PathPair Privacy Policy

Last Updated: September 10, 2026

PathPair LLC ("PathPair," "we," "our," or "us") respects your privacy and believes that trust should extend beyond the hiring experience—it should include how information is collected, used, protected, shared, retained, and deleted.

This Privacy Policy explains how PathPair handles information when you:

• Visit our Website;

• Contact us regarding our services;

• Use a PathPair pricing or informational tool;

• Participate in a Bridge Assessment;

• Use PathPair's Candidate Experience Assessment;

• Submit PathPair's Preliminary Financial Exposure Assessment;

• Engage PathPair for Hiring Experience Engineering;

• Participate in a Hiring Experience Diagnostic;

• Engage PathPair for AI Implementation Enablement;

• Engage PathPair for Implementation Engineering;

• Participate in AI Enablement Assurance or Reassessment;

• Participate in workshops, research, advisory services, or related Professional Services; or

• Otherwise interact with PathPair.

Please read this Privacy Policy carefully before using our Website, submitting information, or engaging PathPair.

This Privacy Policy describes PathPair's practices. It does not replace any Data Processing Addendum ("DPA"), Professional Services Agreement ("PSA"), Statement of Work ("SOW"), confidentiality agreement, or other executed agreement that may apply to a Client engagement.

Where an executed agreement imposes additional or different data-processing obligations, that agreement governs as provided in its terms.

1. Our Privacy Philosophy

Privacy is more than a legal obligation.

It is part of our responsibility to the Clients, Candidates, hiring teams, and other people whose information may become part of our work.

At PathPair, we believe:

• Trust should be earned, not assumed.

• We should collect only information reasonably necessary for the applicable purpose.

• Better hiring experiences do not require unnecessary personal data.

• Candidates should not become raw material for analysis simply because information exists.

• Clients should understand how their information is used.

• Artificial Intelligence should enhance human capability without weakening human accountability.

• Evidence should take precedence over technology-generated output.

• Sensitive information should be minimized whenever practical.

• Personally identifiable information should be removed, redacted, aggregated, or de-identified when the work does not require it.

• Privacy, security, accessibility, and human responsibility should be considered as part of system design rather than added after the fact.

Whenever practical, PathPair encourages Clients and assessment participants to provide aggregated, de-identified, pseudonymous, or redacted information rather than information that directly identifies an individual.

Depending on the circumstances, PathPair may act as either a data controller or a data processor, sometimes referred to as a "service provider" under certain privacy laws.

1.1 Our Role: Controller vs. Processor

Controller

PathPair acts as a controller when we determine why and how personal information is used for our own business operations.

This may include:

• Operating our Website;

• Responding to inquiries;

• Managing prospective-Client relationships;

• Administering complimentary assessments;

• Providing requested assessment results;

• Scheduling meetings;

• Maintaining business communications;

• Managing Client relationships;

• Processing payments;

• Maintaining business records;

• Securing our systems;

• Preventing fraud or misuse;

• Conducting permitted business analytics;

• Marketing our services where permitted; and

• Complying with legal obligations.

Processor

When PathPair processes personal information on behalf of a Client in connection with Professional Services, PathPair generally acts as a processor or service provider and processes that information according to:

• The Client's documented instructions;

• The Professional Services Agreement;

• The applicable Statement of Work;

• Any applicable Data Processing Addendum;

• Applicable confidentiality obligations; and

• Applicable law.

In those circumstances, the Client generally determines the purposes and means of processing the personal information.

PathPair does not independently repurpose Client Personal Data for unrelated purposes merely because the information was made available during an engagement.

If you are an individual whose information PathPair processes solely on behalf of a Client, the Client may be the appropriate organization to contact regarding your privacy rights. PathPair will reasonably assist the Client with applicable privacy requests as required by our agreements and applicable law.

2. Information We Collect

The information PathPair collects depends on how you interact with us.

2.1 Website & Inquiry Information

When you contact us, schedule a meeting, submit an inquiry, or otherwise communicate with PathPair, we may collect:

• Name;

• Company or organization;

• Job title;

• Business email address;

• Business telephone number, if provided;

• Information contained in your message;

• Meeting-request information;

• Communication history; and

• Other information you voluntarily provide.

2.2 Discovery, Sales & Bridge Assessment Information

During introductory discussions, Bridge Assessments, scoping conversations, or other pre-engagement interactions, we may collect information such as:

• Hiring challenges;

• Recruiting goals;

• Candidate Experience concerns;

• Organizational structure;

• Talent Acquisition team structure;

• Hiring volume;

• Recruiting processes;

• Hiring workflows;

• Technology environment;

• AI usage at a high level;

• Business concerns;

• Available evidence;

• General operational information;

• Stakeholder information; and

• Meeting notes.

Users should not provide unnecessary Candidate-level or highly sensitive personal information during preliminary discussions.

