Pathways Privacy Policy

Effective Date: January 1, 2025

IWYNO FINWORKS LLC dba QWYK iSoft ("QWYK iSoft," "we," "us," or "our") operates Pathways ("Platform"), a technology platform that connects users with independent peer advisors for college admissions and career guidance. We are committed to protecting your privacy and handling your personal information responsibly. This Privacy Policy explains how we collect, use, share, and protect your data when you use the Platform. By accessing or using the Platform, you agree to this Privacy Policy.

1. Scope of This Policy

This Privacy Policy applies to all users of the Platform, including:

Users: Individuals seeking college admissions or career guidance. Advisors: Independent contractors offering non-professional advice based on personal experiences.

This policy does not apply to data collected by advisors outside the Platform or by third-party websites linked from the Platform.

2. Information We Collect

We collect the following types of information to operate the Platform: a. Information You Provide

Registration Data: Name, email address, age, and (for advisors) qualifications or tax forms (e.g., W-9). Payment Data: Billing information (e.g., credit card details) processed securely via our payment provider (e.g., Stripe). Session Data: Booking details, session feedback, and messages sent through the Platform. Parental Consent: For users under 13, we collect verifiable parental consent (e.g., signed form, guardian email verification).

b. Information Collected Automatically

Usage Data: IP address, device type, browser, pages visited, and interaction timestamps. Cookies and Tracking: We use cookies to improve functionality (e.g., session management). You can manage cookie preferences via your browser settings.

c. Information from Third Parties

Analytics: Aggregated data from analytics providers (e.g., Google Analytics) to understand Platform usage. Payment Providers: Confirmation of transactions from Stripe or similar services.

3. How We Use Your Information

We use your information to:

Facilitate connections between users and advisors (e.g., booking sessions, messaging). Process payments and issue advisor payouts. Provide customer support and resolve disputes. Improve the Platform (e.g., analyzing usage trends). Comply with legal obligations (e.g., tax reporting, COPPA compliance). Send transactional emails (e.g., booking confirmations) and, with your consent, promotional updates.

Lawful Basis (GDPR): For users in the EU/EEA, we process data based on:

Contract performance (e.g., providing services). Legitimate interests (e.g., improving the Platform). Consent (e.g., marketing emails). Legal obligations (e.g., tax compliance).

4. How We Share Your Information

We share your information only as necessary to operate the Platform:

With Advisors: Users’ names and session details are shared with advisors to facilitate sessions. With Service Providers: Payment processors (e.g., Stripe), hosting providers, and analytics tools receive limited data under strict confidentiality agreements. For Legal Reasons: We may disclose data if required by law, court order, or to protect our rights (e.g., fraud prevention). Business Transfers: In the event of a merger or acquisition, your data may be transferred with appropriate safeguards.

We do not sell or share your data for marketing purposes beyond our own communications, and advisors are independent contractors responsible for their own data handling.

5. Children’s Privacy (COPPA Compliance)

The Platform is open to users aged 13 and older. For users under 13:

We require verifiable parental consent (e.g., signed form, guardian email verification) before collecting personal information. Parents may review, delete, or revoke consent for their child’s data by contacting [email protected]. We do not knowingly collect data from children under 13 without consent.

Advisors must comply with COPPA when interacting with minors and maintain confidentiality of user data.

6. Your Data Protection Rights

Depending on your location, you have the following rights:

Access: Request a copy of your personal data. Correction: Update inaccurate or incomplete data. Deletion: Request deletion of your data, subject to legal obligations (e.g., tax records). Restriction: Limit how we process your data. Portability: Receive your data in a structured format. Objection: Object to processing based on legitimate interests. Withdraw Consent: Opt out of marketing or non-essential processing.

To exercise these rights, contact [email protected]. We will respond within 30 days (or 15 days for CCPA requests). EU/EEA users may also contact their local data protection authority.

7. Data Security

We use industry-standard security measures (e.g., encryption, secure servers) to protect your data. However, no system is completely secure, and we cannot guarantee absolute protection. You are responsible for maintaining the confidentiality of your account credentials. Advisors, as independent contractors, must secure user data shared during sessions. QWYK iSoft is not liable for advisors’ data handling practices.

8. Data Retention

We retain your data only as long as necessary to:

Provide services (e.g., active account data). Comply with legal obligations (e.g., tax records for 7 years). Resolve disputes or enforce agreements.

When no longer needed, we securely delete or anonymize your data. You may request deletion earlier, subject to legal requirements.

9. International Data Transfers

The Platform is hosted in the United States. If you access the Platform from outside the US (e.g., EU/EEA), your data may be transferred to the US. We use safeguards (e.g., Standard Contractual Clauses for GDPR) to ensure compliance with international data protection laws.

10. Cookies and Tracking

We use cookies for:

Essential Functions: Session management, login authentication. Analytics: Understanding usage trends (e.g., Google Analytics).

You can disable cookies via your browser, but this may affect Platform functionality. We do not use cookies for targeted advertising.

The Platform may link to third-party websites (e.g., payment processors). We are not responsible for their privacy practices. Review their policies before providing data.

12. Advisor Data Handling

Advisors are independent contractors and must handle user data responsibly, maintaining confidentiality and complying with applicable laws. QWYK iSoft is not liable for advisors’ data practices outside the Platform’s systems.

13. Changes to This Policy

We may update this Privacy Policy to reflect legal or operational changes. We will notify you via email or through the Platform. Continued use of the Platform after changes constitutes your acceptance.

14. Contact Us

For questions, data requests, or concerns about this Privacy Policy, contact:

Email: [email protected]

EU/EEA users may contact our Data Protection Officer at the above email or their local data protection authority.

15. Additional Information for California Residents (CCPA)

Under the California Consumer Privacy Act:

You have the right to know, access, delete, and opt out of data sales (we do not sell data). We will respond to verifiable requests within 45 days. Contact [email protected] to exercise these rights.

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