Notification of Personal Data Processing by Family Pathway

We, Family Pathway (“Family Pathway” and “we“), care about your personal data and do everything possible to protect it.

We have created this Notification of Personal Data Processing (“Notification“) to help you understand what personal data of yours is collected, stored, and processed, as well as what happens to it when you use our website (“Site“).

You, as a data subject, can be our visitor, client, partner, or representative.

Purpose of the Notification

The Notification of Personal Data Processing (“Notification”) is a document that provides basic information about the controller of personal data (Family Pathway) and describes how we collect, use, store, and disclose personal data.

This Notification covers our Site.

Summary of the Notification:

We need to process some of your data so that you can use our Site and services. For any other purposes, we will always request your consent in advance.
We will not share your data for third-party advertising purposes.

Your rights regarding personal data are also explained in it.

You can browse our Site without providing us with your data. If you want to use all the features of our Site, you will need to provide some of your data.

If you do not agree to the Terms of Use or any part of them, please stop using our Site and the services on it.

Purpose of Data Collection

Regardless of who you are (Visitor, Client, Partner, or Representative), we have only three categories of data about you:

Automatically Collected Data (the same for everyone)

We collect data about your interaction with the Site, devices, and connections, as well as cookie files and similar technologies to ensure the functionality of our Site.

Data Provided by Visitors

We collect your contact information and additional case-related information, if applicable, when you contact us and our customer support.

Data Received from Other Sources

We collect contact information, information about trips to medical service providers, and information about medical courses when you interact with us through social networks or when we provide services to our partners.

We process sensitive categories of personal data: health and medical data. We understand the importance of the security of this data. It is necessary for you to understand that the processing of sensitive categories of personal data (medical and health-related) is required to provide you with services (legal basis: contract performance).

Automatically Collected Data

When you visit our Site, some data is collected automatically. We require technical data for the operation, maintenance, and improvement of our Site. Such data includes:

Category of Actions	Description of Category	Legal Basis
Your Interaction with the Site	We may collect data about your interaction with our Site. This data includes: – Your interaction with the Site, the features and pages you view, and how you use our Site; – Actions you take, if such actions are present.	Legitimate Interest
Connection	We gather information about your computer, phone, tablet, or other devices you use to access the Site. Specifically, we collect: – Type of connection and settings when accessing, updating, or using our services; – Data about your operating system, browser type, IP address, URL of entry/exit pages, device identifiers, and error data; – Geolocation (for example, we use your IP address and/or preferred country to approximately determine your location). The extent of this information we collect depends on the type and settings of the device you use to access the services.	Legitimate Interest
Cookie Files and Similar Technologies	We use cookie files for analytical purposes. You can disable cookie files in your browser settings at any time. Learn more about how we use cookie files in our Cookie Policy.	Legitimate Interest and/or Consent

Data You Provide to Us

Please note that the collection of all the data listed here is not mandatory. Their presence on the list only means that we may obtain them from you.

Data Provided by Visitors

When using our Site, you may inquire about our services or seek recommendations based on your situation.

When contacting us and our customer support service, we may collect your contact details such as name, email address, phone number, and country of residence, as well as additional information about your case, if applicable.

Data We Receive from Other Sources

We may receive personal data from other sources and combine it with the information we collect through the Site. These sources may include social networks and partner collaborations.

Use of Data

We process your data for seven main purposes:

Operation of the Site’s functionality;
Provision of our services;
Providing information about our services;
Research and analytical purposes;
Compliance with security obligations;
Compliance with our legal obligations;
Sending marketing messages.

We will seek your consent if we need to process your data for other purposes.

Storage of Personal Data

We store your data on our servers. To process it in a secure and GDPR-compatible manner, we use encryption, contractual commitments, storage control, access levels, and supplier security verification.

We ensure accepted standards—physical, electronic, and procedural security measures—to protect the personal data we process and store.

We use Standard Contractual Clauses approved by the European Commission to ensure proper protection when processing data jointly with our Partners.

We retain your personal data for as long as necessary to achieve the purposes described in this Notice of Personal Data Processing, unless otherwise required by law. However, we may retain some of your personal data for as long as reasonably necessary for our legitimate business interests (including fraud detection and prevention), as well as to comply with our legal obligations (including tax, legal reporting, and auditing).

Before disclosing your personal data to any third party, we conduct a supplier security verification to ensure appropriate security measures are in place.

Disclosure of Personal Data

We may disclose your personal data to:

authorized third parties;
for security, legal, and law enforcement purposes;
as part of our commercial activities;
with your consent;
to service providers.

As a controller, we have specific obligations to protect your data. Before any transfer, each supplier undergoes a security audit.

Data Transfers

Due to the international nature of Family Pathway’s activities, we may need to process your data outside the country in which you reside. In such cases, we will use appropriate security measures (such as data protection contractual clauses) to ensure that your personal data remains protected in accordance with this Notice.

Your Rights as a Data Subject

If you provide us with your personal data, you can exercise any of the following rights:

Right to access information;
Right to data portability;
Right to restrict processing;
Right to erasure;
Right to rectification;
Right to object;
Right not to be subject to a decision based solely on automated processing;
Right to lodge complaints.

Use of Cookies

A cookie is a piece of data stored on a user’s hard drive containing information about the user. Cookies usually do not allow us to identify you personally.

Data collected through cookies may include:

the site from which you came to us;
web pages you viewed on our Site;
advertisements you viewed and clicked on while browsing various sites;
browser settings (e.g., language preferences);
information collected through web beacons (also known as “tracking pixels”).

For more information, please read our Cookie Policy.

Updating the Notice

Applicable legislation and our data processing practices may change over time. If we decide to update our Notice or change the scope/purposes of data we process, we will publish the changes on the Site. If significant changes to data processing procedures are made, we will send you a prior notice or, if required by law, request your consent before implementing such changes. We appreciate your interest in our personal data protection and processing practices.