This policy explains what data we collect when you use the Pathway Apex assessment, how we use it, and your rights. We do not sell your data. We do not share it with advertisers.
The controller of your personal data is:
References to "we", "us", or "our" in this policy refer to Pathway Apex. If you wish to exercise any of the rights set out in section 8, or to raise a concern about how we handle your data, contact us using the details above.
When you complete the assessment, we collect:
If you enrol, we additionally process the laboratory results you choose to share with us, and the check-in data you submit during the programme.
We do not collect your email address unless you provide it voluntarily. We do not collect payment information through this site.
We do not sell your data, and we do not share it with advertisers.
Some of the information you provide — sleep, stress, waist circumference, medication status, and any laboratory results you share — is health data, which is special-category personal data under the GDPR.
We process it on the basis of your explicit consent under Article 9(2)(a) GDPR. That consent is given by ticking the dedicated consent box before you submit the assessment — it is never implied, bundled with our terms, or pre-ticked. We record the time your consent was given and the version of this notice you were shown.
You may withdraw your consent at any time by emailing us, without affecting the lawfulness of processing already carried out before withdrawal. We treat this information with particular care and do not share it with third parties other than the processors listed below.
This assessment is not a medical tool and we are not a healthcare provider. Your data is processed for lifestyle coaching and education purposes only.
Your assessment responses are transmitted over HTTPS and processed through our automation platform. Access is limited to Amir Vakili and any direct coaching staff.
Your generated report is delivered via a unique URL which contains an encoded version of your assessment data. We recommend you do not share your report URL if you wish that data to remain private.
This website uses the Meta (Facebook) pixel. It is a tracking technology that sets cookies and reports events — such as page visits and completion of the assessment — back to Meta.
We use it for two purposes: to measure the performance of our advertising, and to show advertisements to people who have previously visited this site. It does not transmit your assessment answers or any health information to Meta.
Where required, we ask for your consent before non-essential cookies and tracking technologies are set, and you may decline. You can also control this through your browser settings and through Meta's own advertising preferences.
Your data is processed through the following services, each under its own privacy policy and data-processing terms:
We do not share your data with any other third parties. Your laboratory is engaged by you, not by us.
Some of these providers are based outside the European Economic Area, including in the United States. Where your data is transferred outside the EEA, that transfer is protected by appropriate safeguards — such as the European Commission's Standard Contractual Clauses or a recognised adequacy decision — under each provider's own data-processing terms, so that your data continues to receive an equivalent level of protection.
Under the GDPR you have the right to:
To exercise any of these rights, email office@pathwayapex.com. We will respond within 30 days.
We retain assessment data for as long as is necessary for the purposes described above, and delete it on request. Client records are retained for the duration of the programme and for such period afterwards as is required to meet our legal obligations.
We may update this policy from time to time. The date at the top of this page reflects when it was last updated.
For any questions about this privacy policy or your data, email office@pathwayapex.com.