Privacy Policy

1. INTRODUCTION

This Privacy Policy ("Policy") governs how Paced Studios LLC (doing business as PathPicker and the Awarded App) (collectively, "Company," "we," "our," or "us") collects, uses, maintains, and discloses information from users ("User," "you," or "your") of the PathPicker website, the Awarded mobile application, and all associated digital properties and services (collectively, the "Services").

By accessing or using the Services, you expressly consent to the data practices described in this Policy. If you do not agree with these practices, please do not use the Services.

We may update this Policy at any time. Material changes will be notified via email or prominent notice on the Services. Your continued use after changes constitutes acceptance.

2. WHAT INFORMATION WE COLLECT

2.1 Information You Provide

Account & Contact Information:

• Full name, email address, phone number
• Account username and password
• Profile picture (if provided)

Profile & Demographic Data:

• Age and date of birth
• Academic standing and intended major
• Grade point average (GPA) range
• Career interests and goals
• First-generation or second-generation student status
• Location/state of residence

Financial Intent Data:

• Self-reported income bracket
• Student loan interest
• Credit card information for payment processing (see Section 2.4)
• Financial product interests
• Credit readiness indicators

Communication Preferences:

• Email opt-in/opt-out status
• SMS opt-in/opt-out status
• Marketing communication preferences

2.2 Information Automatically Collected

When you use the Services, we automatically collect:

Device & Network Data:

• Internet Protocol (IP) address
• Browser type and version
• Operating system
• Unique device identifier (UDID) or device ID
• Device model and manufacturer
• Mobile network information

Usage & Behavioral Data:

• Pages visited and time spent
• Features used
• Clicks and interactions
• Referral source and exit pages
• Search queries
• Quiz/assessment responses and results

Location Data:

• IP-based geographic location (city/state level)
• Device-based location (if permissions granted)

Cookies & Tracking:

• Session IDs and authentication tokens
• Preferences and settings
• Affiliate tracking identifiers
• Third-party advertising cookies (see Section 5)

2.3 Information from Third Parties

We may receive information from:

• Third-party authentication providers (Google, Apple Sign-In, etc.)
• Affiliate partners (when you engage with their offers)
• Data brokers or lead aggregators (for verification purposes)
• Your browser/device (referral data, crash reports, etc.)

2.4 Information We Do NOT Collect

We do not collect or store:

• Full credit card numbers (processed by PCI-compliant payment providers)
• Bank account numbers or routing numbers
• Social Security Numbers
• Full credit reports or credit scores
• Biometric data (fingerprints, facial recognition, etc.)
• Health information

3. HOW WE USE YOUR INFORMATION

We process your information for the following purposes:

3.1 Providing the Services

• Operating the PathPicker matching engine
• Delivering personalized educational and financial matches
• Processing subscriptions and payments
• Maintaining and troubleshooting your account
• Responding to your inquiries and support requests

3.2 Proprietary Matching Algorithm

• Assessing your profile against available offers
• Routing you to relevant third-party opportunities
• Optimizing match accuracy over time
• A/B testing algorithm improvements

3.3 Communications

• Sending transactional emails (account confirmations, receipts, password resets)
• Sending newsletters and educational content
• Sending promotional offers and updates (if you opted in)
• Sending SMS messages (if you opted in)
• Customer support and account notifications

3.4 Analytics and Improvement

• Analyzing platform usage trends
• Measuring feature effectiveness
• Identifying bugs and technical issues
• Improving user experience and interface design
• Conducting research and user surveys

3.5 Affiliate Referrals and Partner Engagement

• Tracking which offers you view and click
• Attributing conversions to our affiliate partners
• Sharing your profile data with partners when you express interest
• Enabling partners to contact you per your consent

3.6 Compliance and Security

• Detecting and preventing fraud
• Preventing unauthorized access
• Complying with legal obligations
• Enforcing our Terms of Service
• Investigating violations or security incidents

3.7 Marketing and Advertising

• Creating audience segments for targeted ads
• Testing marketing campaigns
• Measuring ad performance and ROI
• Personalizing your experience

4. HOW WE SHARE YOUR INFORMATION

4.1 We Do NOT Sell Personal Information

We do not sell your personal information to data brokers or third parties for money. However, under California privacy law, some of our data sharing may constitute a "sale" or "sharing" for targeted advertising purposes (see Section 6).

