Introduction

PATH is a platform for creating and sharing short-form videos (the “Platform”). This privacy policy ("Privacy Policy") applies to the personal information that PATH processes in connection with the Platform and other PATH-related applications, websites, products, and services that link to or reference this Privacy Policy (collectively, the "Services").

Data Controller: If you live in the European Economic Area (“EEA”), the UK, or Switzerland, PATH controls any information processed in connection with this Privacy Policy.

What Information We Collect

We collect three categories of information: Information You Provide, Automatically Collected Information, and Information From Other Sources. More detail about each of the categories is provided below.

Information You Provide

• Profile Information. We collect information that you provide when you set up your PATH account, such as your date of birth, username, email address and/or telephone number, and password. You can add other information to your profile, such as a bio or a profile photo.

• User Content. We collect the content you create or publish through the Platform, including photographs, videos, audio recordings, livestreams, and comments, and the associated metadata (such as when, where, and by who the content was created). We collect User Content through pre-loading at the time of creation, import, or upload, regardless of whether you choose to save or upload that User Content, for example, to recommend music based on the video. We also collect content (such as text, images, and video) from your device's clipboard if you choose to copy and paste content to or from the Platform or share content between the Platform and a third party platform.

• Direct Messages. When you communicate with others using direct messages, we collect the content of the message and the associated metadata (such as the time the message was sent, received and/or read, as well as the participants in the communication). We do this to block spam, detect crime, and to safeguard our users.

• Your Contacts. When you choose to import your contacts, we will collect information from your device’s phone book or your social media contacts. We use this information to help you make connections on the Platform when you are using our “Find Friends” function and to suggest your account to others.

• Purchase Information. We collect your payment card information or other third-party payment information (such as PayPal) where payment is required. We also collect your transaction and purchase history.

• Surveys and Promotions. We collect information you provide if you choose to participate in one of our surveys, promotions, contests, or marketing campaigns or events.

• Information When You Contact Us. When you contact us, we collect the information you send us, such as proof of identity or age, feedback about your use of our Services or information about possible violations of our Terms of Service (our “Terms”), Community Guidelines (our “Guidelines”), or other policies.

Automatically Collected Information

• Technical Information. We collect certain device and network connection information when you access any of our Services. This information includes your device model, operating system, keystroke patterns or rhythms, IP address, and system language. We also collect service-related, diagnostic, and performance information, including crash reports and performance logs. We automatically assign you a device ID and user ID when you use our Platform. Where you log-in from multiple devices, we use information such as your device ID and user ID to identify your activity across devices to give you a seamless log-in experience and for security purposes.

• Location. We collect your approximate location based on your Technical Information (such as SIM card and IP address) to customise your experience and for diagnostics and troubleshooting. With your permission, we may also collect precise location information (such as GPS).

• Usage Information. We collect information about how you engage with our Services, including information about the content you view, how long and how often you use our Services, how you engage with other users, your search history on the Platform, and your settings.

• Content Characteristics and Features. We detect and collect characteristics and features about the video and audio recordings that are part of your User Content, for example, by identifying objects and scenery; the existence or location within an image of a face or other body parts; and the text of words spoken in your User Content. We do this, for example, for content moderation and to provide special effects (such as video filters and avatars) and captions.

• Inferred Information. We infer your attributes (such as age-range and gender) and interests based on the information we have about you. We use inferences to, for example, keep our Platform safe, content moderation, and, where permitted, to serve you personalised ads based on your interests.

• Cookies. We use cookies and similar tracking technologies to operate and provide our Services. For example, we use cookies to remember your language preferences, make sure you don’t see the same video more than once, and for security purposes. We also use these technologies for marketing purposes. To learn more about our use of cookies, please see our Web Cookies Policy and Platform Cookies Policy. We will obtain your consent to our use of cookies where required by law.

