Pathaka App Privacy Policy

Last updated 10 January 2025

Introduction to Pathaka and this policy

Pathaka is committed to our members' privacy. Pathaka is an AI podcast generator which allows our users to create AI generated audio files via a simple prompt.

This policy explains how we manage personal data within our organisation: please view, read and save a copy of it. It also governs your use of products, services, content, features, technologies or functions offered by us and all related sites, applications and services.

The policy is structured into sections so you can understand what data is collected, how we do this and why. At every point of your relationship with us, you remain in control, and your rights and privacy are respected.

Who we are, our role and responsibilities

Pathaka Limited UK company number 15419258 is committed to protecting and respecting your privacy. We adhere to the ICO (Information Commissioner's Office) best practice for compliance with the UK Data Protection Act and the European Union General Data Protection Regulation (GDPR) which came into force in May 2018.

By complying with the requirements under applicable laws and regulations ourselves, we are equally committed to ensuring all our employees, service providers and agents uphold these obligations.

You accept this policy when you sign up for, access, or use our services and by doing so you agree and have consented to us using the information you have given us and our trusted partners, as outlined in this Privacy Policy.

When data is shared with a partner, they become the data controller for the data they receive and their usage of the data from that point is then governed under their applicable terms and privacy policy. We do not accept any responsibility or liability for the content of third-party websites or third-party terms and conditions or policies.

Keeping your data up to date

We are the data controller (registered with UK ICO ZB697943) responsible for your personal data and it is important the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Data we collect from you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

The kinds of personal data that we collect and hold about you can include:

• identifying information, such as your name;
• identity verification information, such as images of your government issued ID, passport, utility bill or driving licence;
• contact information, such as your postal address, email address and telephone numbers;
• social media handles and other social media profile information that you make available to us or to the public;
• financial information, such as a credit or debit card, bank account or other payment details and/or other personal wealth information;
• information about transactions and balances from connected accounts as well as any transactional information manually entered by you;
• online identifiers that may also constitute personal data, such as your computer and mobile device unique device ID and IP information based on your internet connection settings;
• usernames and passwords that you create when registering for an account with us;
• details of any products or services that we provide to you;
• information about how you use the products and services we provide;
• records of our communications with you, including any messages you send us;
• education and employment information;
• lifestyle information such as family, interests and other observations from use of our services

We also collect, use and share aggregated data such as statistical or demographic data at various levels of anonymisation and for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific site feature.

If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which is used in accordance with this privacy notice.

Without this information, we may not be able to provide you with our products or services (or with all of the features and functionality offered by our products or services), to respond to queries or requests that you submit to us and to protect against the risks of cybercrime, fraud and money laundering & terrorist financing.

Except in limited circumstances which will be made clear to you, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we collect personal data

We collect personal data about you in a number of ways including:

• where you register for an account or to receive emails from us;
• when you order products or services from us;
• when you submit a query or request to us;
• when you respond to a survey that we run or fill in forms on one of our websites;
• when you directly port your data from 'gatekeeper' services such as Google, Meta and Tiktok, and LinkedIn;
• when you connect your banking account data;
• by tracking your use of our websites and mobile applications;
• from public sources;
• from third parties who you allow or are otherwise entitled to disclose that information to us;
• when you apply for a job with us.

In some cases, we may also be required by law to collect certain types of personal data about you.

Where we collect personal data from you, we will generally do so ourselves. However, in some cases we may collect personal data from a third party, such as through your representatives, contractors who provide services to us, or third parties who refer you to us because they think you may be interested in our products or services.

How we use your data

We will only use your personal data when we have a lawful reason to do so. Most commonly, we will use your personal data in the following circumstances:

• where you consent to it;
• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• where we need to comply with a legal or regulatory obligation.

Purposes for which we use personal data

We use personal data that we collect about you for the following purposes:

• to verify your identity (including age) when you are dealing with us;
• to determine your eligibility for any of our products or services;
• to determine your compliance with the terms and conditions that apply to any of our products or services and applicable law;
• to enable us to offer our products and services;
• to personalise search results and information in our discovery feed;
• to provide you with the services, products and information you have requested;
• to communicate with you about our products and services;
• to improve our website based on your information and feedback;
• to answer your queries and requests;
• to resolve complaints;
• to comply with our legal and regulatory obligations;
• to carry out market analysis and research;
• to monitor use of our products and services;
• to assess, maintain, upgrade and improve our products and services;
• to carry out education and training programs for our staff;
• to manage and resolve any legal issues;
• to carry out planning and forecasting activities and other internal business processes;
• to improve and train personalised AI and machine learning models that can only be deployed within the Pathaka application and directly for user benefit;
• to keep you informed about our activities, including by sending out newsletters;
• to carry out investigations for breaches of conduct by our employees;
• for business continuity, disaster recovery or any other of our legitimate business interests.