4.2 Affiliate and Marketing Partners

How it works:

• When you view or click on a partner offer, we share your referral with that partner
• Partners receive UTM parameters, tracking IDs, and sometimes your profile data
• Partners may contact you if you explicitly opted in
• We may receive compensation (Cost Per Action, Cost Per Click, or revenue share) from these partners

Partners receive:

• Email address and name (if you click their offer)
• Profile data (academic major, grade level, location, financial interests)
• Quiz results and match compatibility scores
• Behavioral data (pages visited, time on site)

Your control:

• Do not click offers you're not interested in
• Opt-out of SMS to prevent partner contact
• Request deletion (see Section 6 for Your Rights)

4.3 Service Providers

We share data with vendors who help us operate the Services:

• Cloud Hosting: AWS, Google Cloud, or similar (for infrastructure)
• Email/SMS Providers: SendGrid, Twilio, or similar (for communications)
• Analytics: Google Analytics, Mixpanel, or similar (for usage tracking)
• Payment Processing: Stripe, PayPal, or similar (for billing)
• Customer Support: Zendesk, Intercom, or similar (for support tickets)
• Security & Fraud: Cloudflare, Max Mind, or similar (for protection)

These vendors are contractually bound to:

• Use data only for their contracted services
• Maintain security standards
• Not share with other customers
• Delete data upon request

4.4 Aggregated & De-Identified Data

We may share anonymized, aggregated data with:

• Prospective investors and partners
• Academic researchers
• Marketing and advertising platforms
• Industry analysts

This data does not identify you and cannot be used to re-identify you.

4.5 Legal Requirements & Corporate Changes

We may disclose information if required by:

• Court orders or subpoenas
• Law enforcement requests
• Legal obligations (tax, regulatory, etc.)
• Protecting our rights or user safety

Corporate Changes: If PathPicker is merged, acquired, or assets are sold, your data may be transferred as a business asset. We will notify you of any such change.

5. TRACKING TECHNOLOGIES & ADVERTISING

5.1 Cookies & Local Storage

We use the following technologies:

Essential Cookies (Required):

• Session management (keeping you logged in)
• Security and fraud prevention
• Account preferences

Analytics Cookies (Optional):

• Tracking usage patterns
• Understanding user behavior
• Improving platform performance

Marketing Cookies (Optional):

• Affiliate conversion tracking
• Advertising partner tracking
• Cross-site behavior mapping

You can:

• Manage cookie preferences using our cookie banner or "Cookie Settings" in the site footer
• Read our full Cookie Policy for a list of tools, data collected, recipients, retention, and opt-out options
• Manage cookie preferences in your browser settings
• Disable cookies (though this may break some features)
• Use "Do Not Track" settings (we honor applicable opt-out signals where required by law)

California residents: Analytics and marketing cookies, pixels, and similar tracking technologies will not fire until you explicitly opt in via our cookie banner. Essential cookies remain active to provide the Services.

5.2 Third-Party Advertising Networks & Pixels

With your opt-in consent, we use third-party advertising pixels and cookies that may:

• Track your browsing across websites
• Create audience profiles
• Deliver targeted ads based on your interests
• Measure ad conversions and campaign performance

Tools currently in use (after marketing opt-in):

• Meta (Facebook) Pixel
• Snapchat Pixel
• TikTok Pixel

We may also use or test:

• Google Ads
• LinkedIn Insight Tag
• Other display advertising networks

See our Cookie Policy for details on data collected, recipients, and retention. These networks may collect data even when you're not on PathPicker. You can:

• Opt out via the Digital Advertising Alliance
• Adjust privacy settings in Google, Facebook, and other accounts
• Use browser extensions like uBlock Origin or Privacy Badger

5.3 Analytics

With your opt-in consent, we use Google Analytics and similar tools to track:

• Pages visited and time spent
• Geographic location
• Device type and browser
• Traffic sources
• User flows and drop-off points

You can opt out of Google Analytics here.