Information From Other Sources

• Advertising, Measurement and Data Partners. Advertisers and measurement and data partners share information with us such as mobile identifiers for advertising, hashed email addresses, and event information about the actions you’ve taken on a website or app. Some of our advertisers and other partners enable us to collect similar information directly from their website or app by integrating our PATH Advertiser Tools (such as PATH Pixel).

• Third Party Platform Information. If you choose to sign-up for PATH using a third party platform (such as Facebook or Google or Linkedin), the third party platform will share information such as your email address, user ID, and public profile.

• Integration Partners. When you interact with any third party service (such as third party apps, websites or products) that integrate PATH Developer Tools, we will receive the information necessary to provide you with features like cross-service authentication or cross-posting. For example, this will happen if you log in to another service with your PATH account or if you use the PATH “share” button on a third party service to share content from the third party service to PATH.

• Others. Other users or individuals may provide us with information about you, including if you are featured or mentioned in another user’s content or direct messages, a complaint or feedback submitted by a third party, or if your contact information is provided to us by another user through our “Find Friends” function.

How We Use Your Information

We use your information to operate, provide, develop, and improve our Services, including for the following purposes. You can find more detail in “Our Legal Bases and How We Process Your Information”.

• Provide and administer our Services, such as enabling you to create, share, and consume content and to interact with other users and their content.

• Personalising and customising your experience on the Platform, such as providing your For You feed.

• Process, facilitate, or fulfill requests of purchases of products, goods, and services.

• Enforce our Terms, Guidelines, and other policies that apply to you. We review User Content and other information to protect the safety and well-being of our community.

• Provide certain interactive features, such as enabling your content to be used in other users’ videos and suggesting your account to other users to help connect you with other users.

• Provide and improve our advertising services, including to serve ads (including personalised ads when permitted) and to measure and understand the effectiveness of the ads.

• Maintain and enhance the safety, security, and stability of our Services by identifying and addressing technical or security issues or problems (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity).

• Review, improve, and develop our Services, including by monitoring interactions and usage across your devices, analysing how people are using our Services, and informing our algorithms.

• Share your information with third party platforms at your request to provide you with features, like content sharing when you integrate your PATH account with a third party service.

• Promote our Services or third party services through marketing communications, contests, sweepstakes, or promotions.

• Comply with our legal obligations, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people.

How We Share Your Information

Service Providers

We engage service providers that help us provide, support, and develop our Services and understand how they are used. They provide services such as cloud hosting, content delivery, customer and technical support, content moderation, marketing, analytics, and online payment. We share Information You Provide, Automatically Collected Information, and Information From Others with these service providers as necessary to enable them to provide their services.

Partners

Integration Partners: When you choose to access third party services from our Platform, we may share your Usage Information with third party partners to help them integrate with PATH technology and to provide you with a seamless experience.

Third Party Platforms. We partner with third party platforms (such as Facebook or Google) to offer you a seamless log-in and content sharing experience. We share information with these third party platforms when you want to use these features. For example, if you choose to:

• log-in to a third party platform using your PATH account, we will share your basic account information and any other information you provide;

• sign-up or log-in to the Platform using your account details from a third party platform, we will share certain Technical Information to facilitate this;

• share User Content you publish on the Platform on other social media platforms, we will share your User Content and related information.

Advertising Partners

Advertisers: We provide advertisers with aggregate information about how their ads have performed to help them measure the effectiveness of their advertising campaigns. We create this aggregate information using Technical Information and Usage Information relating to how you engage with ads on our Platform, and Information From Other Sources. We share your information directly with advertisers where you give us your permission.

Measurement and Data partners: We also share Technical Information and Usage Information with third party measurement providers who help us measure advertising on our Platform and help our advertisers determine how effective their ads have been.

Our Corporate Group

As a global company, our Services are supported by a number of affiliated entities within our corporate group (“Corporate Group”). We share Information You Provide, Automatically Collected Information, and Information From Others with our Corporate Group as necessary to enable them to provide important functions such as cloud hosting, content delivery, security, research and development, analytics, online payments, customer and technical support, and content moderation.