2.3 Client Engagement Information

During Professional Services, a Client may provide information including:

• Applicant Tracking System reports and exports;

• Hiring metrics;

• Recruiting metrics;

• Candidate stage or status information;

• Candidate survey results;

• Interview scheduling information;

• Interview process documentation;

• Scorecard or debrief information;

• Hiring workflows;

• Standard Operating Procedures;

• Hiring Manager documentation;

• Recruiter documentation;

• Stakeholder feedback;

• Stakeholder interview notes;

• Internal communications;

• Executive observations;

• Project documentation;

• Process maps;

• Scorecards;

• Hiring policies;

• Governance documentation;

• Technology documentation;

• Implementation documentation;

• Vendor documentation;

• System-generated reports;

• Business contact information; and

• Other information reasonably necessary to perform the contracted Professional Services.

Depending on the engagement, information may relate to:

• Candidates;

• Applicants;

• Employees;

• Recruiters;

• Recruiting coordinators;

• Sourcers;

• Hiring managers;

• Interviewers;

• Talent Acquisition stakeholders;

• Human Resources stakeholders;

• Executives;

• Client contacts; and

• Other individuals whose information is contained in Client Materials.

The specific information PathPair requests depends on the scope of the applicable engagement.

PathPair does not require unrestricted access to all Client information merely because such information exists.

2.4 Automatically Collected Website Information

When you visit our Website, certain technical information may be collected automatically by PathPair or Website service providers, depending on the technologies enabled at the time.

This may include:

• IP address;

• Browser type;

• Device type;

• Operating system;

• Date and time of access;

• Pages visited;

• Referring website;

• Approximate location derived from IP address;

• Session information;

• Website interactions; and

• Website performance or analytics information.

The collection that applies to specific PathPair tools may differ, as explained below.

3. Candidate Experience Assessment

PathPair's Candidate Experience Assessment is intentionally designed differently from our other Website services.

When you use the Candidate Experience Assessment:

• Assessment-response processing occurs within your browser on your device.

• PathPair does not receive or store your individual assessment answers or assessment result.

• No account, login, or registration is required to complete the assessment.

• Responses are not submitted to PathPair as part of normal use of the tool.

• Closing or refreshing the assessment removes the locally generated assessment state according to the operation of the tool.

• An optional draft communication may be generated from your answers within the tool.

• PathPair does not receive or store that draft through normal use of the assessment.

• If you copy, modify, or send the draft to another person, that communication occurs outside the Candidate Experience Assessment.

• PathPair has no involvement in that communication unless you separately choose to contact us.

The Candidate Experience Assessment itself is not designed to transmit your assessment answers to PathPair.

The webpage containing the assessment is also intended to operate without assessment-specific analytics or tracking that captures your answers or results.

If PathPair materially changes the way this tool processes information, this Privacy Policy will be updated as appropriate.

The Candidate Experience Assessment should not be confused with the Preliminary Financial Exposure Assessment.

PathPair does receive information submitted through the Preliminary Financial Exposure Assessment.

4. Pricing Estimator

PathPair may provide a complimentary Website Pricing Estimator that allows a visitor to answer basic questions about a potential PathPair engagement and receive directional pricing information.

The current Pricing Estimator is designed to process the selections used to generate the estimate within the visitor's browser.

PathPair does not require a name, email address, account, or registration to receive a Pricing Estimator result.

PathPair does not intentionally collect or store the individual answers you select inside the Pricing Estimator through the estimator itself.

General Website information may still be processed when you visit the page, such as ordinary hosting, security, server, cookie, or Website analytics information described elsewhere in this Privacy Policy where those technologies are enabled.

If you choose to contact PathPair after viewing an estimate, the information you subsequently provide through the contact process is treated separately under this Privacy Policy.

A Pricing Estimator result is a planning estimate and not a binding quote or contract.

5. Preliminary Financial Exposure Assessment

PathPair's Preliminary Financial Exposure Assessment is a voluntary business assessment designed to help organizational and Talent Acquisition leaders obtain a high-level, conservative estimate of potential annual financial exposure associated with certain reported hiring-process conditions.

Unlike the Candidate Experience Assessment and the current Pricing Estimator, PathPair receives and reviews information submitted through the Preliminary Financial Exposure Assessment.

5.1 Information Collected

Depending on the version of the assessment, PathPair may collect:

• Name;

• Business email address;

• Company name;

• Job title, if requested;

• Company size;

• Industry;

• Approximate annual hiring volume;

• Types of roles or hiring populations;

• Approximate salary ranges;

• Time-to-fill information;

• Hiring-process delay information;

• Candidate withdrawal information;

• Offer acceptance information;

• Recruiter headcount;

• Recruiter compensation ranges;

• Approximate recruiter rework or administrative time;

• Hiring-process conditions reported by the respondent;

• Information regarding the source or reliability of submitted estimates;

• General information regarding Candidate and customer overlap;

• General information regarding employer-brand or Candidate Experience effects; and

• Other information voluntarily submitted through the assessment.

The Preliminary Financial Exposure Assessment does not require Candidate names, Candidate resumes, Candidate contact information, employee personnel files, government identification numbers, or other unnecessary highly sensitive personal information.

Please do not submit such information.

5.2 Form Provider

PathPair currently uses Tally.so ("Tally") to host, administer, and capture responses to the Preliminary Financial Exposure Assessment.

When you submit the assessment:

• Your responses are transmitted through Tally;

• Tally processes information in connection with its service;

• PathPair receives and can access the information you submit; and

• The information may subsequently be processed using approved PathPair systems and service providers.