5.4 Video Viewing & VPPA

Some pages embed third-party video players (for example, Vimeo) to showcase product demos. When you play an embedded video:

• The video provider may receive your IP address, device/browser data, and playback information
• PathPicker does not combine video viewing history with your name, email, or account ID for disclosure to third parties
• We do not sell or share personally identifiable video viewing records as defined under the Video Privacy Protection Act (VPPA)

For more information, review the video provider's privacy policy and our Cookie Policy.

6. YOUR PRIVACY RIGHTS & HOW TO EXERCISE THEM

Depending on where you live, you may have rights regarding your personal data:

6.1 California Residents (CCPA/CPRA)

Right to Know:

• Request what personal information we've collected
• Learn how we use and share it

Right to Delete:

• Request deletion of your information
• Exceptions: if we need it for legal compliance or service delivery

Right to Opt-Out:

• Opt out of the "sale" or "sharing" of personal information for targeted advertising

Right to Correct:

• Request corrections to inaccurate data

Right to Limit:

• Limit use of sensitive personal information (financial data, etc.)

Non-Discrimination:

• We will not discriminate against you for exercising these rights
• We will not deny services, charge higher prices, or reduce quality

Cookie & Pixel Opt-In (California): For California residents, analytics and marketing cookies, pixels, and similar tracking technologies will not fire until you explicitly opt in via our cookie banner. You can change your preferences at any time using "Cookie Settings" in the site footer.

6.2 European Residents (GDPR & UK DPA)

Right to Access:

• Request a copy of your personal data

Right to Erasure ("Right to be Forgotten"):

• Request deletion of your data
• Exceptions: legal obligations, contract performance

Right to Rectification:

• Correct inaccurate or incomplete data

Right to Restrict Processing:

• Limit how we use your data while we verify accuracy

Right to Data Portability:

• Receive your data in a portable, machine-readable format
• Transfer it to another service provider

Right to Object:

• Object to marketing communications
• Object to profiling and automated decision-making

Right to Lodge a Complaint:

• Contact your local data protection authority (e.g., ICO in the UK, CNIL in France)

6.3 Colorado, Connecticut, Utah, Virginia (US State Privacy Laws)

You may have similar rights to California residents. These laws typically include:

• Right to know what information we collect
• Right to delete information
• Right to opt out of targeted advertising
• Right to non-discrimination for exercising these rights

6.4 How to Exercise Your Rights

To submit a privacy request:

• Email: support@pathpicker.com
• Include: "Privacy Request" in the subject line
• Specify which right you're exercising
• Provide details about the information you're requesting

Include:

• Your full name
• Email address used with your account
• Description of your request
• Proof of residency (for CCPA/CPRA: copy of ID, utility bill, or residency attestation)

Response time:

• We will respond within 45 days (California) or 30 days (GDPR)
• We may request additional information to verify your identity
• We will not charge a fee

California Opt-Out of Sale/Sharing: Click "Do Not Sell or Share My Personal Information" on our website, or email support@pathpicker.com with "Opt-Out Request" in the subject line.

7. DATA RETENTION

7.1 How Long We Keep Your Data

Active Accounts:

• We retain data while you maintain an active subscription
• Data includes profile information, usage history, and communication records

Deleted Accounts:

Within 30 days of account deletion, we delete:

• Your personal information (name, email, profile data)
• Your usage history and analytics data
• Your communication records

We may retain anonymized/de-identified data for analytics

Payment Information:

• Credit card data is processed by third-party payment providers (Stripe, PayPal)
• We do not store full card numbers
• Payment records are retained for 7 years (legal/tax requirement)

Legal & Compliance:

• We may retain data longer if required by law
• Examples: tax records (7 years), fraud investigations, legal disputes

Cookies & Tracking:

• Session cookies: deleted when you log out
• Persistent cookies: stored for up to 2 years (you can delete anytime)
• Analytics data: retained for 38 months by Google Analytics