Others

We share your information in other limited scenarios as follows.

Other users and the public: Based on your privacy settings, your Profile Information and User Content may be visible to other users of the Platform and the public. You can learn about account types and privacy settings, including how to limit the audience for your videos, here. Your profile and content may also be visible to third parties, such as search engines, content aggregators, and news sites. You may choose to share information, such as text and photos, with others on the Platform using direct messaging.

Corporate transactions: Your information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control, or acquisition of all or a portion of our business.

Legal obligations and rights: We may access, preserve, and share the information described in "What Information We Collect" with law enforcement agencies, public authorities, copyright holders, or other third parties if we have good faith belief that it is necessary to:

• comply with applicable law, legal process or government requests, as consistent with internationally recognised standards;

• protect the rights, property, and safety of our users, copyright holders, and others, including to protect life or prevent imminent bodily harm. For example, we may provide information (such as your IP address) to law enforcement in the event of an emergency where someone’s life or safety is at risk.

• investigate potential violations of and enforce our Terms, Guidelines, or any other applicable terms, policies, or standards; or

• detect, investigate, prevent, or address misleading activity, copyright infringement, or other illegal activity.

To learn more about how we handle requests from law enforcement agencies and public authorities, see our Law Enforcement Guidelines.

Our Legal Bases and How We Process Your Information

We may only use your information when we have a “legal basis” to do so. We use different legal bases depending on why we use your information (in other words, the “purpose” of our processing). These legal bases involve contractual necessity, legitimate interests (ours, yours or those of another party), consent, compliance with a legal obligation, performing a task in the public interest, and protection of vital interests.

Here we explain the legal bases we rely on when we process your information. This section also describes why we use your information, how this information is processed, the categories of information involved, and the associated rights (which always includes the right to access your information). For more information on how to exercise any of your rights, please check out the “Your Rights and Choices” section in the Privacy Policy.

Contractual Necessity

We use Information You Provide, Automatically Collected Information, and Information From Other Sources where it is necessary to perform the contract you enter into (our Terms) when you register for, access, or use our Services. This means we use your information to:

• Provide you with our Services. We use your information to provide you with our Services. This includes using your information so you can create, share, and consume content, and interact with others. It also includes using your information to provide you with products and services you purchase through the Platform. We also personalise your experience on the Platform, such as providing your “For You” feed, which shows you videos based on what we have determined could be interesting for you. See here for more information.
• Enforce our Terms, Guidelines, or policies. We use your information to enforce our Terms, Guidelines, and policies. This may include removing content or suspending or banning your account if we determine that you are violating our Terms or Guidelines.
• Administer our Services. We also use the information we have to administer our Services, such as communicate with you on service related matters and respond to your queries (including when you tell us about a problem or ask for a copy of your information).

Your Rights: Whenever we use your information on the basis that it is necessary for the contract we have with you, you have the right to port information you have provided to us.

Legitimate Interests

We use your information where this is necessary to achieve legitimate interests - whether belonging to us, you, or a third party - provided these interests are not outweighed by your interests or fundamental rights and freedoms. We use your information to:

Enable your videos to be used in interactive features.

• Our interactive features, like Duet and Stitch, enable other users to include your videos in their videos (if you allow this in your settings).
• Legitimate Interest relied upon: To provide users with tools to inspire creativity, collaboration, and enjoyment, and to create opportunities for users to reach new audiences.
• Information used: Information You Provide and Automatically Collected Information.

Suggest your account to other users.

• We may suggest your account to other users, including other users who use our “Find Friends” features.
• Legitimate Interest relied upon: To enable users to quickly and efficiently find and connect with others users on our Platform.
• Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Provide all users with non-personalised advertising.

• We show all users non-personalised advertising, including those who have chosen not to receive personalised ads.
• Legitimate Interest relied upon: We show non-personalised ads to keep our Platform free of charge. We process limited categories of your information to make sure our advertising service is useful to our advertisers (for example, to serve ads to users in a particular country or to users who speak the same language).
• Information used: Automatically Collected Information and Information From Other Sources.