The Preliminary Financial Exposure Assessment is therefore not a browser-only tool.

5.3 How PathPair Uses Assessment Responses

PathPair may use Preliminary Financial Exposure Assessment responses to:

• Review reported hiring conditions;

• Apply PathPair's approved preliminary methodology;

• Calculate a conservative Preliminary Annual Financial Exposure Estimate where supported;

• Determine which exposure categories can responsibly be quantified;

• Identify incomplete, conflicting, or insufficient information;

• Request clarification;

• Prepare a personalized explanation;

• Draft assessment-related communications;

• Conduct internal quality review;

• Improve PathPair methodologies using appropriately anonymized or aggregated information; and

• Determine whether a Bridge Assessment may reasonably provide additional value.

Submitting an assessment does not guarantee that PathPair will be able to produce a financial estimate.

5.4 Human Review & Technology

Technology, including Artificial Intelligence, may assist with:

• Organizing responses;

• Applying approved calculations;

• Identifying missing information;

• Identifying inconsistencies;

• Supporting quality review; and

• Drafting assessment-related communications.

Artificial Intelligence does not replace PathPair's human professional review.

A PathPair human reviews personalized Preliminary Financial Exposure Assessment results before external delivery.

5.5 Assessment Communications

By providing contact information and submitting the assessment, you authorize PathPair to communicate with you for purposes reasonably related to the assessment, including:

• Confirming receipt;

• Requesting clarification;

• Providing the requested result;

• Explaining the result;

• Answering related questions; and

• Discussing an appropriate next step where relevant.

Submitting the assessment does not, by itself, subscribe you to unrelated marketing or promotional communications.

5.6 Information You Should Not Submit

Please do not submit:

• Candidate names;

• Candidate email addresses;

• Candidate resumes;

• Employee personnel files;

• Social Security numbers;

• Government identification numbers;

• Medical or health information;

• Biometric information;

• Banking information;

• Background-check information;

• Immigration records;

• Protected-class information about identifiable individuals; or

• Other unnecessary sensitive personal information.

PathPair does not need this information to conduct the Preliminary Financial Exposure Assessment.

6. AI Implementation Enablement & AI-Related Professional Services

PathPair's AI Implementation Enablement capability applies Hiring Experience Engineering to the intentional use of Artificial Intelligence and AI-enabled technologies within Talent Acquisition and hiring systems.

An AI Implementation Enablement engagement may require information concerning how technology interacts with workflows, people, Candidates, and organizational systems.

Depending on the agreed scope, PathPair may receive or review information concerning:

• AI-enabled recruiting technologies;

• General-purpose AI used for recruiting work;

• AI workflows;

• AI agents;

• Applicant Tracking System AI functionality;

• AI-generated communications;

• AI-supported hiring activities;

• Vendor documentation;

• AI policies;

• AI governance documentation;

• Approval records;

• Operating procedures;

• Human Review procedures;

• Human Access and escalation processes;

• Incident records;

• Change-management records;

• Technology configuration documentation;

• AI usage records;

• System-generated logs or reports where appropriate;

• Candidate Experience evidence;

• Candidate communication templates;

• Aggregate hiring data;

• Aggregate Candidate data;

• Measurement information; and

• Other information reasonably necessary to evaluate the approved AI-enabled hiring scope.

6.1 Data Minimization for AI Implementation Enablement

PathPair does not require raw Candidate Personal Data merely to understand that an AI capability exists.

Where practical, PathPair prefers evidence such as:

• Aggregated reports;

• De-identified records;

• Redacted examples;

• Screenshots with unnecessary identifiers removed;

• Pseudonymous records;

• Process documentation;

• System configuration evidence;

• Sample templates;

• Metadata;

• Workflow maps; and

• Client-prepared summaries or exports.

Identifiable Candidate information should be provided only where reasonably necessary for the approved engagement purpose and permitted under the Client's obligations and applicable agreements.

6.2 Candidate and Employee Information

Where Candidate or employee information is necessary to perform an AI Implementation Enablement engagement, PathPair generally processes that information on behalf of the Client.

The Client remains responsible for:

• Determining the lawful basis for Client-controlled processing;

• Providing required notices;

• Obtaining required permissions where applicable;

• Determining what information may be provided to PathPair;

• Managing employment-related records;

• Making employment decisions; and

• Satisfying the Client's own legal, regulatory, privacy, accessibility, and employment obligations.

PathPair processes Client-provided personal information according to the applicable agreements and documented Client instructions.

6.3 AI Enablement Assurance & Reassessment

AI Enablement Assurance or Reassessment may require PathPair to review operating evidence generated after implementation.

Depending on scope, this may include:

• Usage records;

• Approval records;

• Incident records;

• Change records;

• Candidate Experience evidence;

• Human Access records;

• Escalation evidence;

• Operational measures;

• System-generated reports;

• Adoption information;

• Control evidence; and

• Other information necessary to evaluate the agreed condition.

PathPair applies the same data-minimization principles to Assurance and Reassessment that apply to other Professional Services.

7. Information We Do Not Intentionally Require

PathPair generally does not require highly sensitive personal information to provide its standard Website tools, assessments, or Professional Services.

