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Privacy Policy Last Updated: August 14, 2026 Scope of this Privacy Policy. This Privacy Policy describes how Path Education Inc. (“Pathify,” “we,” “us,” or “our”) collects, uses, and discloses information through the public Pathify website located at https://pathify.com (the “Website”). This Privacy Policy applies only to information collected through the Website. If you are a student, faculty member, staff member, or other user accessing the Campus Experience Platform (the “CXP”) or the AI Agent through your educational institution’s deployment, this Privacy Policy does not govern that access. Your institution is the data controller for Personal Data processed through the CXP and the AI Agent, and your institution publishes its own privacy policy describing how that Personal Data is collected, used, and shared. Institutional administrators or contract reviewers seeking additional detail about Pathify’s obligations as a processor may also review Pathify’s Data Processing Addendum at https://pathify.com/data-processing-addendum. 1. Interpretation and Definitions 1.1. Interpretation The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural form. 1.2. Definitions. For the purposes of this Privacy Policy: For the purposes of this Privacy Policy: “Account” means a unique account created for you to access features of the Website that require authentication (for example, Pathify’s customer portal or resource library). “Affiliate” means an entity that controls, is controlled by, or is under common control with Pathify, where “control” means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for election of directors or other managing authority. “Business,” for the purpose of the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (together, the “CCPA/CPRA”), refers to Pathify as the legal entity that collects Consumers’ Personal Data and determines the purposes and means of the processing of Consumers’ Personal Data. “CCPA/CPRA” has the meaning given above. “Consumer,” for the purpose of the CCPA/CPRA, means a natural person who is a California resident. “Cookies” are small files that are placed on your computer, mobile device, or other device by a website, containing the details of your browsing history on that website among its many uses. “Data Controller” for the purposes of the European Union General Data Protection Regulation (the “GDPR”) refers to the legal person that, alone or jointly with others, determines the purposes and means of the processing of Personal Data. “Data Processor” means a natural or legal person, public authority, agency, or other body that processes Personal Data on behalf of a Data Controller. “Device” means any device that can access the Website, such as a computer, a cellphone, or a digital tablet. “Do Not Track” or “DNT” is a concept promoted by US regulatory authorities, in particular the US Federal Trade Commission, for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites. “GDPR” has the meaning given above. “Global Privacy Control” or “GPC” is a browser-based signal that expresses a user’s opt-out preference under certain US state privacy laws. “Pathify” refers to Path Education Inc., 5910 S University Blvd, C-18 #224, Greenwood Village, CO 80121, United States. “Personal Data” means any information that relates to an identified or identifiable individual. For the purposes of the GDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity. For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you. “Service Provider” means any natural or legal person who processes Personal Data on behalf of Pathify. Service Providers refer to third-party companies or individuals engaged by Pathify to facilitate operation of the Website, to perform services related to the Website, or to assist Pathify in analyzing how the Website is used. For the purpose of the GDPR, Service Providers are considered Data Processors. “Third-party Social Media Service” refers to any website or social network website through which a user can log in or create an account to access features of the Website. “Usage Data” refers to data collected automatically, either generated by use of the Website or from the Website infrastructure itself (for example, the duration of a page visit). “Website” has the meaning given in the opening paragraph of this Privacy Policy. “you” means the individual accessing or using the Website, or the company or other legal entity on behalf of which such individual is accessing or using the Website. Under the GDPR, you may be referred to as the Data Subject. Under the CCPA/CPRA, you may be referred to as the Consumer. 2. Information We Collect Through the Website 2.1. Personal Data you provide. When you voluntarily provide information through the Website, Pathify may collect Personal Data including: Name Email address Phone number Employer, job title, and institutional affiliation Address, state, province, ZIP/postal code, city Information you include in sales inquiries, support requests, demo requests, newsletter subscriptions, job applications, or other voluntary submissions through the Website 2.2. Usage Data. Usage Data is collected automatically when you use the Website. Usage Data may include your Device’s Internet Protocol address (IP address), browser type, browser version, the pages of the Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data. When you access the Website through a mobile device, Pathify may collect certain information automatically, including the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers, and other diagnostic data. 2.3. Information from Third-party Social Media Services. If you decide to register for a Website Account or otherwise interact with the Website through a Third-party Social Media Service (including Google, Facebook, Instagram, Twitter, or LinkedIn), Pathify may collect Personal Data already associated with your Third-party Social Media Service account, such as your name, email address, profile image, and other profile information you choose to share or authorize through that account. You may also choose to share additional information with Pathify through your Third-party Social Media Service account. If you choose to provide such information, you permit Pathify to use, share, and store it in a manner consistent with this Privacy Policy. 