Measure the effectiveness of advertising.

• We measure the effectiveness of the advertising you see on our Platform.
• Legitimate Interest relied upon: To enable advertisers to view and understand the performance of their ads and make informed decisions (such as what kinds of ad campaigns they may want to run and the type of audience they want to reach). This helps keep the advertising on our Platform relevant and keeps our Platform free for all users.
• Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Ensure the safety and well-being of our community.

• We use your information to ensure your safety and well-being, including by reviewing User Content (and if permitted under applicable law, direct messages and associated metadata) for breaches of our Terms, Guidelines, and other policies. We also infer your age range, and under certain circumstances, may ask you to provide additional information to confirm your age.
• Legitimate Interest relied upon: To keep our users safe, review compliance with our Guidelines, and prevent misuse of our Services.
• Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Ensure the security and stability of our Services.

• We use your information to carry out testing and analysis to ensure the stability and security of our Services, including by identifying and combating technical or security issues (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity).
• Legitimate Interest relied upon: To ensure the ongoing stability and security of our Services and to ensure they are continuously available and functioning.
• Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Review, improve and develop our Services.

• We use the information we have to understand how people are using our Services to improve and develop our Services (including our algorithms). We also use this information to understand and promote popular topics and emerging trends on the Platform.
• Legitimate Interest relied upon: To improve, promote, and develop our Services in an informed way.
• Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Share your information with third parties to provide additional features.

• We share your information with third parties providing additional features when you choose to use these features. For example, when you link your PATH account to a third party service, the third party will be able to obtain your basic account information and other information you choose to provide depending on the permissions you give.
• Legitimate Interest relied upon: To enable those third party service providers to better authenticate users and optimise the user experience.
• Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Marketing communications.

• We may send you direct marketing messages about features of our Services and third party services that we think will interest you. We may also send you promotions, contests, or marketing campaigns or events. We will obtain your consent to send you messages where required by law.
• Legitimate Interest relied upon: To promote new developments and features of our Services and/or third party products and services.
• Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Your Rights: Whenever we use your information on the basis that it is necessary for Legitimate Interests, you can object to, and request restriction of, such usage.

Your Consent

We ask for your consent to access or use your information for specific purposes. If we do, you’ll always be able to revoke your consent through the device permissions or in-app settings.

Personalised advertising.

• With your consent, we will serve you with personalised ads based on your activity on and off of the Platform.

• Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources for this purpose.

Your rights: Whenever we use your information based on your consent, you can withdraw your consent at any time. However, your withdrawal of consent will not affect the lawfulness of processing your information based on your consent prior to your withdrawal of consent. You can withdraw your consent for personalised ads by following these instructions.

You also have the right to port information you have provided to us that we use based on your consent.

Compliance with a legal obligation

We may use your information including your Profile Information or User Content where it is necessary to comply with a legal obligation. This includes situations where we have obligations to take measures to ensure the safety of our users or comply with a valid legal request such as an order from law enforcement agencies or courts. We generally use Information You Provide and Automatically Collected Information, although it depends on the specific situation.

To perform a task in the public interest

We may use your information where it is necessary to perform a task in the public interest, including undertaking research, preventing and detecting crime, safeguarding children and promoting public safety, security, and integrity as laid down by applicable law. We generally use Information You Provide and Automatically Collected Information, although it depends on the specific situation.

Your rights: When we use your information on the basis that it is necessary for a task carried out in the public interest, you have the right to object to, and seek restriction of, our usage.

To protect someone's vital interests

We may use your information where it is necessary to protect your or someone else's life, physical integrity, or safety. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life. We generally provide Information You Provide and Automatically Collected Information, although it depends on the specific situation.

Your Rights and Choices

You have rights and choices when it comes to your information. Some of these rights apply generally, while others will only apply in certain circumstances. Depending on the scenario, these rights may be subject to some limitations.

