California Consumer Privacy Act & California Privacy Rights Disclosure
- Part I: Legal Entities
- Part II: Applicability
- Part III: Introduction
- Part IV: Collection and Disclosure of Personal Information
- Part V: Use of Personal Information
- Part VI Sale of Personal Information
- Part VII Rights under the CCPA
- Part VIII How to Exercise Your Rights
- Part IX Changes to This California Consumer Privacy Act Disclosure
- Part X Our Commitment to Data Security
- Part XI Security of your Personal Information
- Part XII Information Tracked
- Part XIII Contact
Your privacy is important to us. This California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) Disclosure explain how the legal entities listed above (“Company,” “we,” or “us”) collect, use, and disclose personal information relating to California residents covered by the California Consumer Privacy Act of 2018 (CCPA). This notice is provided pursuant to the CCPA.
The CCPA and CPRA classify “Personal Information” as information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked (directly or indirectly) to a California resident. The CCPA and CPRA do not apply to certain information, such as information subject to the Gramm- Leach-Bliley Act (GLBA).
Keeping Personal Information secure is one of our most important priorities. Path maintains physical, technical, electronic, and procedural organizational safeguards and security measures designed to protect personal data. These safeguards and security measures are consistent with obligations under applicable laws and regulations. The measures prevent accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access, to personal data whether it is processed by us or elsewhere.
Collection and Disclosure of Personal Information
In the past 12 months, we have collected and/or disclosed to third parties for our business purposes the following categories of Personal Information relating to California residents covered by this Disclosure:
- Identifiers, such as name and government-issued identifier (e.g., Social Security number)
- Personal information, as defined in the California safeguards law, such as contact information and financial information
- Characteristics of protected classifications under California or federal law, such as sex and marital status
- Commercial information, such as transaction information, account information and purchase history
- Internet or network activity information, such as browsing history and interactions with our website
- Geolocation data, such as device location and Internet Protocol (IP) location
- Audio, electronic, visual, and similar information, such as call and video recordings
- Professional or employment-related information, such as work history and prior employer
- Education information, such as student records and directory information
The categories of sources from whom we collected this Personal Information are:
- Directly from a California resident or individual representatives
- Service Providers, Consumer Data Resellers, and other third parties
- Public Record Sources (Federal, State or Local Government Sources)
- Information from our Affiliates
- Website/Mobile App Activity/Social Media
- Information from Client Directed third parties or Institutions representing a Client/Prospect
The categories of third parties to whom we disclose Personal Information for our business purposes described in this privacy disclosure are:
- Affiliates and Subsidiaries of Path Software
- Vendors and Service Providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, auditing, marketing and marketing research activities
- Other third parties who enable customers to conduct transactions online and via mobile devices, support mortgage and fulfillment services and aggregators (at the direction of the customer)
- Government Agencies, as required by laws and regulations
Use of Personal Information
Path has used Personal Information relating to California residents to operate, manage, and maintain our business, in the past 12 months to provide our products and services, and to accomplish our business purposes and objectives, including the following:
- Performing services, including:
- Maintaining or servicing accounts
- Providing customer service
- Processing or fulfilling orders and transactions
- Verifying customer information
- Facilitating the evaluation of financial application processing payments
- Providing advertising or marketing services providing analytic services
- Providing similar services on behalf of the business
- Detecting security incidents including:
- Protecting against malicious, deceptive, fraudulent, or illegal activity
- Prosecuting those responsible for that activity
- Undertaking activities to verify or maintain the quality or safety of a service controlled by Path
- Undertaking activities to improve, upgrade or enhance the service controlled by the Path
- Debugging to identify and repair errors that impair existing intended functionality.
- Undertaking internal research for technological development and demonstration.
- Complying with laws and regulations
- Complying with other legal processes and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes, or opinions)
Sale of Personal Information
Path has not sold Personal Information subject to the CCPA, including Personal Information of minors under the age of 16 in the past 12 months. The exception is the sharing of personal information for services you have requested that are provided by third parties. For purposes of this Disclosure, sold means the disclosure of Personal Information to a third party for monetary or other valuable consideration.
Rights under the CCPA and CPRA
You have the right to the following if you are a California resident:
- Request we disclose to you free of charge the following information covering the 12 months preceding your request:
- the categories of Personal Information about you that we collected
- the categories of sources from which the Personal Information was collected
- the purpose for collecting Personal Information about you;
- the categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you
- the specific pieces of Personal Information we collected about you
- Request we delete Personal Information we collected from you unless the CCPA and CPRA recognize an exception
- Request we do not sell personal information by clicking the following link
- Be free from unlawful discrimination for exercising your rights under the CCPA and CPRA
- Request we correct your personal information
Path may require proof of authorization and verification of identity directly from the person for whom you are submitting a request if you submit a request on behalf of another person.
Path may not be able to honor your request in some instances. For example, Path will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Path will not honor your request where an exception applies (such as: where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights). We will advise you in our response if we are not able to honor your request. Path will not provide social security numbers, driver’s license numbers, or government-issued identification numbers. Path will not provide financial account numbers, health care or medical identification numbers, account passwords, security questions, and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.
Path will work to process all verified requests within 45 days pursuant to the CCPA and CPRA. Path will provide you with an explanation for the delay if we need an extension for up to an additional 45 days in order to process your request.
How to Exercise Your Rights
If you are a California resident, you may submit a request by:
- Completing the online Personal Information Request Form; or
- Calling Privacy Services toll-free at 844.684.1146.