from your child in error, please contact us immediately at friends@pathways.org so that we can make reasonable efforts to promptly remove such personal information from our systems.
We may, however, collect personal information about your child or a child under your care that you submit to us, such as information you provide regarding your child’s birth and developmental milestones, activities your child participated in, your child’s name, or your child’s address. We process such personal information in accordance with this Privacy Policy. We may use such personal information to customize your experience with the Services.
Third-Party Links to our Services
Our Services may contain links to websites and applications owned by other entities. If you decide to use these links, you will leave our Services. We are not responsible for the privacy practices or content provided by such third parties, and we make no representations or endorsements about them. If you decide to leave our Services to access third party links, it will be at your own risk. If leaving our Services, this Privacy Policy will no longer govern. Please review the terms and policies of any other third party when you navigate away from our Services.
Internet Information Security
Pathways.org takes reasonable precautions to ensure that any personal information you provide through our Services is kept confidential and stored in a secure environment, and that only those personnel with legitimate business purposes will have access to this information. Even so, we cannot guarantee that data provided to us will not be subject to loss, alteration, misuse, unauthorized access, disclosure, or destruction. It is important to be aware that all internet transmissions are subject to security breaches and errors. You should take precautions in choosing the information you send to Pathways.org and safeguard any passwords or special types of identification you use to access our Services.
Please note that we retain personal information only for the period reasonably necessary to provide our Services to you, support our business operational purposes listed in the section titled “Purposes for Processing Personal Information” above, and ensure compliance with applicable law or as otherwise in accordance with your consent.
International Notice
Personal information that is voluntarily submitted through our Services may be maintained or accessed in servers or files located in the United States under applicable United States comprehensive state data privacy laws. If you do not consent to having your information processed and stored in the United States, please do not provide it.
Cookies
We use cookies and other tracking technologies to allow you to stay logged on to our Services, to permit us to recognize repeat visitors, to facilitate your use of our Services, to track access and use of our Services, such as pages visited and links clicked, to analyze website traffic and improve user experience. At least some of data is collected through services like Google Analytics and is generally anonymized to protect user privacy.
Additional Disclosures for Certain U.S. Residents
This section provides disclosures for certain residents of U.S. states with comprehensive data privacy laws that apply to Pathways.org.
· Data Subject Rights. Residents of some U.S. states have certain rights with respect to the processing of their personal information. Depending on your state of residence, these rights may include rights to access, correct, and delete your personal information or a right to obtain personal information in a portable format. Some states also allow residents to opt out of the sale of personal information and to opt out of the processing of personal information for purposes of targeted advertising and profiling in furtherance of legal or similarly significant effects. Some states allow residents to revoke their consent to certain types of processing activities.
· Exercising Data Subject Rights & Authorized Agents. To exercise data subject rights applicable to you, you may contact us via email at friends@pathways.org or via mail at Pathways.org, 355 East Erie Street, Chicago, IL 60611. Residents of some states, including Colorado, may also authorize an agent to make data subject requests on your behalf. In such instances, authorized agents may use the same method as you to submit requests on your behalf. To verify your identity and protect your personal information, we may ask the requestor to provide information that will enable us to verify your identity in order to comply with your data subject request, such as asking your agent to provide proof of signed permission from you, or ask you to confirm with us directly that you provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law.
· Appeals. If we deny your request, residents of some states may appeal our decision by contacting us by email at friends@pathways.org. If you submit an appeal, please enclose or otherwise specifically reference your initial request so that we may appropriately assess and respond to your appeal. We will process appeals in accordance with applicable law.
· Sales & Processing for Purposes of Targeted Advertising. We sell personal information and process personal information for targeted advertising purposes, as those terms are defined by applicable state comprehensive data privacy laws. For example, we disclose personal information to third parties for marketing purposes. This includes information we collect via cookies and other tracking technologies, such as IP address and browsing data. It may also include sensitive inferences about you and/or your baby’s health.
We also collect contact details and related information, which we may disclose to other organizations we partner with for our and their marketing purposes. To opt out of these types of disclosures, you may contact us by email at friends@pathways.org or via mail at Pathways.org, 355 East Erie Street, Chicago, IL 60611.
· Opt-Out Preference Signals. Some web browsers or devices offer settings where you may pre-set a signal to websites that you do not want to have your online activity and behavior sold or processed for targeted advertising purposes. We recognize opt-out preference signals to the extent we are required to do so for compliance with applicable law. Please note, however, that our websites are not currently configured to recognize the “Do Not Track” signal.
· Profiling. We do not process personal information for profiling in furtherance of legal or similarly significant effects.
Please note that some state comprehensive data privacy laws, including the California Consumer Privacy Act (“CCPA”), do not regulate processing of personal information by 501(c)(3) non-profit organizations like Pathways.org. The disclosures in this section do not apply to consumers who reside in states with state comprehensive data privacy laws that do not apply to Pathways.org.
Other Disclosures
· California Residents Under 18. If you are under the age of 18 and a registered user of our websites, you may ask us to remove content or data that you have posted to our websites by emailing friends@pathways.org. Please note that your request does not ensure complete or comprehensive removal of the content or data as, for example, some of your content or data may have been reposted by another user.
· Direct Marketing Disclosure for California Residents. California’s “Shine the Light” law regulates the disclosure of certain personal information to third parties by a company for the recipients’ direct marketing purposes by requiring companies to provide certain information upon request and allow consumers to opt out of such disclosures. To make such a request, please contact us by emailing friends@pathways.org with the subject line “Shine the Light Request.” We process such requests in accordance with applicable law.
· Disclosure for Nevada Residents. We sell certain covered information, as defined by Nevada Revised Statute § 603A, as described in more detail in the section titled “Additional Disclosures for Certain U.S. Residents” above. To opt out of the sale of your covered information, Nevada residents may contact us by emailing friends@pathways.org.
Changes to Our Privacy Policy
We reserve the right to change or modify this Privacy Policy as needed. When we do so, we will post the updated Privacy Policy on this page and post a prominent notice of the change on our homepages.
Contacting Us
If you have any questions regarding this Privacy Policy or our privacy practices, please contact us by email at friends@pathways.org, by phone at 1-312-893-6620, or by mail at the below address :
Pathways.org
Attn: Privacy Team
355 E Erie St
Chicago, Illinois 60611