Unless specifically required, appropriately approved, and relevant to an agreed engagement, do not provide:

• Social Security numbers;

• Driver license numbers;

• Passport information;

• Government identification numbers;

• Full payment-card information;

• Bank-account information;

• Protected Health Information;

• Medical records;

• Biometric information;

• Genetic information;

• Criminal background reports;

• Immigration documents;

• Tax records;

• Authentication credentials;

• Passwords;

• Private cryptographic keys; or

• Other highly sensitive personal information not reasonably necessary for the applicable purpose.

PathPair may encounter information relating to accommodations, accessibility, protected characteristics, or other sensitive circumstances when evaluating Candidate Experience.

Where possible, such conditions should be communicated through aggregated, redacted, de-identified, or otherwise minimized evidence rather than unnecessary identifiable personal information.

If PathPair receives unnecessary sensitive information, we may redact, delete, isolate, return, or otherwise minimize the information as reasonably appropriate, subject to contractual, legal, security, insurance, recordkeeping, or dispute-related requirements.

8. How We Use Information

PathPair may use information for legitimate business and Professional Services purposes including:

• Operating and securing our Website;

• Responding to inquiries;

• Scheduling meetings;

• Managing prospective Clients;

• Conducting Bridge Assessments;

• Performing Hiring Experience Diagnostics;

• Providing AI Implementation Enablement;

• Supporting Implementation Engineering;

• Providing AI Enablement Assurance;

• Conducting AI Enablement Reassessments;

• Performing research and advisory work;

• Administering Preliminary Financial Exposure Assessments;

• Producing requested assessment results;

• Reviewing evidence;

• Conducting stakeholder interviews;

• Analyzing hiring systems;

• Evaluating Candidate Experience;

• Developing Target-State designs;

• Developing recommendations;

• Preparing Client Deliverables;

• Preparing implementation guidance;

• Developing measurement plans;

• Conducting Quality Assurance;

• Managing projects;

• Providing Client support;

• Processing invoices and payments;

• Maintaining business records;

• Improving methodologies;

• Maintaining benchmark libraries;

• Conducting internal research;

• Preventing fraud, misuse, or unauthorized access;

• Protecting PathPair's rights and proprietary materials;

• Meeting contractual obligations; and

• Complying with applicable legal obligations.

PathPair does not sell personal information for monetary consideration.

PathPair does not use Client Confidential Information for unrelated advertising purposes.

PathPair does not use Client Personal Data to train public Artificial Intelligence models.

PathPair does not intentionally use identifiable Candidate or employee information to train public Artificial Intelligence models.

9. Artificial Intelligence & Technology

PathPair uses technology, including Artificial Intelligence, to assist people performing PathPair work.

Artificial Intelligence may support activities such as:

• Drafting;

• Summarization;

• Organization;

• Data normalization;

• Pattern identification;

• Analytical support;

• Research support;

• Document preparation;

• Formatting;

• Quality support;

• Administrative work;

• Project-document organization;

• Preliminary-assessment processing;

• Calculation support;

• Identifying incomplete or conflicting information;

• Implementation planning; and

• Preparing draft communications.

Artificial Intelligence assists PathPair.

It does not replace professional judgment or human accountability.

Artificial Intelligence output is not treated as evidence merely because a system generated it.

Where PathPair provides professionally reviewed Client Deliverables or personalized analytical results, PathPair applies human review according to applicable PathPair standards and agreements.

9.1 Data Minimization Before AI Processing

PathPair applies data-minimization principles when using Artificial Intelligence.

Where reasonably practical, PathPair prefers:

• Aggregated data;

• De-identified data;

• Redacted data;

• Pseudonymous data;

• Minimum-necessary extracts;

• Client-generated reports;

• Synthetic examples where appropriate; and

• Information without unnecessary direct identifiers.

PathPair does not intentionally place raw highly sensitive Candidate, employee, or other personal information into Artificial Intelligence systems when the information is unnecessary for the purpose.

9.2 Client Information & AI

Client Confidential Information, Client Personal Data, proprietary business information, or other sensitive Client Materials may be processed using an approved Artificial Intelligence or technology provider only where that processing is:

• Reasonably necessary for an authorized purpose;

• Consistent with applicable agreements;

• Permitted under Client instructions where required;

• Subject to appropriate privacy and security safeguards; and

• Consistent with PathPair's internal governance standards.

Public or consumer AI tools are not used with identifiable Client Personal Data or Client Confidential Information unless the information is appropriately authorized, protected, anonymized, aggregated, redacted, or otherwise processed in accordance with applicable agreements and safeguards.

PathPair does not transfer professional responsibility for its work to an Artificial Intelligence provider.

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10. Benchmark, Research & De-Identified Data

PathPair may use appropriately anonymized, aggregated, or otherwise non-identifiable information to improve:

• Hiring Experience Engineering;

• AI Implementation Enablement;

• Assessment methodologies;

• Benchmark libraries;

• Internal standards;

• Research;

• Training;

• Quality processes;

• Future services; and

• Industry analysis.

Such information may be derived from:

• Client engagements;

• Preliminary Financial Exposure Assessment submissions;

• Other PathPair assessments;

• Operational observations; and

• Public or licensed research.