Access your information: You can ask us, free of charge, to confirm what information we process about you, to provide certain information about the processing, and for a copy of your information. In-app controls enable you to:

• access your information that is available to other users when you navigate to the "me" tab on your account

• request a copy of your information by using the ‘Download your data’ tool. Click here for detailed instructions.

Delete your information: You can delete or ask us to delete some or all of your information. In-app controls enable you to:

• delete the content posted on your profile, such as your User Content and your Profile Information.

• delete your full account.

• request the deletion of a particular piece of content using the in-app reporting feature. More information is available here.

Rectify your information: You can change or ask us to change or correct your information where that information is not accurate. You can change or correct much of your information through the in-app controls and settings (such as your Profile Information and video content).

Port your information: You have the right to data portability in circumstances where we rely on contractual necessity and consent as our legal basis. This means that you have the right to receive your information in a structured, commonly used, and machine-readable format and to share it with a third party. You can exercise your right of portability by choosing to ‘Download your data’ in your settings. Click >here for detailed instructions.

Object to the processing of your information: You also have the right to object to the processing of your information in certain circumstances. The right to object applies when the processing you are objecting to is relying on legitimate interest or public interests as a legal basis. In submitting an objection request, you should explain what specific processing activity you are objecting to and why the processing should be stopped. We will stop the particular processing if we don't have compelling legitimate grounds to continue that processing or don’t need it for legal claims.

Restrict the processing of your information: You have the right to request the restriction of the processing of your information where (a) you are challenging the accuracy of the information, (b) the information has been unlawfully processed, but you are opposing the deletion of that information, (c) where you need the information to be retained for the pursuit or defence of a legal claim, or (d) you have objected to processing and you are awaiting the outcome of that objection request.

Exercising your rights: To exercise any of the above rights, please contact us through our . Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details or provide additional information so that we can understand the issue.

We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the Irish Data Protection Commission (PATH Ireland’s lead supervisory authority) or with your local supervisory authority.

In addition to these rights, you can control privacy settings for your account. Click  for more information.

Data Security and Retention

Security of your information is important to us. We maintain appropriate technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods.

We retain information for as long as necessary to provide our Services and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing our Services, and enhancing the safety, security and stability of our Services), and for the exercise or defence of legal claims.

The retention periods will be different depending on the type of information and the purposes for which we use the information. For example, when we process your information to provide you with the Service, we keep this information for as long as you have a PATH account. This information includes your Profile Information, User Content, and Direct Messages. If you infringe our Guidelines or Terms, we may remove your Profile Information and/or User Content from public view immediately but keep your information as is necessary to process the infringement.

Our Global Operations and Data Transfers

To support our global operations, we share your information with members of our Corporate Group and other entities outside of your country of residence as described in the “How We Share Your Information” section. These entities are committed to using and storing information in compliance with applicable privacy laws and to implementing appropriate security measures to protect your information.

When we transfer your information outside of the European Economic Area (EEA), the United Kingdom, or Switzerland, we ensure it benefits from an adequate level of data protection by:

• relying on European Commission adequacy decisions made under Article 45 of the GDPR, finding that the third country to which the information is being transferred offers an adequate level of data protection; or

• using European Commission approved standard contractual clauses under Article 46 of the GDPR for the transfer of information to all other third countries. For a copy of these standard contractual clauses, please contact us via the details provided in the “Contact us” section below.

Younger Users

You must be at least 13 years old to use the Services. If you believe that we have information about someone younger than this, please contact us via the details set out in the “Contact Us” section below.

To provide users younger than 18 with an age-appropriate experience, certain features are not available. Further details are available in our Help Centre.

If you are the guardian of a teen, our Safety Centre contains information and resources to help you understand the Platform and the tools and controls you and your teen can turn on together.

Privacy Policy Updates

We may amend or update this Privacy Policy from time to time. We will notify you of any material changes to this policy by a notice provided through the Platform or by other means.