2.4 Cookies and tracking technologies. Pathify uses Cookies and similar tracking technologies on the Website, which may include Cookies (both session and persistent), web beacons, pixel tags, and similar technologies. Where required by applicable law, Pathify seeks your consent before using non-essential Cookies and similar tracking technologies. The Website Cookie Policy at https://pathify.com/cookie-policy/ lists every Cookie the Website sets, grouped in the same categories used by the cookie consent tool on the Website, and explains how to give or withdraw consent. 2.4.1 Essential Cookies. These Cookies are necessary for you to browse the Website and use its features, for example to maintain security, authenticate users and prevent fraudulent activity. They are enabled by default, and without them the Website may not work properly. 2.4.2. Functional Cookies. These Cookies allow the Website to remember choices you have made and how you use it, for example your language preference or content you have viewed. They are disabled by default and are set only if you consent. 2.4.2. Functional Cookies. These Cookies allow the Website to remember choices you have made and how you use it, for example your language preference or content you have viewed. They are disabled by default and are set only if you consent. 2.4.3. Marketing Cookies. These Cookies track your activity in order to measure Website traffic and how the Website is used, and to help deliver more relevant advertising or limit how often you see an advertisement. They are disabled by default and are set only if you consent. Information gathered through these Cookies may directly or indirectly identify you. 2.4.4. Service Provider Cookies. Some Cookies in the categories above are set by Pathify’s Service Providers when you visit the Website. Those Service Providers are contractually limited to using such Cookies only to provide services to Pathify. 2.4.5. Managing Cookies. You can give, change or withdraw consent for Functional and Marketing Cookies at any time through the cookie consent tool on the Website. You can also refuse or delete Cookies through your browser. Methods vary from browser to browser and from version to version, and up-to-date information is available through your browser’s documentation and through the following resources: Chrome: https://support.google.com/chrome/answer/95647 Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences Safari: https://support.apple.com/guide/safari/sfri11471/mac Edge: https://support.microsoft.com/en-us/microsoft-edge Blocking all Cookies will negatively affect the usability of the Website. 3. How We Use Personal Data Collected Through the Website Pathify uses Personal Data collected through the Website for the following purposes: To operate and maintain the Website, including to monitor Website usage. To manage your Website Account, if you have one, including your registration as a Website user. To respond to your inquiries, including sales inquiries, support requests, demo requests, and other voluntary submissions. To communicate with you, including by email, telephone, SMS, or other equivalent forms of electronic communication regarding updates, marketing, or informative communications related to Pathify’s products and services. To provide marketing communications, including news, special offers, and information about Pathify’s products and services, subject to your opt-out rights. To analyze Website performance, including data analysis, identifying usage trends, and evaluating and improving the Website. For business transfers, including to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Pathify’s assets. For legal compliance, including to comply with Applicable Laws, respond to valid requests by public authorities, and protect Pathify’s rights and property. 4. How We Share Personal Data Collected Through the Website Pathify may share Personal Data collected through the Website in the following circumstances: With Service Providers: Pathify engages Service Providers to operate, maintain, and analyze the Website, including hosting providers, analytics providers, marketing-automation providers, and customer-relationship-management providers. These Service Providers are contractually limited to using Personal Data only to provide services to Pathify. With Affiliates: Pathify may share information with its Affiliates, in which case Pathify will require those Affiliates to honor this Privacy Policy. With business partners: Pathify may share information with business partners to offer certain products, services, or promotions. In business transactions: Pathify may share Personal Data in connection with a merger, acquisition, financing, reorganization, or sale of assets. If Pathify’s Personal Data is transferred in such a transaction, Pathify will provide notice before the Personal Data becomes subject to a different privacy policy. For legal reasons: Pathify may disclose Personal Data when Pathify believes in good faith that disclosure is necessary to comply with a legal obligation, protect and defend Pathify’s rights or property, prevent or investigate wrongdoing in connection with the Website, protect the personal safety of users of the Website or the public, or protect against legal liability. With your consent: Pathify may disclose Personal Data for other purposes with your consent. 