Examples may include non-identifiable information concerning:

• Industry;

• Organization size;

• Talent Acquisition team size;

• Hiring-volume ranges;

• Technology platforms;

• Applicant Tracking Systems;

• General AI usage patterns;

• General AI-use categories;

• Hiring Experience Scores;

• Experience Health Indicators;

• Hiring maturity observations;

• Financial Exposure ranges;

• Preliminary Exposure ranges;

• Candidate Experience patterns;

• Hiring-process delays;

• Candidate withdrawal patterns;

• Offer acceptance patterns;

• Recruiter-capacity observations;

• Governance patterns;

• Implementation observations;

• Common operating conditions; and

• General assurance or measurement observations.

PathPair does not need names, email addresses, Candidate identities, or other direct identifiers for benchmark research.

Client-specific confidentiality obligations continue to apply.

PathPair will not knowingly publish or disclose benchmark or research information in a manner that identifies a Client, Candidate, assessment respondent, or other individual without permission or another lawful basis.

De-identified information may be retained after identifiable source data is deleted where permitted by applicable agreements and law.

11. Confidential Information

PathPair treats confidential information as an important part of the trust Clients place in us.

Confidential information received during a Professional Services engagement is handled according to the applicable agreements and may be used only for authorized purposes.

PathPair uses commercially reasonable safeguards designed to:

• Limit access to authorized personnel and approved providers;

• Prevent unnecessary disclosure;

• Protect information during storage and transmission;

• Restrict information to appropriate purposes; and

• Preserve applicable confidentiality obligations after an engagement concludes.

Additional confidentiality requirements may be established through:

• Mutual Non-Disclosure Agreements;

• Professional Services Agreements;

• Statements of Work;

• Change Orders; and

• Data Processing Addenda.

Information voluntarily submitted before an executed Client agreement is handled according to this Privacy Policy but does not automatically become contractually defined Confidential Information merely because it was submitted through a Website form.

12. Third-Party Service Providers

PathPair relies on third-party service providers to operate its Website and business and to provide Professional Services.

Depending on the interaction and services in use, providers may support:

• Website hosting;

• Form hosting;

• Scheduling;

• Client relationship management;

• Client portals;

• Electronic signatures;

• Invoicing;

• Payment processing;

• Email;

• Cloud document storage;

• Collaboration;

• Artificial-Intelligence-assisted productivity;

• Research;

• Website analytics where enabled;

• Security; and

• Related operational functions.

Providers currently or potentially used by PathPair include:

Squarespace

PathPair uses Squarespace for Website hosting and related Website functionality.

Squarespace may process technical information relating to Website visits and other information submitted through Squarespace-hosted functionality.

Tally

PathPair uses Tally to host and capture Preliminary Financial Exposure Assessment submissions and may use Tally for other approved forms.

HoneyBook

PathPair may use HoneyBook for scheduling, client relationship management, project administration, Client portals, invoicing, payments, communications, and related business operations.

Google Workspace

PathPair uses Google Workspace for business email, document creation, file storage, collaboration, communications, and project administration.

Stripe

PathPair may use Stripe for payment processing and related payment records.

PathPair does not need to receive complete payment-card credentials where payment processing is performed directly by a payment processor.

DocuSign and Electronic-Signature Providers

PathPair may use DocuSign, HoneyBook, or another approved electronic-signature provider to execute and retain agreements and related records.

Artificial Intelligence Providers

PathPair may use approved Artificial Intelligence and productivity providers, which may include:

• Anthropic Claude Team;

• OpenAI ChatGPT Business; and

• Other approved providers adopted in accordance with PathPair's privacy, security, contractual, and governance standards.

Use of an Artificial Intelligence provider does not mean all Client information is submitted to that provider.

PathPair applies the data-minimization and authorization principles described in this Privacy Policy and applicable Client agreements.

Analytics Providers

PathPair may use Website analytics technologies such as Google Analytics where enabled.

The specific technologies active on the Website may change as PathPair's Website and business operations evolve.

Third-party providers may maintain their own privacy notices and independent processing activities.

Where appropriate based on the processing involved, PathPair may use:

• Data Processing Addenda;

• Confidentiality obligations;

• Contractual security terms;

• Enterprise or business service configurations; and

• Other commercially reasonable safeguards.

PathPair periodically evaluates providers and may add, replace, or discontinue providers.

13. Data Security

PathPair implements administrative, technical, contractual, and organizational safeguards designed to protect information against unauthorized access, disclosure, alteration, loss, misuse, or destruction.

Safeguards may include:

• Secure cloud-based storage;

• Encryption in transit where supported;

• Encryption at rest where supported;

• Multi-factor authentication;

• Password-protected systems;

• Restricted or role-based access;

• Secure file sharing;

• Device-security practices;

• Data minimization;

• Provider review;

• Contractual confidentiality requirements;

• Approved-business or enterprise technology configurations;

• Limited access to Client Materials;

• Human review of externally delivered analytical work;

• Incident-response procedures; and

• Deletion, redaction, or anonymization practices.

Information submitted through Tally, Squarespace, HoneyBook, Google Workspace, Stripe, or another service provider is also subject to the technical systems and security controls operated by that provider.

