Privacy Policy

Last updated: 15 May 2026

1. Who we are

PATHS ("PATHS Platform", "we", "our") is an AI-powered talent acquisition platform operated by PATHS Ltd. Our registered address and data protection contact are listed at the end of this document.

2. What data we collect

We collect: • Identity & contact data: name, email, phone, location provided at registration. • CV/résumé data: professional history, skills, education, and certifications extracted from uploaded documents. • Usage data: pages visited, features used, timestamps, IP addresses. • Communication data: emails and messages sent through the platform. • Billing data: plan selections and invoice records (card details are processed directly by Stripe, not stored by us).

3. How we use your data

We use your data to: • Provide, operate, and improve the PATHS platform. • Match candidates with job opportunities. • Send transactional notifications (interview invites, decision emails). • Comply with legal obligations. • Conduct analytics to improve AI model performance (always on aggregated or anonymised data).

4. Legal bases

Under UK GDPR / EU GDPR our lawful bases are: • Contract performance: processing necessary to deliver the service you signed up for. • Legitimate interests: fraud prevention, security, and platform improvement. • Consent: marketing communications and non-essential cookies (you can withdraw at any time). • Legal obligation: retaining records as required by applicable law.

5. Data retention

• CVs and candidate profiles: 24 months from last activity, or until you request deletion. • Interview transcripts: 18 months. • Hire/reject decisions: 7 years (legal hold requirement for employment records). • Account data: deleted 30 days after you request account closure.

6. Your rights

Under GDPR you have the right to: • Access — request a copy of your personal data (use the Export button in Settings). • Rectification — correct inaccurate data. • Erasure — ask us to delete your data (subject to legal hold obligations). • Restriction — ask us to limit processing. • Portability — receive your data in a machine-readable format. • Objection — object to processing based on legitimate interests. To exercise any of these rights, email privacy@paths.ai.

7. Cookies

We use: • Strictly necessary cookies: session management and security. These cannot be disabled. • Analytics cookies: usage measurement (opt-in via the cookie banner). • Marketing cookies: campaign attribution (opt-in, never enabled by default). You can change your cookie preferences at any time using the cookie settings link in the footer.

8. Third parties

We share data with: • Stripe (payment processing) • OpenRouter / Anthropic (AI inference — no training on your data per our DPA) • Qdrant Cloud (vector storage) • Vercel / Fly.io (hosting) All processors are under DPAs with equivalent GDPR protections.

9. Contact

Data controller: PATHS Ltd Email: privacy@paths.ai If you are unhappy with how we handle your data, you can complain to the ICO (UK) or the supervisory authority in your country.

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