This Website collects some Personal Data from its Users. This document explains what we collect, why we collect it, how we process it, and the rights you have over your Personal Data.
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Owner and Data Controller
The P.A.T.H. Model™, LLC
336 Mount Hope Avenue, Ste 14
Bangor, Maine 04401
Owner contact email: jack@thepathmodel.com
The P.A.T.H. Model™ provides trainings, education, consultation, and limited internal coaching for non-clinical purposes. Content on this Website is educational and informational only. It is not medical or mental health advice, diagnosis, or treatment. If you are experiencing a crisis, call your local emergency number.
1) Types of Data Collected
We collect Personal Data either directly from you or automatically when you use this Website.
Personal Information you provide
- Contact details: name, email address, phone number.
- Message content: your questions or comments submitted via forms or email.
- Registration details: information you provide if you sign up for updates, downloads, or events.
- Payment-related info: if we offer paid trainings, we may collect limited billing details through a third-party processor. We do not store full payment card numbers.
Usage Data collected automatically
- Device and browser data, IP address, pages viewed, time on page, referral URLs.
- Interaction events such as clicks, scrolls, and session statistics.
- Cookies and similar technologies used for essential site functions and analytics.
Sensitive data
- We do not seek to collect Protected Health Information (PHI) via this Website. Please do not submit confidential health details through contact forms. If such information is inadvertently received, we will delete it when reasonably possible.
Children
- This Website is not directed to children under 13 (or under 16 in the EU/UK). We do not knowingly collect Personal Data from children.
2) Mode and Place of Processing the Data
Methods of processing
We adopt appropriate security measures designed to prevent unauthorized access, disclosure, modification, or destruction of Personal Data. Processing is performed using computers and IT-enabled tools, following organizational policies related to the stated purposes.
Place of processing and data transfers
Data is processed at our operating locations and at locations of our service providers. Depending on your location, your data may be transferred to and processed in a country different from yours. Where required, we use appropriate safeguards for international transfers.
3) Legal Basis for Processing
We process Personal Data when one or more of the following apply:
- You have given consent for one or more specific purposes.
- Processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.
- Processing is necessary for compliance with a legal obligation.
- Processing is necessary for our legitimate interests or those of a third party, and these interests are not overridden by your rights and freedoms.
4) Retention Time
We retain Personal Data for as long as needed for the purposes outlined in this Policy. Factors include:
- The duration you maintain an account or ongoing communications.
- Legal, tax, and accounting obligations.
- Security, fraud prevention, and service improvement needs.
When no longer necessary, data is securely deleted or anonymized.
5) Purposes of Processing
We use Personal Data to:
- Provide and improve our Services: operate the Website, deliver requested content, process registrations, and support users.
- Respond to inquiries: answer questions sent via forms or email.
- Analytics: monitor and analyze web traffic and user interactions to improve content and performance.
- Communications: send updates you subscribe to, such as newsletters or event information. You can unsubscribe at any time.
- Security and fraud prevention: detect, investigate, and prevent malicious or unlawful activity.
- Compliance: meet legal obligations and enforce our terms.
Typical tools and integrations
- Forms and email for inquiries and sign-ups.
- Analytics to understand traffic and improve the user experience.
- Payment processor (if applicable) to handle training or event payments. We do not store full payment card data on our servers.
6) Users’ Rights
Depending on your location, you may have rights that include:
- Withdraw consent: where consent is the basis, you can withdraw it at any time.
- Object to processing: you may object to processing based on legitimate interests or direct marketing.
- Access: request confirmation whether we process your data and receive a copy.
- Rectification: request correction of inaccurate or incomplete data.
- Restriction: request we limit processing of your data under certain conditions.
- Erasure: request deletion of your data when legally permissible.
- Portability: receive your data in a structured, commonly used, machine-readable format and have it transferred to another controller where technically feasible.
We will not discriminate against you for exercising your rights. Some rights may be limited by applicable law.
How to exercise your rights
Submit a request to jack@thepathmodel.com and include sufficient information to verify your identity and understand your request. We will respond within the time required by law.
7) Additional Information About Data Collection and Processing
Legal action
Your Personal Data may be used for legal purposes in court or in stages leading to possible legal action arising from improper use of this Website or the related Services.
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interactions (system logs) or use other Personal Data.
Do Not Track
Some browsers offer “Do Not Track.” Our Website’s response to DNT signals may vary based on the third-party services we use. You can manage cookies at the browser level.
Third-party links
This Website may link to third-party sites. We are not responsible for their content or privacy practices. Review their policies before providing Personal Data.
8) Cookies and Tracking Technologies
We use cookies and similar technologies to:
- Enable core site functions.
- Remember preferences.
- Perform analytics and improve performance.
- Provide content or features from third parties.
You can manage cookies in your browser settings. Disabling cookies may affect certain features.
9) Sharing of Personal Data
We share Personal Data only as needed and with appropriate safeguards:
- Service providers: hosting, analytics, email delivery, customer support, payment processing.
- Professional advisors and legal authorities: when required by law or to protect rights, safety, and security.
- Business transfers: if we engage in a merger, acquisition, or asset sale, Personal Data may be transferred as part of that transaction.
We do not sell Personal Data.
10) Security
We use administrative, technical, and physical safeguards designed to protect Personal Data. No method of transmission or storage is completely secure. We encourage you to use strong passwords and protect your devices.
11) International Users
If you access the Website from outside the country where our servers are located, you understand your information may be transferred to and processed in other jurisdictions. Where required, we use appropriate safeguards for international transfers.
12) Region-Specific Notices
EEA/UK
If you are in the EEA or UK, our legal bases for processing are listed in Section 3. You may lodge a complaint with your local supervisory authority. If required, we will identify a representative or DPO in a supplemental notice.
California (CCPA/CPRA)
We do not sell or share Personal Information as defined by CPRA. California residents can request access, deletion, and correction as described in Section 6. We honor rights to limit use of sensitive Personal Information where applicable.
13) Changes to This Privacy Policy
We may update this Policy from time to time. We will post the updated version on this page and update the “Latest update” date below. Material changes may also be communicated by reasonable means such as email or on-site notices. Please review this page periodically.
Latest update: October 13, 2025