No method of electronic transmission, storage, or processing can be guaranteed to be completely secure.

Accordingly, PathPair cannot guarantee absolute security.

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14. Security Incidents

If PathPair confirms a security incident involving Client Personal Data, PathPair will respond according to applicable law, contractual obligations, and any applicable Data Processing Addendum.

PathPair may take steps including:

• Investigating the incident;

• Containing affected access or systems;

• Preserving relevant information;

• Working with affected service providers;

• Assessing available information regarding scope and impact;

• Taking reasonable remediation steps; and

• Providing required notifications.

Client-specific notification timing and procedures may be governed by the applicable DPA or Professional Services Agreement.

15. Data Retention

PathPair retains identifiable information only for as long as reasonably necessary for the purposes for which it was collected or as otherwise permitted or required by:

• Applicable law;

• Contractual obligations;

• Professional recordkeeping requirements;

• Tax or accounting requirements;

• Insurance requirements;

• Security needs;

• Backup cycles;

• Dispute resolution;

• Protection of legal rights; or

• Legitimate business operations.

PathPair generally applies the following guidelines unless a different period is required or permitted:

Website Inquiries & Contact Requests

Up to two (2) years after the applicable interaction.

Pricing Estimator Answers

PathPair's current browser-based Pricing Estimator is not designed to transmit or retain the visitor's individual estimator selections.

Ordinary Website technical information associated with visiting the page may be retained according to the applicable Website-provider or analytics practices.

Candidate Experience Assessment

PathPair does not retain the individual assessment answers or results generated through normal use of the current browser-based Candidate Experience Assessment.

Preliminary Financial Exposure Assessment

Submissions and related communications may generally be retained for up to two (2) years after submission unless:

• The respondent becomes a Client;

• A longer period is reasonably necessary for an authorized business purpose;

• Retention is required by law;

• A dispute or legal obligation requires retention; or

• A different period applies under an executed agreement.

Client Communications

Generally up to seven (7) years following completion of the last applicable engagement with the Client, subject to applicable agreements and legal requirements.

Client Personal Data & Project Records

Client Personal Data used in Professional Services is retained only as long as reasonably necessary for:

• The applicable Professional Services;

• Contractual obligations;

• Business records;

• Professional recordkeeping;

• Backup cycles;

• Security;

• Dispute resolution;

• Legal obligations; or

• Another purpose permitted by the applicable agreements.

An applicable DPA or SOW may establish additional requirements.

Contracts, Invoices & Financial Records

Retained according to applicable legal, accounting, tax, insurance, and business-record requirements.

De-Identified Benchmark & Research Data

May be retained indefinitely where it no longer reasonably identifies an individual or Client and retention is permitted by applicable agreements and law.

Third-party providers may maintain information in routine backups or technical systems for limited additional periods according to their own deletion and backup processes.

Where legally permissible and contractually appropriate, PathPair may delete, return, anonymize, or de-identify information that is no longer reasonably required.

16. Your Privacy Rights

Depending on where you reside and the law that applies to PathPair's processing, you may have rights relating to your personal information.

These may include the right to:

• Confirm whether PathPair processes personal information about you;

• Access certain personal information;

• Correct inaccurate information;

• Request deletion, subject to applicable exceptions;

• Obtain a portable copy of certain information;

• Opt out of certain processing where applicable;

• Object to or restrict certain processing where provided by law;

• Withdraw consent where consent is the applicable basis for processing;

• Use an authorized agent where permitted;

• Appeal certain decisions regarding a privacy request; and

• Exercise applicable rights without unlawful discrimination.

To submit a privacy request, contact:

privacy@pathpair.co

PathPair may take reasonable steps to verify your identity before fulfilling a request.

If an authorized agent submits a request, PathPair may request information sufficient to verify the agent's authority.

16.1 Requests Involving Client-Controlled Information

If PathPair processes information about you solely on behalf of a Client, PathPair may direct your request to that Client because the Client is the organization responsible for determining how your information is processed.

Where required, PathPair will reasonably assist the Client in responding to verified requests.

17. Texas Privacy Rights

Texas residents may have rights under the Texas Data Privacy and Security Act ("TDPSA") where the law applies to PathPair and the applicable processing.

Applicable rights may include rights concerning:

• Access;

• Correction;

• Deletion;

• Portability;

• Certain opt-outs; and

• Appeal.

If PathPair declines to take action on an authenticated request and an appeal right applies, PathPair will provide information regarding the decision and how to appeal.

Appeals may be submitted to:

privacy@pathpair.co

PathPair will process applicable appeals within the timeframe required by law.

Where required, an individual whose appeal is denied may be provided information regarding how to contact the Texas Attorney General.

PathPair will not unlawfully discriminate against an individual for exercising an applicable privacy right.

18. California Privacy Rights

The California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), provides certain rights to California residents where the law applies to a business and the relevant processing.

To the extent applicable, California residents may have rights to:

• Know categories of personal information collected;

• Know specific pieces of personal information collected;

• Know categories of sources;

• Know applicable business or commercial purposes;

• Know categories of third parties to whom information is disclosed, sold, or shared;

• Request deletion, subject to exceptions;

• Request correction;

• Obtain certain portable information;

• Opt out of sale or sharing where applicable;

• Limit certain uses or disclosures of sensitive personal information where applicable;

• Use an authorized agent; and

• Exercise applicable rights without unlawful discrimination or retaliation.

