Who is responsible for data

Pathwise is operated by Bahrom Kalonov, an individual based in Tajikistan.

For data, support and purchase enquiries: billing@pathwise.me.

For purchases through Dodo Payments, some data is processed by Dodo Payments in its role as Merchant of Record and seller for the particular payment transaction.

Data we process

We may process:

• email address;
• chosen name;
• language and settings;
• account login, session and security information;
• access rights and invitations;
• activity within the service;
• purchase and access-status information.

When the corresponding features are used, we may store:

• journal entries;
• station responses;
• selected actions;
• progress;
• self-check-ins;
• observations and other data the user enters into Pathwise.

For service security and reliability, we may also process IP addresses, browser and device information, event timestamps and technical logs.

If password-based login features are used, passwords are stored only in protected, hashed form.

Purposes and legal bases

Data is used for:

• creating and operating accounts;
• login and access recovery;
• preserving users’ work and progress;
• providing paid or free access;
• handling support requests;
• preventing abuse, fraud and technical attacks;
• fulfilling legal and accounting obligations.

Depending on applicable law, the legal bases may include:

• performance of the user agreement;
• legitimate interests in service security, stability and improvement;
• compliance with legal requirements;
• user consent where required.

We do not sell users’ personal entries or use them for advertising profiling.

Personal entries and AI features

Pathwise may offer personal reflection features and, in the future, separate features using AI.

If an AI feature becomes available, this will be visible in the interface. Personal content is shared with an AI provider only to the extent necessary for the corresponding feature and in accordance with settings and applicable requirements.

Providers of these technologies may include OpenAI or another technical provider.

AI responses, where such a feature is available, are not diagnoses or medical, psychological, legal or other professional assessments.

Do not include payment secrets, full bank card details, access codes or other people’s data without a lawful basis in your personal entries.

Payments and providers

We use third-party infrastructure and email-delivery providers, including Timeweb and Resend.

For purchases through Dodo Payments, it receives the customer and payment data needed to:

• process payments;
• issue receipts;
• handle taxes;
• prevent fraud;
• process refunds;
• comply with legal requirements.

Pathwise receives information needed to provide access and support, such as:

• order identifiers;
• payment status;
• the selected product;
• information needed to contact the buyer.

Pathwise does not store full bank card numbers or CVC codes.

Personal entries, journals, station responses, self-check-ins and other user entries are not shared with Dodo Payments for payment processing.

Dodo Payments’ own privacy policy applies to its data processing.

Browser storage and international transfers

For login, language, settings and sessions, Pathwise may use cookies, local storage and other necessary browser-storage mechanisms.

This policy does not authorize advertising tracking.

Data may be processed outside the user’s country of residence, including in Tajikistan and the countries where our providers operate.

Where applicable law requires specific safeguards for international data transfers, those safeguards must be followed.

Retention and deletion

Data is kept for as long as necessary for:

• account operation;
• providing selected features;
• support;
• security;
• accounting and legal record-keeping.

Users may request data export or deletion through service settings or by contacting billing@pathwise.me.

Some records may be retained longer where needed for:

• compliance with the law;
• accounting;
• fraud prevention;
• dispute resolution;
• security.

Backups may temporarily contain deleted data until their scheduled replacement, but that data is not used as an active user profile.

User rights

Depending on applicable law, users may have the right to:

• access their data;
• correct it;
• delete it;
• obtain a copy or transfer of data;
• restrict processing;
• object to certain processing;
• withdraw consent for future processing.

Withdrawing consent does not make processing carried out before withdrawal unlawful.

We may ask users to confirm account ownership before fulfilling a request.

Users may also contact the competent data protection authority.

Absolute security of an internet service cannot be guaranteed, but Pathwise takes reasonable technical and organizational measures to protect data.

Children and policy changes

Independent Pathwise accounts are intended for adults.

Materials may be used together with a child under an adult’s responsibility, without unnecessarily entering identifying information about the child.

If you learn that a child has created an account without the necessary permission, please contact us.

We may communicate material policy changes through the service or by email.

New processing purposes for which the law requires consent will not rely solely on user silence.

Contact: billing@pathwise.me