7.2 Inactive Accounts

• Accounts inactive for 365+ days may be deactivated
• We will attempt to notify you before deletion
• You can reactivate by logging in again (within 30 days)

8. DATA SECURITY

8.1 Our Security Measures

We implement industry-standard safeguards:

Technical Safeguards:

• Encryption of data in transit (HTTPS/TLS)
• Encryption of sensitive data at rest
• Secure authentication (passwords, two-factor authentication)
• Regular security audits and penetration testing
• Web Application Firewall (WAF)
• DDoS protection

Administrative Safeguards:

• Access controls and role-based permissions
• Employee confidentiality agreements
• Background checks for staff
• Data breach response procedures

Physical Safeguards:

• Secure data centers with restricted access
• Video surveillance and monitoring

8.2 Your Responsibility

While we take security seriously, no system is 100% secure. You are responsible for:

• Keeping your password confidential
• Not sharing your login credentials
• Using strong, unique passwords
• Logging out on shared devices
• Notifying us of suspicious activity immediately

8.3 Data Breach Notification

If we experience a security breach affecting your personal information, we will:

• Notify you without unreasonable delay (typically within 30 days)
• Provide details of the breach and affected data
• Offer credit monitoring or identity theft protection if applicable
• Not blame you for the breach

9. INTERNATIONAL DATA TRANSFERS

9.1 Cross-Border Data Flows

If you are located outside the United States:

• Your data may be transferred to, processed, and stored in the United States
• US data protection laws may differ from your country's laws
• By using the Services, you consent to these transfers

9.2 GDPR Data Transfers

For European residents, we transfer data based on:

• Standard Contractual Clauses (SCCs) or Binding Corporate Rules (BCRs)
• Adequacy decisions (where applicable)
• Your explicit consent

10. CHILDREN'S PRIVACY (COPPA)

Age Requirement: The Services are for users 18 years and older only.

COPPA Compliance: We do not knowingly collect personal information from children under 13. If we discover we've collected data from a child under 13, we will:

• Immediately delete the information
• Notify parents/guardians if required by law

If you are a parent concerned about your child's data, contact support@pathpicker.com.

11. THIRD-PARTY LINKS & SERVICES

The Services contain links to third-party websites, apps, and services that are not operated by PathPicker. We are not responsible for:

• Their privacy practices or policies
• Their data collection or use
• Their content or services

We strongly recommend: Review their privacy policies before providing information.

12. YOUR CHOICES & CONTROLS

12.1 Email & SMS Communications

• Marketing emails: Opt out by clicking "Unsubscribe" in any email or contacting support@pathpicker.com
• SMS messages: Reply "STOP" to any text, or email support@pathpicker.com
• SMS consent records: When you opt in to SMS, we record the date, time, and method of your consent (for example, web form submission, checkbox, or text-to-join) and retain that record for at least 48 months for compliance purposes.
• Account emails: You cannot opt out of transactional emails (login alerts, receipts, etc.)

12.2 Personalization & Advertising

• Cookie preferences: Use our cookie banner or "Cookie Settings" in the site footer
• Disable personalized ads: Adjust privacy settings in Google, Meta, Snapchat, and your device
• Block third-party cookies: Use browser settings or privacy extensions
• California residents: Analytics and marketing cookies require explicit opt-in; you may also email an opt-out request (see Section 6.4)

12.3 Account Data

• Access your data: Email support@pathpicker.com with "Data Access Request"
• Download your data: Available in your account settings
• Delete your account: Use account settings or contact support
• Correct errors: Update your profile or request corrections

13. CONTACT US

For privacy questions, requests, or concerns:

Email: support@pathpicker.com

Response time: We'll respond within 5 business days

Data Protection Authority (EU/UK): If you believe we've violated your privacy rights, you may lodge a complaint with your local data protection authority.

14. POLICY UPDATES

We may update this Privacy Policy to reflect:

• Changes in our practices
• New features or services
• Legal or regulatory changes
• User feedback

Material changes will be notified via email or prominent notice on the Services. Your continued use constitutes acceptance of updates.