18.1 Categories of California Personal Information

Depending on how you interact with PathPair, categories collected during the preceding twelve months may include:

Identifiers

Examples may include:

• Name;

• Business email address;

• Telephone number;

• IP address; and

• Similar identifiers.

Commercial Information

Examples may include:

• Records concerning requested services;

• Purchased Professional Services;

• Assessments;

• Invoices;

• Transactions; and

• Client relationship information.

Internet or Electronic Network Activity

Examples may include:

• Browser type;

• Device information;

• Pages visited;

• Referring website;

• Session information; and

• Website interactions.

Professional or Employment-Related Information

Examples may include:

• Employer or company;

• Job title;

• Organizational role;

• Talent Acquisition information;

• Recruiting-process information; and

• Other professional information provided during an interaction.

Inferences or Analytical Information

Information supplied to PathPair may be used to generate:

• Assessment outputs;

• Preliminary estimates;

• Engagement recommendations;

• Professional observations; or

• Other analytical information reasonably linkable to an individual.

Other Information Provided Through Professional Services

Where PathPair acts as a processor for a Client, Client Materials may contain personal information relating to Candidates, employees, recruiting personnel, hiring managers, or other stakeholders.

Such processing is governed by the applicable Client relationship and agreements.

18.2 Sources of Information

PathPair generally obtains information:

• Directly from individuals;

• From organizations engaging PathPair;

• From Client Materials;

• Automatically through Website technologies;

• From service providers;

• From publicly available sources where appropriate; and

• From other sources authorized or permitted for the applicable Professional Service.

18.3 Business Purposes

PathPair may use California personal information for purposes including:

• Providing requested assessments or services;

• Communicating with Users and Clients;

• Managing Professional Services;

• Operating the Website;

• Securing systems;

• Processing transactions;

• Maintaining business records;

• Conducting permitted analytics;

• Preventing misuse;

• Developing and improving services;

• Improving methodologies using appropriately de-identified information;

• Meeting contractual responsibilities; and

• Complying with legal obligations.

18.4 Categories of Recipients

Personal information may be disclosed for legitimate business purposes to categories including:

• Website providers;

• Form providers;

• Cloud and email providers;

• Client-management providers;

• Payment processors;

• Electronic-signature providers;

• Approved Artificial Intelligence or productivity providers;

• Analytics providers where enabled;

• Contractors and service providers;

• Professional advisers; and

• Other providers reasonably necessary for PathPair operations.

PathPair does not sell personal information for monetary consideration.

To submit a California privacy request, contact:

privacy@pathpair.co

Identify the privacy right you wish to exercise.

PathPair may take reasonable steps to verify identity and authority before fulfilling a request.

Nothing in this Section limits privacy rights available under other applicable laws.

19. Sale, Sharing & Targeted Advertising

PathPair does not sell personal information for monetary consideration.

PathPair does not use Client Confidential Information for targeted advertising.

PathPair does not knowingly use Candidate information received through Professional Services for unrelated behavioral advertising.

Depending on the technologies enabled on our Website, certain analytics, advertising, or cross-context tracking technologies could be regulated as "selling," "sharing," or targeted advertising under some privacy laws even where no money changes hands.

PathPair intends to configure and operate Website technologies in accordance with applicable legal requirements.

Where applicable law requires an opt-out mechanism, consent mechanism, or recognition of a legally valid preference signal, PathPair will provide or honor the required mechanism.

20. Cookies & Website Analytics

# 20. Cookies & Website Analytics

PathPair may use cookies, local storage, pixels, analytics technologies, or similar tools for purposes such as:

• Website functionality;

• Security;

• Remembering preferences;

• Measuring Website performance;

• Understanding Website usage; and

• Improving the visitor experience.

Where Google Analytics or another non-essential analytics technology is enabled, it may process information such as:

• Browser and device characteristics;

• Approximate geographic location;

• Pages visited;

• Session information;

• Referral information;

• Website interactions; and

• Technical identifiers.

Visitors may manage cookies using available Website cookie controls or browser settings.

Where applicable law requires consent before using a non-essential technology, PathPair will seek consent as required.

20.1 Candidate Experience Assessment

The Candidate Experience Assessment is intentionally designed so its assessment answers and generated result remain browser-side and are not submitted to PathPair through normal use.

Assessment-specific tracking is not intended to capture those answers or results.

20.2 Pricing Estimator

The current Pricing Estimator similarly processes estimator answers in the visitor's browser and is not designed to transmit individual estimator selections to PathPair.

Ordinary page-level Website technologies may still operate on the pricing page where enabled.

20.3 Preliminary Financial Exposure Assessment

The Preliminary Financial Exposure Assessment is different.

Information entered and submitted through the Tally form is transmitted through Tally and received by PathPair.

21. Global Privacy Control & Do Not Track

Some browsers and devices provide privacy preference mechanisms.

