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 Pathways to Nutrition

Mobile Application 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 mobile applications (each, the “App”).

Please read this Privacy Policy carefully. By using or accessing the App, 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 App.


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  1. What information do we collect from users of the App, and how do we use it?

The following describes the types of information we may collect about you through the App, and how we use and maintain that information:

Information You Affirmatively Provide to Us

If the App offers the option for you to set up an account on the App, 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 your age, height and weight (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 App or the terms governing the App, and to facilitate the functioning of the App. We may also use your Personal Data to notify you of new features on the App, or to request that you provide feedback to us about the App. We may keep this information indefinitely.

Information Collected Automatically

  • Usage Data. When you use the App, we may collect certain usage data generated through your use of the App, such as information about your mobile device and operating system. We may use this information as part of our providing the App to you, and to improve the experiences of users with the App. We may keep this information indefinitely.

  • Information Collected Through Automated Gathering Tools. Like most mobile apps, we may use automated information gathering tools (like cookies) that are intended to make using the App 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 mobile apps, we may also implement certain third-party content on the App, or integrate other third-party offerings into the App, enabling the third parties providing such content or offerings to collect information about you through your use of the App. 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.


2. To whom do we disclose information about you collected through the App?

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 App (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 App (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 App 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 App, we may disclose certain information about you (including your Personal Data) to other users of the App 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 App 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 App (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 App, or to respond to a subpoena, court order or other legal process. We reserve the right to release information collected through the App 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 App; 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 App.


3. What security measures do we employ for information about you collected through the App?

To help protect the privacy of data collected through the App, 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 App with the objective of protecting such data against unauthorized access. However, no technology is completely secure. PLEASE BE AWARE THAT the App 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 App or private communications.  Accordingly, although we will take reasonable steps to protect the security and integrity of all information you provide through the App, 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 App (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 App 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 App are not currently capable of following whatever Do Not Track preferences you set. For more information about Do Not Track, visit

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 App by Pathways. You should be aware that when you are using the App, 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 App. We encourage you to read the posted privacy policy whenever interacting with any third-party website, app, or other offering.

6. What is our policy on children users of the App?

We do not knowingly collect or maintain personally identifiable information from persons under 13 years old, and no part of the App is directed to persons under 13. IF YOU ARE UNDER 13 YEARS OF AGE, PLEASE DO NOT USE THIS APP AT ANY TIME OR IN ANY MANNER. If you learn that your child under 13 has provided us with personal information without your consent, please contact us.


7.  What are your California Privacy Rights?

We will not disclose your personal information to third parties for their direct marketing purposes, unless you have first affirmatively agreed to that disclosure.


8. What law governs your use of the App?

By using the App, or otherwise providing information to Pathways, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the State of California, without reference to the choice of law or conflicts of law principles thereof, and will be subject to the dispute resolution clause contained in the end user license agreement for the App (available here). You also agree to abide by any limitation on damages contained in the end user license agreement applicable to the App or any other agreement that we have with you.


9. What are the terms regarding any future changes to this Privacy Policy?

Pathways reserves the right to update or modify this Privacy Policy from time to time, with any such changes to be effective prospectively. Please visit this page periodically so that you will be apprised of any such changes. Your continued use of the App after any modification to this Privacy Policy will constitute your acceptance of such modification.


10. How can you contact us?

If you have any questions about this Privacy Policy, or need to reach us for any other reason, you may contact us by email at


Last Updated: April 6th, 2022

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