Privacy Policy
Last updated: 18 August 2026
1. Introduction
MyPathway is an employee onboarding, engagement and retention platform operated by ATP Global Talent Ltd, a company registered in England and Wales under company number 14304707 ("MyPathway", "we", "us" or "our"). This Privacy Policy explains how we collect, use, store and otherwise process personal information in connection with the MyPathway website, platform and related services. MyPathway is primarily a business-to-business service. Businesses using MyPathway may provide personal information relating to their employees, workers, applicants or other personnel in order to use the platform's onboarding, documentation, engagement, reporting and related functionality. For questions about this Privacy Policy or how personal information is handled, contact:
support@mypathway.global2. Our role in relation to personal information
Our role under applicable data protection law depends on the circumstances in which personal information is processed.
Information relating to our customers and website users
Where we determine why and how personal information is processed — for example, information relating to customer accounts, business contacts, demo requests, billing administration and communications with us — ATP Global Talent Ltd generally acts as a data controller.
Employee and workforce information provided by customers
Where a business uses MyPathway to collect, upload, store, manage or otherwise process personal information relating to its employees or other personnel, the customer generally determines the purposes for which that information is processed. In these circumstances, the customer will generally act as the controller (or equivalent responsible business under applicable law) and MyPathway will generally process the information on the customer's behalf as a processor or service provider. Customers are responsible for ensuring that they have an appropriate legal basis and provide any notices required to collect and process employee information through MyPathway.
3. Information we may process
Depending on how MyPathway is used, personal information processed through our services may include:
Business and account information
• Name • Business name • Job title or role • Email address • Telephone number • Account credentials • Communications with MyPathway • Subscription and account information
Employee and workforce information
Information entered, uploaded or collected by customers through MyPathway may include: • Employee names • Email addresses • Telephone numbers • Residential addresses • Dates of birth • Employment information • Start dates • Employment status • Employee documentation • Agreements and acknowledgements • Electronic signatures • Onboarding information • Employee check-in responses • Engagement feedback • Offboarding feedback • Retention-related information • Other information required by the employer as part of its employee processes
Depending on a customer's configuration and use of the platform, documents processed through MyPathway may also contain information required for employment administration, tax, identity verification or payroll/direct-deposit purposes. This may include information contained in documents such as Form W-4, Form I-9 and direct-deposit authorisations. Customers control which information they request from employees through the platform.
4. How we obtain information
We may obtain personal information: • Directly from customers when they create or manage an account • From individuals who contact us or request a demonstration • When customers upload or enter employee information into MyPathway • When employees complete onboarding documents, agreements, check-ins or other activities through the platform • Through communications with our support team • Through payment and subscription administration • Automatically through essential technical processes necessary to operate and secure the website and platform
5. How we use personal information
Depending on our role and the circumstances, information may be used to: • Provide and operate MyPathway • Create and administer customer accounts • Facilitate employee onboarding • Facilitate completion and management of employment documentation • Facilitate electronic document completion and signing • Provide employee check-in functionality • Provide employee engagement and retention visibility • Provide reporting and administrative functionality • Facilitate employee offboarding feedback • Provide customer support • Communicate about accounts and services • Administer subscriptions and payments • Maintain and improve the reliability and functionality of the service • Protect the security and integrity of MyPathway • Prevent misuse, fraud or unauthorised access • Comply with legal and regulatory obligations • Establish, exercise or defend legal claims
Where we process employee information on behalf of a customer, we process that information in accordance with the customer's instructions and our contractual obligations, subject to applicable law.
6. Legal bases for processing
Where UK GDPR or other laws requiring a lawful basis apply and we act as a controller, we may rely on one or more of the following legal bases:
Contract
Where processing is necessary to enter into or perform a contract with a customer.
Legitimate interests
Where processing is necessary for our legitimate business interests or those of another party, provided those interests are not overridden by the rights and interests of the individual. These interests may include operating, securing, supporting and improving MyPathway and managing business relationships.
Legal obligation
Where processing is necessary to comply with a legal obligation.
Consent
Where consent is the appropriate lawful basis, individuals may withdraw their consent subject to applicable law. Where MyPathway processes employee information as a processor on behalf of a customer, responsibility for determining the appropriate lawful basis generally rests with that customer.