21.1 Global Privacy Control

Global Privacy Control ("GPC") is a browser-based opt-out preference signal that may be legally recognized in certain jurisdictions.

Where PathPair is legally required to treat a valid GPC signal as an applicable privacy opt-out request, PathPair will process the signal as required by applicable law and the capabilities of the technologies operating on the Website.

21.2 Do Not Track

Some browsers also provide a "Do Not Track" ("DNT") setting.

There is not a single universally adopted legal or technical standard governing DNT signals.

PathPair does not currently treat a DNT signal as a universal opt-out request unless applicable law requires otherwise.

DNT is separate from legally recognized opt-out preference signals such as GPC.

22. Marketing Communications

PathPair may communicate with prospective or existing Clients regarding requested services, assessments, meetings, inquiries, or active engagements.

Transactional or service-related communications are separate from general marketing communications.

Submitting:

• A Preliminary Financial Exposure Assessment;

• A contact form;

• A Pricing Estimator;

• A Bridge Assessment request; or

• Another service inquiry

does not, by itself, constitute consent to unrelated marketing communications where separate consent is required.

Where PathPair provides an email newsletter or other marketing subscription, individuals may unsubscribe using the mechanism included in the communication or by contacting PathPair.

23. International Processing

PathPair is headquartered in the United States.

PathPair and its service providers may process or store information in the United States or other jurisdictions.

For example, Tally is a European-based form provider, and other approved cloud, collaboration, Artificial Intelligence, or technology providers may operate systems in multiple jurisdictions.

If you interact with PathPair from outside the United States, information may be transferred to and processed in jurisdictions that may have privacy laws different from those where you reside.

Where applicable, PathPair relies on contractual, organizational, technical, or other legally recognized safeguards appropriate to the applicable processing.

Client-specific international-transfer requirements may also be addressed through a Data Processing Addendum or other executed agreement.

24. Children's Privacy

PathPair's Website, Professional Services, business assessments, and consulting offerings are intended primarily for adults, organizations, and business users.

They are not directed toward children under the age of 13.

PathPair does not knowingly collect personal information directly from children through Website services directed at children.

The Preliminary Financial Exposure Assessment, Pricing Estimator, Bridge Assessment, and Professional Services are intended for adult organizational or business users.

If PathPair becomes aware that information was collected directly from a child in violation of applicable law, PathPair will take reasonable steps to address or delete the information as required.

This provision does not mean that Client Materials can never contain information relating to younger applicants or Candidates.

If a Client lawfully provides information relating to a Candidate who is a minor as part of contracted Professional Services, PathPair handles that information according to the Client's instructions, applicable agreements, data-minimization requirements, and applicable law.

25. Business Transfers & Legal Disclosures

PathPair may disclose information where reasonably necessary to:

• Comply with law, regulation, legal process, or enforceable governmental request;

• Protect the rights, property, security, or safety of PathPair or others;

• Investigate fraud, misuse, security incidents, or violations;

• Enforce agreements;

• Establish, exercise, or defend legal claims; or

• Obtain professional legal, accounting, insurance, security, or other advice.

If PathPair participates in a merger, acquisition, reorganization, financing, sale of assets, or other business transfer, information may be transferred as part of that transaction subject to applicable law and appropriate confidentiality or privacy protections.

26. Changes to This Privacy Policy

PathPair may update this Privacy Policy from time to time to reflect changes in:

• Our Website;

• Professional Services;

• AI Implementation Enablement;

• Assessments;

• Pricing tools;

• Business operations;

• Technology;

• Artificial Intelligence practices;

• Service providers;

• Security practices;

• Privacy laws;

• Contractual requirements; or

• Internal governance.

When changes are made, PathPair will update the "Last Updated" date.

Where appropriate or legally required, PathPair may provide additional notice through:

• The Website;

• Email;

• A Client portal;

• An assessment interface;

• Contractual communications; or

• Another reasonable method.

Material changes will apply prospectively as required by applicable law.

27. Contact Information

If you have questions about this Privacy Policy or wish to exercise an applicable privacy right, contact:

PathPair LLC

Website: pathpair.co

Privacy Email: privacy@pathpair.co

General Support: help@pathpair.co

Business Hours:  

Monday–Friday  

9:00 AM–5:00 PM Central Time

28. Transparency Commitment

Transparency is one of PathPair's core commitments.

We believe privacy should be understandable—not hidden behind legal jargon or buried in fine print.

If something in this Privacy Policy is unclear, we encourage you to ask.

If you want to understand how your information is collected, used, protected, processed, stored, shared, or deleted, we will answer honestly, respectfully, and in plain language whenever reasonably possible.

We believe technology should enhance human capability without weakening human responsibility.

We believe Candidates deserve dignity even when their information appears only indirectly in a hiring system.

We believe Clients should know what happens to the information they trust us with.

And we believe trust is earned through what an organization consistently does—not simply what its policies claim.

That philosophy guides how we design hiring experiences and how we operate our own business.

Humans helping humans.

Thank you for placing your trust in PathPair.

We intend to earn it.

Bridging the Gap Between Talent Teams and Trust.

Helping organizations design hiring experiences worthy of the people moving through them.

© 2026 PathPair LLC. PathPair® is a registered trademark. All Rights Reserved.