Privacy Policy

PATHWAYS TO NUTRITION

WEBSITE PRIVACY POLICY

This Privacy Policy describes the collection, storage, and dissemination practices of Pathways to

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”).

Please read this Privacy Policy carefully. By using or accessing the Site, you are accepting the practices

described in this Privacy Policy (which are optimized for compliance with U.S. law). If you do not agree

to all of the terms of this Privacy Policy, please do not download or use 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 indefinitely.

• 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 will not disclose your Personal Data to any third party, except as described in this Privacy Policy.

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

those services that we have requested; (b) to abide by this Privacy Policy; and (c) to provide

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

information.

• 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

this Privacy Policy.

• 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

appropriate.

• 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.

Please also be aware that despite our best intentions and the guidelines outlined in this Privacy Policy, no

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

reasonably possible.

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

this Privacy Policy.

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?

This Privacy Policy only addresses the use and disclosure of information obtained through the Site by

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

posted privacy policy whenever interacting with any third-party website, Site, or other offering.

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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