Purposes for which we do not use personal data

• Pathaka, including any 3rd party we partner with, will not use your personal data, including data you have ported from 'gatekeepers' such as Google, Meta etc… to develop, improve, or train generalised AI or machine learning models that can be utilised independently of Pathaka applications.
• We will never sell any personal data gathered either through our applications or ported from gatekeeper services.

Automated decision making

We may process your personal data without human intervention to evaluate your personal situation such as distributing rewards, transactional history, search history, and account opening anniversary events. We may do this to decide what marketing communications are suitable for you, to analyse statistics and to assess risks. This is done on the basis of our legitimate interests, to protect our business, and to develop and improve our products and services. If we use automated decision making including profiling activity to assess your application, this will be performed on the basis of it being necessary to perform the contract.

Rewards programme

We require consent for you to share certain non-personally identifiable information with third parties [Pathaka consent notice]. When we hold this data this is personal data but when you decide to share this data with your trusted brands as part of our rewards and advertising programme, it is only a limited subset of the personal data we collect and it is not personally identifiable information that transfers to the trusted brand.

Marketing

We want to send you marketing materials about our products or services we think you may be interested in but we shall always give you the opportunity to easily opt-out of any such communications.

You can opt-out of receiving marketing communications from us by contacting us at optout@pathaka.ai or, in respect of emails, by clicking unsubscribe on the relevant email.

We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes.

Who we share your data with

As necessary, we may disclose your information to:

• your representatives, advisers and others you have authorised to interact with us on your behalf;
• our staff who need the information to discharge their duties;
• related entities within our corporate group;
• our business partners, agents and service providers;
• payment system operators and financial institutions;
• identity verification agents;
• fraud and crime prevention agencies and organisations;
• prospective purchasers of all or part of our business or a related entity;
• professional advisers who we engage to provide advice on our business; and/or
• government authorities and bodies, supra-national authorities and bodies, crime investigation agencies, courts and others who ask us to disclose that information as required by law.

We may also disclose your personal information where it is necessary to do so: for compliance with a legal obligation; in order to protect the vital interests of you or another natural person; and for the establishment, exercise or defence of legal claims.

We require all third parties to respect the security of any personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Whenever we transfer your personal data out of the UK and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

You can learn more about how data is protected internationally here. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Children and young people

You must be aged 18 or over to use our services. Our website and apps are not aimed at children under the age of 18 and we do not knowingly collect any personal data from visitors in this age group.

If you are under the age of 18 and we learn that we have inadvertently obtained personal data from you from our app, website or any other source, then we will close that account and delete the information as soon as possible.

Please contact us at enquiries@pathaka.ai if you are aware that we may have inadvertently collected personal data from a child under the age of 18.

Your right to lodge a complaint to the Information Commissioner's Office (ICO)

We'd appreciate an opportunity to fix things, but you can complain to the ICO by clicking here or in writing to Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

How we use cookies

We use cookies to distinguish you from other users of the Website. This helps us to provide you with a good experience when you use our Services.

We use the following 4 main type of cookies:

• Strictly necessary cookies: required for the operation of our website and include e.g. cookies that enable you to log into secure areas of our website and enter into transactions.
• Analytical/performance cookies: allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works e.g. by ensuring that users are finding what they are looking for easily.
• Functionality cookies: used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences.
• Targeting cookies: these record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests.

We may combine information collected by analytics cookies with other information that you provide to us, to improve our products and services. We may also share this information with third parties for this purpose.

If you wish you can change your cookie settings in your browser if you would like to prevent any cookies being stored on your online enabled device, but be aware that this may impact the functionality of the Services.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Most browsers will allow you to turn off cookies. If you want to know how to do this please look at the menu on your browser, or look at the instructions on http://www.allaboutcookies.org/

Unfortunately, turning off cookies may mean our website doesn't retain your personalised settings and may restrict use of the site and services.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

Your personal data will only be kept as long as required to meet our legal obligations and no longer than is necessary. In most cases we will retain your personal data for a maximum period of 18 months after our relationship ends.

In some cases we may be obliged to retain some of your personal data for longer periods as are required by law. At our discretion, we shall retain personal data for any period we consider is reasonably necessary to meet our legal or regulatory obligations.

Your legal rights

You have rights under data protection laws in relation to your personal data, which are set out below:

• Right to be informed: we aim to give you all the relevant information about the collection and use of your personal data.
• Access right: this enables you to receive a copy of the personal data we hold about you.
• Rectification right: this enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Erasure right ('right to be forgotten'): you can ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
• Data processing restriction right: you can ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please note that any requests in relation to this right mean that we may be unable to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel your use of our services but will notify you if this is the case at the time.
• Data portability right: at your request, we can provide your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdrawal of consent: you can exercise this at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Please contact us at enquiries@pathaka.ai if you wish to exercise any of these rights.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Third-party sites

Some pages made available through the Services include links to third-party websites: clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control such websites and are not responsible for their privacy statements. We encourage you to read the privacy policy of every website you visit.

Changes to this policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this policy are welcomed and should be addressed to our support team and DPO at enquiries@pathaka.ai