Privacy Policy

Last updated: [Date]

1. Introduction

The Path Project ("we", "us", "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our website (www.thepathproject.co.uk) and book our programme.

We are the data controller responsible for your personal data.

2. Information We Collect

When you book the programme, we collect:

  • Participant's full name, date of birth, school/college, year group

  • Participant's email address and mobile number

  • Parent/guardian's full name, relationship, email, mobile, and emergency contact number

  • Medical conditions, allergies, dietary requirements, learning needs

  • Billing information for payment processing

When you use our website, we may collect:

  • IP address and browser information

  • Cookie data (see our Cookie Policy)

  • Pages visited and time spent on site

When you complete the Lumina Spark assessment:

  • Assessment responses and results

  • Performance and personality profile data

If you consent to media use:

  • Photographs and video footage

  • Testimonial quotes and feedback

3. How We Use Your Information

We use your personal data to:

  • Process your booking and payment

  • Communicate with you about the programme

  • Provide coaches with necessary information to support your child appropriately

  • Deliver the programme, including psychometric assessments

  • Send pre-programme materials and post-programme resources

  • Comply with legal obligations and safeguarding requirements

  • Improve our services (anonymised data only)

  • Marketing purposes (only with your explicit consent)

Legal basis for processing:

  • Contract performance (delivering the programme you've booked)

  • Legitimate interests (improving our services, safeguarding)

  • Legal obligation (safeguarding, health and safety)

  • Consent (marketing, photography/filming)

4. Who We Share Your Information With

We may share your personal data with:

Service providers:

  • Payment processors (Stripe/Square) - to process payments

  • Lumina Learning - to deliver psychometric assessments

  • Venue providers (Clifton College) - for access and catering arrangements

  • Our coaching team - to deliver the programme safely and effectively

  • Email service providers - to send programme communications

Legal requirements:

  • Law enforcement or regulatory bodies if legally required

  • Safeguarding authorities if we have concerns about a child's welfare

We will never:

  • Sell your personal data

  • Share your data for third-party marketing

  • Transfer data outside the UK/EEA without appropriate safeguards

5. Data Security

We implement appropriate technical and organisational measures to protect your data:

  • Secure payment processing (PCI-DSS compliant)

  • Encrypted data transmission (SSL)

  • Password-protected systems

  • Limited access to personal data (only authorised staff)

  • Regular security reviews

6. How Long We Keep Your Data

Participant booking data: 7 years (for safeguarding and legal purposes)

Medical/dietary information: Deleted 6 months after programme completion (unless safeguarding concerns require retention)

Assessment results: Retained securely; participants receive their own copy

Marketing consent: Until you withdraw consent

Photography/video: Until consent is withdrawn (though published materials may remain in circulation)

Financial records: 7 years (HMRC requirement)

7. Your Rights

Under UK GDPR, you have the right to:

Access - Request a copy of the personal data we hold about you

Rectification - Request correction of inaccurate data

Erasure - Request deletion of your data (subject to legal obligations)

Restriction - Request we limit how we use your data

Portability - Receive your data in a portable format

Object - Object to processing based on legitimate interests

Withdraw consent - For marketing or media use at any time

To exercise these rights, contact us at: info@thepathproject.co.uk

You also have the right to complain to the Information Commissioner's Office (ICO): www.ico.org.uk

8. Children's Data

As participants are under 18, we obtain consent from parents/guardians before collecting any personal data.

Parents/guardians have the right to:

  • Access their child's data

  • Request correction or deletion

  • Withdraw consent at any time

We take extra care with children's data and:

  • Only collect necessary information

  • Limit access to authorised staff and coaches

  • Follow safeguarding protocols

  • Obtain separate consent for photography/filming

9. Cookies

Our website uses cookies to improve your experience. See our separate Cookie Policy for details.

You can control cookies through your browser settings.

10. Marketing Communications

We will only send you marketing emails if you've given explicit consent.

You can unsubscribe at any time by:

11. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for their privacy practices. Please review their privacy policies separately.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last updated" date.

For significant changes, we will notify you by email.

13. Contact Us

If you have any questions about this Privacy Policy or how we handle your data:

Email: info@thepathproject.co.uk

ICO Registration: TBC