5. Retention of Personal Data Collected Through the Website Pathify retains Personal Data collected through the Website only for as long as necessary for the purposes set out in this Privacy Policy and to comply with Pathify’s legal obligations, resolve disputes, and enforce Pathify’s legal agreements and policies. Usage Data is generally retained for a shorter period, except where this data is used to strengthen security or improve functionality of the Website or where Pathify is legally obligated to retain the data for longer periods. 6. International Transfer of Personal Data Personal Data collected through the Website is processed at Pathify’s operating offices in the United States and at other locations where Pathify’s Service Providers are located. Personal Data may therefore be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction. Where the GDPR or other applicable law requires appropriate safeguards for international transfers, Pathify relies on the Standard Contractual Clauses or other lawful transfer mechanisms. For information about how Pathify handles international transfers in connection with Pathify’s services provided to institutional customers, please see Pathify’s Data Processing Addendum at https://pathify.com/data-processing-addendum. 7. Your Rights Regarding Personal Data Collected Through the Website You have the right to delete, correct, or request access to the Personal Data that Pathify has collected about you through the Website. You may update, amend, or delete Personal Data associated with your Website Account at any time by signing in to your Account, if you have one, and visiting the account settings section. You may also contact Pathify to request access to, correction of, or deletion of Personal Data that you have provided to Pathify through the Website. Pathify may need to retain certain information where Pathify has a legal obligation or lawful basis to do so. Pathify does not charge a fee for these requests unless a request is excessive, repetitive, or manifestly unfounded. 7.1 Verification of your request. To protect your Personal Data, Pathify will verify your identity before processing a request. Verification may involve confirming details about your recent interactions with Pathify and asking for certain identifying information. 7.2 Authorized agents. You may designate an authorized agent to submit a request on your behalf. Pathify may require proof of the agent’s authority and verification of your identity. 8. Security of Personal Data Pathify implements reasonable technical, organizational, and physical security measures designed to protect Personal Data collected through the Website against accidental loss and unauthorized access, use, alteration, or disclosure. No method of transmission over the Internet or method of electronic storage is 100% secure, however, and Pathify cannot guarantee absolute security. 9. GDPR Privacy 9.1. Legal basis for processing Personal Data under the GDPR. Where the GDPR applies, Pathify processes Personal Data collected through the Website on the following legal bases: Consent: Where you have given consent (for example, for marketing communications). Contract: Where processing is necessary to perform a contract with you or to take steps at your request before entering into a contract. Legal obligation: Where Pathify must process Personal Data to comply with a legal obligation. Legitimate interests: Where Pathify has a legitimate interest that is not overridden by your rights and interests (for example, operating and securing the Website, analyzing Website performance, and marketing Pathify’s own services to existing contacts). 9.2. Your rights under the GDPR. Where the GDPR applies, you have the right to: Request access to your Personal Data. Request correction of inaccurate Personal Data. Request erasure of your Personal Data. Object to processing of your Personal Data. Request restriction of processing of your Personal Data. Request data portability. Withdraw consent where processing is based on your consent. Lodge a complaint with a supervisory authority. 9.3. Exercising of your GDPR Data Protection Rights. To exercise any of the rights above, please contact Pathify using the contact information in Section 15. Pathify will respond to verifiable requests within the time required by Applicable Law. 9.3. Exercising your GDPR rights. To exercise any of the rights above, please contact Pathify using the contact information in Section 15. Pathify will respond to verifiable requests within the time required by Applicable Law. 9A. Australia Supplemental Notice 9A.1. Application. If you are located in Australia, this Section 9A describes the rights you have under the Privacy Act 1988 (Cth) (the “Privacy Act”), including the Australian Privacy Principles (the “APPs”) and the Notifiable Data Breaches scheme (the “NDB Scheme”) in Part IIIC of the Privacy Act. References in this Section 9A to “personal information” have the meaning given in the Privacy Act. 9A.2. Your rights under the Privacy Act. Subject to the exceptions in the Privacy Act and other applicable law, you have the right to: (A) Request access to the personal information we hold about you (APP 12). (B) Request correction of personal information that is inaccurate, out of date, incomplete, irrelevant, or misleading (APP 13). (C) Receive notification of an Eligible Data Breach affecting your personal information, consistent with the NDB Scheme. (D) Lodge a complaint with the Office of the Australian Information Commissioner (the “OAIC”) at www.oaic.gov.au if you believe we have handled your personal information in a way that breaches