PATHWAYS TO NUTRITION
Nutrition, Inc. (“Pathways”, “we” and “us”) with respect to information that we may obtain about you
through your use of any of our websites (each, the “Site”).
YOU REPRESENT AND WARRANT THAT YOU ARE LOCATED IN THE UNITED STATES.
IF YOU ARE NOT LOCATED IN THE UNITED STATES, YOU MUST CEASE YOUR USE OF
THE SITE IMMEDIATELY.
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1. What information do we collect from users of the Site, and how do we use it?
The following describes the types of information we may collect about you through the Site, and how we
use and maintain that information:
Information You Affirmatively Provide to Us
If the Site offers the option for you to set up an account on the Site, and you choose to set up such an
account, we may request certain personal information about you, such as your first and last name, email
address, mailing address or other contact information and personal details such as, but not limited to, your
age, height, weight, personality characteristics or personal preferences (collectively, your “Personal
Data”). Any Personal Data that you provide to us will be used for identification purposes, to communicate
with you regarding your use of the Site or the terms governing the Site, and to facilitate the functioning of
the Site. We may also use your Personal Data to notify you of new features on the Site, or to request that
you provide feedback to us about the Site. We may keep this information indefinitely.
Information Collected Automatically
• Usage Data. When you use the Site, we may collect certain usage data generated through your
use of the Site, such as information about your browser and device. We may use this information as part
of our providing the Site to you, and to improve the experiences of users with the Site. We may keep this
• Information Collected Through Automated Gathering Tools. Like most website, we may use
automated information gathering tools (like cookies) that are intended to make using the Site easier by,
among other things, saving your preferences for you. We may keep this information indefinitely, but we
do not use such information with any Personal Data that you have provided to us.
• Information Collected By Third-Party Integrated Services. Like many websites, we may also
implement certain third-party content on the Site, or integrate other third-party offerings into the Site,
enabling the third parties providing such content or offerings to collect information about you through
your use of the Site. Any information collected through such integrated technologies would be collected
directly by these third parties for use by them and other parties, subject to the privacy practices and
policies of such third parties.
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2. To whom do we disclose information about you collected through the Site?
We may disclose the information about you obtained through the Site (including your Personal Data)
either (i) when we have your permission or (ii) in any of the following situations without your permission:
• We may disclose information collected about you through the Site (including your Personal Data)
to our affiliates, as well as to third-party service providers who perform services on behalf of
Pathways in connection with our providing the Site or completing or confirming a transaction that
you conduct with us. When we transfer your Personal Data to a third-party service provider, that
service provider will be contractually required (a) to use such Personal Data only to carry out
adequate protection for such Personal Data (as required by applicable legal requirements).
• In furtherance of providing the Site, we may disclose certain information about you (including
your Personal Data) to other users of the Site to the extent they are authorized to receive such
• We may disclose the results of aggregated data about you and other users of the Site without
restriction. In such circumstances, we do not disclose to these entities any of your Personal Data.
• As part of a merger, acquisition or other sale or transfer of all or substantially all of Pathways’s
assets or business, we may disclose to one or more third parties information obtained about you
through the Site (including your Personal Data). We do not guarantee that any entity receiving
such information in connection with one of these transactions will comply with all of the terms of
• We may disclose information about you (including your Personal Data) to the government or to
third parties under certain circumstances when legally obligated to do so, such as in connection
with suspected illegal activity in connection with the Site, or to respond to a subpoena, court
order or other legal process. We reserve the right to release information collected through the Site
to law enforcement or other government officials, as we, in our sole discretion, deem necessary or
• We may also disclose information about you (including your Personal Data) to third parties if
needed to enforce any of the terms and conditions of the Site; to conduct any investigation of
potential violations thereof; to detect, prevent, or otherwise address fraud, security or technical
issues; or to protect against harm to any element of the Site.
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3. What security measures do we employ for information about you collected through the Site?
To help protect the privacy of data collected through the Site, we employ security measures intended to be
consistent with industry best practices. In addition, we take commercially reasonable steps to store certain
data collected through the Site with the objective of protecting such data against unauthorized access.
HOWEVER, NO TECHNOLOGY IS COMPLETELY SECURE. PLEASE BE AWARE THAT THE
SITE IS OPERATED ON SOFTWARE, HARDWARE AND NETWORKS, ANY COMPONENT OF
WHICH MAY, FROM TIME TO TIME, EXPERIENCE BREACHES OF SECURITY OR OTHER
PROBLEMS BEYOND OUR CONTROL.
data transmission over the Internet or via a Wi-Fi or mobile phone network, or through any encryption
method, can be guaranteed to be completely secure. You understand that it may be possible for third
parties not under Pathways’ control to intercept or access any information about you transmitted through
the Site or private communications. Accordingly, although we will take reasonable steps to protect the
security and integrity of all information you provide through the Site, Pathways cannot guarantee that any
such information, whether during transmission or while stored on our systems or otherwise in our care,
will be absolutely safe from intrusion by others who do not have your authorization. Any such
transmission or sharing of that information is done at your own risk.
4. How can you correct or update information about you that is stored by Pathways?
You may correct or update information collected about you through the Site (including your Personal
Data) by contacting us at the email address noted below. We will update our files as promptly as
We may retain original and updated information for reasons such as technical constraints, dispute
resolution, compliance with laws, fraud prevention, troubleshooting and agreement enforcement. In
addition, we are not responsible for updating or removing any information about you collected through
the Site that is already disclosed to third parties who have been provided such information as permitted by
At this time, Pathways does not support “Do Not Track” preferences that may be available in your
browser for letting websites know that you do not want them collecting certain kinds of information.
Specifically, if you turn on the Do Not Track setting on your browser, any online elements of the Site are
not currently capable of following whatever Do Not Track preferences you set. For more information
about Do Not Track, visit donottrack.us.
5. What are the policies of linked websites and other third parties?
Pathways. You should be aware that when you are using the Site, you may be directed to other apps or
websites that are beyond our control, and Pathways is not responsible for the privacy practices of third
parties. We would expect most, if not all, of these third parties will collect information about you when
you use their offerings. However, Pathways is not responsible for the privacy practices of third parties,
regardless of whether they are linked or otherwise connected to the Site. We encourage you to read the
6. What is our policy on children users of the Site?
We do not knowingly collect or maintain personally identifiable information from persons under 13 years
old, and no part of the Site is directed to persons under 13. IF YOU ARE UNDER 13 YEARS OF AGE,
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