Every Pathway™ asks individuals to be aware of the following:

Information we collect

Personal Information data is data which could be used to identify you either directly or indirectly or to contact you. Our Privacy Policy covers all personal information that you voluntarily submit to us and that we obtain from our partners. This Privacy Policy does not apply to data that is anonymised, as this data cannot be used to identify you. Except as described in this Privacy Policy, Every Pathway will never sell, give, rent or loan any data that constitutes personal information to any third party.

Information you give to us.

You choose to give us certain information when using our service. This includes

• Identification Documents: This may be a passport, driver’s license or other recognised national ID cards.
• Personal Identification details: Full Name, date of birth, utility bills, proof of residency photographs, phone number, home address, e-mail, proof of payment, and proof of account holder.
• Payment details: Bank Account Information, payment card details, transaction history, trading data.
• Source of funds: To use certain features may request; Payslip, Receipt, Questionnaire answers, and Blockchain addresses.
• Correspondence Information: Communication between users and our support team via E-mails and Live-Chats. Responses to surveys/questionnaires, entry into prizes, public social network posts and likes.
• Employment Information: Job title, description of the role, payment details, office location.

Information is collected when you use our service.

• Location Information: Your Internet Protocol (IP) Address, OS browser name and version, Geolocation.
• Account Information: Information about the transactions you make on our services, such as timestamp, recipient, amount, order activity, withdrawals, deposits your name and email.

Record

How we use your Personal Information

The main reason we use your information is to deliver and improve our service, prevent fraud and abuse and comply with regulatory obligations.

Legal basis:

Identifiable identification will be saved if necessary. All necessary data is stored for a minimum of 7 years after termination of a Customer Account.  in line with Anti Money Laundering directive and Anti-Terrorist Financing Laws. 

To provide our Service:

To use our service you need to register an account and we need to identify you as the account holder, therefore we request personal information from you to do this. This is needed for you to use the service, without this we would be unable to provide the service to you.

To Enable Communications:

We may need to communicate with you certain essential information, such as when your order is completed, any service/security/network updates to provide you with transaction-related information, and to answer/ investigate any queries. To provide you with customer services. Without such communications, you may not be aware of some important developments relating to your account which may affect your use of our Service.

To prevent fraud or abuse:

We process your personal data to ensure that no fraudulent activities or abuses take place. This includes people using or making fraudulent payments, account thefts, and abuse of our systems. Perform data analysis to fight against future fraudulent attacks.

Marketing:

We may send you marketing communications to inform you about our events/updates or news that we feel you may be interested in. You can opt out of our marketing communications at any time. Display to you relevant ads based on our site usage.

To improve our services and develop new ones:

Administer focus groups and surveys. Conduct research and analysis of users’ behaviour to improve our services and content. Develop new features and services.

To process your information as described above, we rely on the following legal bases:

• Providing our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For example, when you create an account, log in and place an order we use your information to maintain your account and facilitate your transactions and provide you with support when necessary.
• Legitimate Interest: We may use your information where we have legitimate interests to do so. We process information for administrative, fraud detection, communications and other legal purposes.
• Consent: Occasionally, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.
• Legal Obligations: We are required to provide customer data to adhere to anti-money laundering and anti-terrorist financing laws.
• Contractual Obligations: When you create an account and place an order you are entering into a contractual obligation with us, we process your data based on our contract with you, including the completion of transactions with you.

International Data Transfers

We may transfer your personal information to countries other than the country in which you are resident, Every Pathway website servers are mainly located within the United States however third-party service providers also operate outside the United States.

This means that when we collect your personal data we may process it in any of these jurisdictions.

We take appropriate steps to safeguard the security of your personal information in all countries. Some of these safeguards we rely on include where appropriate, using the US Commission’s approved standard contractual clauses with our suppliers, entering into Data Protection Agreements with third parties and contracting with Privacy Shield certified companies in the United States.

How do we share information with third parties?

Service Providers

In order to provide our services to customers, Every Pathway may enter into a contract with third-party processors which support, or make available, certain (or part of a) services. Every Pathway will at all times protect the information it collects, processes or stores, therefore we only chose to do business with companies who are reputable, transparent and in possession of internationally recognised certificates. These third parties assist us with various tasks, including data hosting and maintenance, record keeping, content posting, analytics, customer care, marketing and security operations.

For corporate transactions

We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture restructuring, reorganisation, dissolution, bankruptcy or other change of ownership or control.

When required by law

We may disclose your information if reasonably necessary to comply with a legal process such as a court order, warrant, law enforcement investigation or another legal requirement.

With your consent or at your request

We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share this information.

Your data protections Rights

You have a number of rights under the Data Protection Legislation;

• The right to request a copy of the information we hold on you. When you request this information, this is known as a Subject Access Request (SAR).
• The right to have personal data we hold about you transferred securely to another service provider in an electronic form;
• The right to have inaccurate personal data corrected;
• The right to have any out-of-date personal data deleted once there’s no business need or legal requirement for us to hold it;
• The right to object or restrict some processing, in limited circumstances and only when we don’t have legitimate grounds for processing your personal data;
• The right to object to personal data being used to send you marketing material. As mentioned above, we will only send you marketing material where you have given your consent to do so. You can remove your consent at any time.
• You can ask us not to use your data for marketing. You can do this by not ticking the relevant boxes on our forms, or by contacting us at any time at support@everypathway.com
• The right to ask for a decision to be made manually, where a decision is made using automated means and this adversely impacts you.

Privacy Policy Changes

Because we’re always looking for new and innovative ways to help people with Real estate, this policy may change over time. We will notify you before any material changes take effect so that you have time to review these changes.