7. Payments
MyPathway uses Stripe to support payment processing and subscription administration. Payment information may therefore be processed by Stripe in accordance with Stripe's own privacy practices and terms. MyPathway does not need to receive or store full payment card details where those details are collected and processed directly by Stripe.
8. Service providers and subprocessors
We may use carefully selected third-party service providers to help operate, maintain, secure and support MyPathway. These providers may process personal information only where necessary to provide their services to us and subject to appropriate contractual and legal safeguards. Our technical infrastructure and subprocessor arrangements are periodically reviewed and may change as the platform develops. Where required, additional information regarding subprocessors used to process customer data may be made available to customers. We do not sell employee personal information.
9. International data transfers
MyPathway is operated by a company established in the United Kingdom and may provide services to customers and individuals in other countries, including the United States. As a result, personal information may be processed in countries other than the country in which the individual is located. Where applicable data protection law requires safeguards for international transfers of personal information, we will take appropriate measures designed to protect that information.
10. Data security
We take reasonable technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure. No online service or method of electronic storage can be guaranteed to be completely secure. Customers are also responsible for maintaining appropriate account security, controlling access to their MyPathway account and ensuring that login credentials are not shared with unauthorised persons. We do not make claims in this Privacy Policy regarding specific encryption standards, security certifications or technical infrastructure unless those claims have been independently confirmed.
11. Data retention
We retain personal information for as long as reasonably necessary for the purposes for which it was collected, including providing the service, fulfilling contractual obligations, complying with legal requirements and resolving disputes. Where we process employee information on behalf of a customer, retention may also depend on the customer's instructions, account status and applicable contractual requirements. Information may be retained for longer where required by law or where reasonably necessary to establish, exercise or defend legal claims.
12. Individual privacy rights
Depending on the individual's location and applicable law, individuals may have rights relating to their personal information, including rights to: • Request access to personal information • Request correction of inaccurate information • Request deletion of information • Request restriction of processing • Object to certain processing • Request portability of information • Withdraw consent where processing is based on consent • Lodge a complaint with an appropriate data protection authority
Where personal information has been provided to MyPathway by an individual's employer and we process that information on the employer's behalf, individuals should normally direct requests relating to that information to their employer. Where appropriate, we will assist customers in responding to valid privacy requests. Individuals may also contact us at:
support@mypathway.global13. UK data protection complaints
Individuals in the United Kingdom have the right to complain to the Information Commissioner's Office (ICO) if they believe their personal information has been processed in breach of applicable data protection law. We encourage individuals to contact us first so that we have an opportunity to address their concerns.
14. United States users
MyPathway may be used by businesses and employees located in the United States. Privacy rights and requirements may vary between US states. Where applicable US privacy laws provide individuals with additional rights concerning their personal information, MyPathway and its customers will handle applicable requests in accordance with their respective legal responsibilities. Where MyPathway processes employee information on behalf of a business customer, MyPathway generally acts as a service provider or processor rather than independently determining how that employee information should be used.
15. Cookies and website technologies
The MyPathway website may use cookies or similar technologies that are necessary for the website or platform to function correctly. At present, we do not intentionally use advertising cookies, Meta Pixel or Google Analytics on the public MyPathway website. If analytics, advertising or other non-essential tracking technologies are introduced in the future, this Privacy Policy and any required cookie controls will be updated accordingly. Third-party services accessed through the website, such as our demo-booking provider, may operate their own cookies and technologies in accordance with their own privacy policies.
16. Demo bookings and third-party services
Where a visitor chooses to book a MyPathway demonstration through a third-party scheduling service such as Calendly, information submitted through that service may also be processed by that provider under its own privacy policy. We recommend reviewing the privacy information provided by third-party services before submitting personal information to them.
17. Children's privacy
MyPathway is a business platform and is not directed towards children. We do not knowingly offer the service directly to children as consumers. Customers are responsible for ensuring that their use of MyPathway complies with applicable employment, privacy and age-related laws.
18. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to MyPathway, our practices or applicable legal requirements. The updated version will be posted on this page and the "Last updated" date will be revised. Where appropriate, we may also notify customers of material changes.
19. Contact us
For privacy questions, requests or concerns relating to MyPathway, contact: ATP Global Talent Ltd Trading as MyPathway Company No. 14304707 Registered in England and Wales
support@mypathway.globalHave a question?
Contact support@mypathway.global