Privacy Policy

APC Pathway Pro is operated by Global Healing Project Ltd, a company registered in England and Wales under company number 15868339. We are the data controller for the personal data described in this notice, which means we decide how and why it is processed.

We are not required to appoint a Data Protection Officer. Data protection is the responsibility of The Directors, and you can raise any data protection question with us directly at hello@apcpathwaypro.app.

This notice explains what personal data we collect when you visit our website or use APC Pathway Pro, why we collect it, who we share it with, how long we keep it, and the rights you have under the UK GDPR and the Data Protection Act 2018.

Our use of cookies and similar technologies is described separately in our Cookie Policy.

Most of the data we hold comes directly from you. Some is generated automatically when you use the service.

Account and identity data

Your name, email address, password (stored only as a salted hash), and any profile details or photograph you choose to add. If you sign in using a third-party provider, we receive your name and email address from that provider.

Your submission content

The material you upload or enter for revision purposes: case study documents, experience records, CPD logs, project descriptions and similar files. These documents often contain personal data about you — your employment history, your projects and your professional development — and may contain information about other people, such as colleagues, clients or counsellors.

Your answers and practice activity

Written answers you type, audio recordings of spoken answers and the transcripts made from them, the questions generated for you, the scores and feedback produced, and your progress, streaks and readiness indicators.

Billing data

Your subscription plan, billing period, transaction history, invoices and the last four digits and expiry date of your card. We never receive or store your full card number or security code — those go directly to our payment processor.

Technical and usage data

Your IP address, browser type and version, device and operating system, time zone and language settings, the pages and features you use, and the dates and times of your visits. We also keep security and error logs.

Correspondence

Messages you send us through the contact form or by email, and our replies, including any complaint or support history.

We must have a lawful basis under the UK GDPR for everything we do with your personal data. The table below sets out each purpose and the basis we rely on.

Where we rely on legitimate interests, we have considered whether our interest is fair to you and whether it overrides your rights and freedoms. You may object to this processing at any time — see section 9.

To generate questions and mark your answers, we send the relevant parts of your submission and your answer to large language models operated by the AI providers listed in section 6. This processing happens on our instructions and only for the purpose of delivering the service to you.

Scores, readiness indicators and feedback are generated automatically. They are study aids and are not decisions that produce legal effects for you or otherwise significantly affect you, so the restrictions in Article 22 of the UK GDPR on solely automated decision-making do not apply. Even so, if you disagree with a score or a piece of feedback you can ask us to review it by emailing hello@apcpathwaypro.app, and a person will look at it.

We do not sell your personal data and we do not share it with other users. We do use carefully selected service providers who process data on our behalf as processors, under written contracts that require them to keep it secure and to use it only for the purposes we specify.

We may also disclose your data:

• to our professional advisers, such as accountants and lawyers, where they need it to advise us;
• to a buyer or successor if we sell or reorganise our business, in which case we will tell you beforehand;
• to regulators, courts, law enforcement or other authorities where we are legally required to do so, or to protect our rights, property or safety.

Some of the providers listed above are based outside the United Kingdom, principally in the United States. Whenever we transfer personal data outside the UK, we make sure a similar degree of protection is given to it by relying on one of the following safeguards:

• transferring to a country the UK Government has decided provides adequate protection — for example the European Economic Area;
• the UK International Data Transfer Agreement, or the UK Addendum to the European Commission's standard contractual clauses, together with a transfer risk assessment;
• for US providers certified under it, the UK Extension to the EU–US Data Privacy Framework, commonly called the UK–US Data Bridge.

You may ask us for further information about the safeguards we use by emailing hello@apcpathwaypro.app.

We do not ask you for special category data — information about health, racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership, genetic or biometric data, sex life or sexual orientation — and we have no need for it.

We keep personal data only for as long as we need it for the purposes set out in this notice, and to meet our legal and accounting obligations.

We may keep anonymised or aggregated information, which can no longer identify you, for longer in order to understand how the service is used.

Under UK data protection law you have the right to:

• be informed about how we use your data — which is the purpose of this notice;
• request access to a copy of the personal data we hold about you;
• request correction of data that is inaccurate or incomplete;
• request erasure of your data where there is no good reason for us to keep it;
• object to processing based on our legitimate interests;
• request restriction of processing while a concern is investigated;
• request transfer of your data to you or another provider in a structured, machine-readable format;
• withdraw consent at any time where we rely on consent, such as for marketing emails.

You can delete your submissions and close your account yourself at any time from your account settings. For anything else, email hello@apcpathwaypro.app.

Exercising your rights is free. We will respond within one month, though we may extend this by a further two months for complex requests, in which case we will tell you. We may ask you for information to confirm your identity before we act.

We use appropriate technical and organisational measures to protect your data, including encryption in transit and at rest, database row-level security so that your content is accessible only to your account, hashed passwords, optional multi-factor authentication, access controls limiting who can reach production systems, and regular dependency and security updates.

No system can be completely secure. If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will report it to the Information Commissioner's Office within 72 hours and, where the risk is high, tell you without undue delay.

We will only send you marketing emails where you have asked us to, or where you have bought from us and have not objected. Every marketing email contains an unsubscribe link, and you can opt out at any time from your account settings or by emailing hello@apcpathwaypro.app.

Opting out of marketing does not stop service messages such as password resets, receipts and notices about changes to the service, which we need to send you as part of our contract.

APC Pathway Pro is intended for professionals aged 18 or over and is not directed at children. We do not knowingly collect data about anyone under 18. If you believe a child has given us their data, please contact us and we will delete it.

We may update this notice to reflect changes to the service, our providers or the law. The current version is always shown on this page with the date it was last updated. If a change is significant, we will tell you by email.

If you are unhappy with how we have handled your personal data, please tell us first at hello@apcpathwaypro.app so that we have the chance to put it right.

You also have the right to complain to the Information Commissioner's Office, the UK supervisory authority for data protection: