Privacy Policy (GDPR)

1. Controller

The controller responsible for data processing on this website is:

• pathways digital SL
• C/ Gremi de Sabaters 21
• 07009 Palma, Spain, Spain
• Email: hola@pathways-digital.com
• Website: https://pathways-digital.com

2. Scope

This privacy policy explains how we collect, use, store, and protect personal data when you visit our website, use our contact form, use the site chatbot, subscribe to communications, or interact with our services.

We process personal data in accordance with the General Data Protection Regulation (GDPR), the Spanish Organic Law on Data Protection (LOPDGDD), and applicable EU law.

3. Data we collect

Depending on how you interact with us, we may process:

• Contact details (name, email address, company, phone number if provided)
• Message content submitted via our contact form or chatbot lead form
• Chatbot conversation content you send to receive portfolio answers
• Technical data (IP address, browser type, device information, pages visited)
• Cookie and consent preferences
• Analytics data when you opt in to non-essential cookies

4. Purposes and legal bases

We process personal data for the following purposes:

• Responding to inquiries and providing our services (Art. 6(1)(b) GDPR: contract/pre-contractual steps)
• Operating the site chatbot to answer questions about our portfolio (Art. 6(1)(f) GDPR: legitimate interest, and Art. 6(1)(a), where you submit personal data via the chat lead form)
• Operating and securing our website (Art. 6(1)(f) GDPR: legitimate interest)
• Marketing communication where you have given consent (Art. 6(1)(a) GDPR)
• Analytics to improve our website, only with your consent (Art. 6(1)(a) GDPR)
• Compliance with legal obligations (Art. 6(1)(c) GDPR)

5. Contact form

When you submit our contact form, your data is transmitted to process your request. Submission requires your explicit consent to this privacy policy. We use Web3Forms as a form delivery provider; data is processed to deliver your message to us.

We retain contact form submissions for as long as necessary to handle your inquiry and for up to 24 months thereafter, unless a longer retention period is required by law or ongoing business relationship.

5a. Site chatbot

Our website includes an optional portfolio chatbot that answers questions about our products, services, case studies, and related company information. Messages you send are processed to generate a reply.

To produce answers, message content is transmitted to our large language model provider OpenAI. OpenAI processes this data as a processor/sub-processor for this purpose. Do not submit sensitive personal data in chat messages.

If you use the chatbot lead form, your contact details and message (including an abbreviated chat transcript when provided) are delivered to us via Web3Forms under the same consent and retention rules as our contact form.

We do not use chatbot conversations to train our own foundation models. Retention of chat content by infrastructure providers follows their respective agreements; lead submissions are retained as described for contact form submissions.

6. Cookies

We use essential cookies required for site functionality and consent storage. Non-essential analytics and marketing cookies are only set after you provide consent via our cookie banner. You can change your preferences at any time using the cookie settings link in the footer.

With your consent, we use Plausible Analytics for privacy-friendly website analytics and Google Tag Manager (including tags configured in that container, such as Google Analytics or advertising tags), to measure traffic and campaign performance. These tools load only after you accept the relevant Analytics and/or Marketing categories.

7. Recipients and transfers

We may share data with trusted processors who assist us in hosting, analytics, email delivery, CRM, form processing, and chatbot responses, including Plausible Analytics, Google (Google Tag Manager / related Google services), when you have consented to analytics or marketing cookies, Web3Forms for form delivery, and OpenAI for chatbot message processing. Where data is transferred outside the EU/EEA, we ensure appropriate safeguards such as Standard Contractual Clauses.

8. Retention

We retain personal data only as long as necessary for the purposes described above, unless statutory retention obligations apply.

9. Your rights

Under the GDPR, you have the right to:

• Access your personal data
• Rectify inaccurate data
• Erase data (“right to be forgotten”), where applicable
• Restrict processing
• Data portability
• Object to processing based on legitimate interests
• Withdraw consent at any time without affecting prior lawful processing
• Lodge a complaint with a supervisory authority

10. Contact

For privacy-related requests, contact us at hola@pathways-digital.com. We respond within the timeframes required by applicable law.