the APPs. 9A.3. Overseas disclosures. Personal information collected through the Website may be disclosed to recipients located outside Australia. Pathify takes reasonable steps to ensure that such recipients are subject to contractual obligations that together provide a substantially similar level of protection to the APPs. 9A.4. Exercising your Privacy Act rights. To exercise any of the rights described above, please contact Pathify using the contact information in Section 15. Pathify will respond to verifiable requests within the time required by Applicable Law. 9B. New Zealand Supplemental Notice 9B.1. Application. If you are located in New Zealand, this Section 9B describes the rights you have under the Privacy Act 2020 (NZ) (the “NZ Privacy Act”), including the Information Privacy Principles (the “IPPs”). References in this Section 9B to “personal information” have the meaning given in the NZ Privacy Act. 9B.2. Your rights under the NZ Privacy Act. Subject to the grounds for refusal in the NZ Privacy Act and other applicable law, you have the right to: (E) Confirm whether we hold personal information about you and request access to that information (IPP 6). (F) Request correction of personal information that is inaccurate, out of date, incomplete, or misleading (IPP 7). (G) Be informed where personal information about you is collected from a source other than you, consistent with IPP 3A as it takes effect on 1 May 2026. (H) Receive notification of a privacy breach affecting your personal information that is likely to cause serious harm. (I) Make a complaint to the New Zealand Office of the Privacy Commissioner (the “OPC”) at www.privacy.org.nz if you believe we have interfered with your privacy under the NZ Privacy Act. 9B.3. Cross-border disclosures. Personal information collected through the Website may be disclosed to recipients located outside New Zealand. Pathify takes reasonable steps to ensure that such recipients are subject to contractual obligations that together provide protections comparable to those required by IPP 12. 9B.4. Exercising your NZ Privacy Act rights. To exercise any of the rights described above, please contact Pathify using the contact information in Section 15. Pathify will respond to verifiable requests within the time required by Applicable Law. 10. US State Privacy Notice Depending on your state of residency, you may have rights under applicable state privacy laws, including the CCPA/CPRA, the Colorado Privacy Act, and comparable laws in other states. The availability, scope, and timing of these rights vary by state. Subject to applicable exceptions, these rights may include: Right to access: You may have the right to request that Pathify disclose what Personal Data Pathify collects, uses, and discloses about you. Right to correction: You may have the right to request correction of Personal Data that Pathify maintains about you. Right to deletion: You may have the right to request that Pathify delete Personal Data that Pathify has collected from you. Right to data portability: You may have the right to request a copy of your Personal Data in a portable format. Right to withdraw consent: You may have the right to withdraw consent to processing of your Personal Data. Right to limit use and disclosure of sensitive Personal Data: You may have the right to limit processing of your sensitive Personal Data. Right to opt out: You may have the right to opt out of certain uses of your Personal Data, including targeted advertising, “sale” or “sharing” for cross-context behavioral advertising, or profiling producing legal or similarly significant effects. Pathify does not engage in profiling producing legal or similarly significant effects on users through the Website. Right to appeal: If Pathify declines to take action on your request, Pathify will inform you of the decision and reasoning. You may appeal by contacting Pathify; Pathify will respond to the appeal within the time required by Applicable Law. If the appeal is denied, you may contact your state Attorney General to submit a complaint. To exercise any of these rights, please contact Pathify at [email protected] or by the methods described in Section 15. 10A. Colorado Supplemental Notice. If you are a Colorado resident, you have the rights described above under the Colorado Privacy Act (C.R.S. § 6-1-1301 et seq.). Pathify will respond to verifiable requests within 45 days, with the possibility of a 45-day extension where reasonably necessary. 10B. Browser Privacy Signals (Do Not Track and Global Privacy Control). Where required by Applicable Law, Pathify treats GPC signals received through the Website as valid opt-out-of-sale/sharing requests for the Device from which the signal is received. Pathify does not currently respond to Do Not Track browser signals because there is no uniform industry standard for interpreting them. 11. California Supplemental Notice 11.1. Categories of Personal Data collected through the Website. Pathify may have collected the following categories of Personal Data from Website visitors in the twelve months preceding the Last Updated date: Category A (Identifiers): Name, email address, phone number, postal address, IP address, unique personal identifier, online identifier, account name. Source: directly from you through Website forms or through Third-party Social Media Services you use. Purpose: as described in Section 3. Category B (California Customer Records categories): Name, address, phone number, employment information. Source: directly from you through Website forms. Purpose: as described in Section 3. Category F (Internet or other similar network activity): Browsing history on the Website, search history on the Website, information regarding interaction with the Website. Source: automatically as you use the Website. Purpose: as described in Section 3. Category G (Geolocation data): Approximate location derived from IP address. Source: automatically as you use the Website. Purpose: as described in Section 3. Pathify does not routinely collect other CCPA/CPRA categories of Personal Data through the Website. 11.2. Sources of Personal Data. Personal Data is collected directly from you when you voluntarily provide it through Website forms, automatically as you use the Website, and through Third-party Social Media Services you choose to use in connection with the Website. 11.3. Use of Personal Data. Personal Data is used for the purposes described in Section 3. 11.4. Disclosure of Personal Data. Personal Data is disclosed to the categories of recipients described in Section 4. 11.5. Sale and Sharing of Personal Data. As defined under the CCPA/CPRA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating Personal Data to a third party for monetary or other valuable consideration, and “share” has the meaning given under Cal. Civ. Code § 1798.140(ah). Pathify does not sell Personal Data collected through the Website in the ordinary sense of that term. To the extent Pathify uses analytics or advertising vendors that do not function solely as service providers for a given activity, certain disclosures of Personal Data may constitute a “sale” or “sharing” under the CCPA/CPRA. In the twelve months preceding the Last Updated date, categories of Personal Data that may have been sold or shared are limited to Category A (Identifiers), Category F (Internet or other similar network activity), and Category G (Geolocation data). Categories of recipients that may receive Personal Data in ways that could constitute a “sale” or “sharing” are limited to analytics or advertising vendors and, where applicable, business partners. Disclosures to Pathify’s service providers remain governed by the service-provider restrictions described in this Privacy Policy. Pathify does not knowingly sell or share the Personal Data of Consumers that Pathify actually knows are under 16 years of age. 11.6. Your rights under the CCPA/CPRA. If you are a California resident, you have the rights described in Section 10, including the right to access, delete, correct, and obtain portable copies of your Personal Data, the right to opt out of sale or sharing, the right to limit use and disclosure of sensitive Personal Data, the right to non-discrimination for exercising your rights, and the right to appeal. 11.7. Exercising your CCPA/CPRA rights. To exercise any of the rights in Section 10, please contact Pathify using the contact information in Section 15. Pathify will verify your request and respond within the time required by Applicable Law. 11.8. Do Not Sell or Share My Personal Data. You have the right to opt out of the sale or sharing of your Personal Data. To exercise this right, please contact Pathify using the contact information in Section 15, or use any “Do Not Sell or Share My Personal Data” controls available through the Website. You may also use GPC signals as described in Section 10B. Opt-out is specific to the browser or device from which you exercise the right. 11.9. California Shine the Light Law and Minor Users. Under California Civil Code § 1798.83, California residents with an established business relationship with Pathify may request information once a year about Pathify’s sharing of Personal Data with third parties for third-party direct marketing purposes. California Business and Professions Code § 22581 allows California residents under the age of 18 who are registered users of online sites to request removal of content they have publicly posted. To make either request, contact Pathify using the contact information in Section 15. 12. Children’s Privacy The Website is not directed to children under the age of 13. Pathify does not knowingly collect Personal Data from children under the age of 13 through the Website. If you are a parent or guardian and you believe a child has provided Personal Data through the Website, please contact Pathify. 13. Links to Other Websites The Website may contain links to other websites that are not operated by Pathify. If you click on a third-party link, you will be directed to that third party’s site. Pathify strongly advises you to review the Privacy Policy of every site you visit. Pathify has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services. 13A. Accessibility Pathify is committed to providing an accessible Website and targets substantial conformance with the Web Content Accessibility Guidelines (WCAG) 2.2 Level AA or such successor standard as Pathify may adopt. If you experience difficulty accessing any portion of the Website or this Privacy Policy, or if you require this Privacy Policy or any related privacy disclosure in an alternative accessible format (such as large print, Braille, or an accessible electronic format), please contact Pathify using the information in Section 15. Pathify will work to provide the requested information in a timely and accessible manner. 14. Changes to This Privacy Policy Pathify may update this Privacy Policy from time to time by publishing a new version on the Website. Changes to this Privacy Policy are effective when posted on this page and Pathify has updated the “Last Updated” date at the top of this Privacy Policy. You should check this page periodically to review any changes. 15. Contact Us If you have any questions about this Privacy Policy, or if you wish to exercise any rights described in this Privacy Policy, you can contact Pathify: By email: [email protected] By mail: Path Education Inc., 5910 S University Blvd, C-18 #224, Greenwood Village, CO 80121, United States Through the Pathify contact page: https://pathify.com/contact/