Data controller
The data controller responsible for the personal information described in
this policy is Hidden Pathways LLC, a limited liability company registered in
Ukraine, operating publicly under the HPaths brand. For the purposes of
applicable data protection laws, Hidden Pathways LLC determines the purposes
and means of processing any personal information received through this
website.
Privacy inquiries, access and erasure requests, and any other correspondence
related to this policy should be sent to hello@hpaths.com with a subject line
beginning “Privacy:” so that we can route the message promptly.
Information we receive
HPaths is primarily an informational website. We do not operate account
systems, payment processing, or persistent user tracking on this site. The
categories of information we may receive are as follows.
- Correspondence data. When you send an email to an
hpaths.com address, we receive your name (if provided), your email address,
any signature or organisation details you attach, and the content of your
message, together with any files you choose to include.
- Technical data. Our hosting and content delivery providers
automatically record standard request information when the website is
loaded, including IP address, user agent string, referring URL, and request
timing. This information is used to operate and secure the site.
- Preference data. If you change the colour theme on this
site, that preference is stored in your browser’s local storage under
the key
hpaths-theme. It is not sent to us, shared with anyone,
or associated with any identifier. You can clear it at any time through
your browser’s site-data controls. - Voluntary data. Any additional information you voluntarily
provide in correspondence, for example device models, screenshots, error
messages, or contextual details useful for reproducing a software issue.
We do not use analytics, tracking pixels, behavioural profiling, third-party
advertising cookies, or session replay tools on this website.
How we use the information
We use the information we receive only for the following specific purposes.
- To reply to and handle support requests, inquiries, and ongoing correspondence.
- To investigate and resolve technical issues in our software.
- To operate, secure, and maintain the website and its underlying infrastructure.
- To keep records of business communication where record-keeping is required or commercially reasonable.
- To comply with applicable legal obligations and to respond to lawful requests from competent authorities.
We do not use correspondence data for marketing without the sender’s
explicit consent, and we do not sell, rent, or otherwise commercially trade
personal information collected through this site.
Legal basis for processing
Where applicable data protection law requires us to identify a legal basis
for processing personal information, we rely on the following bases.
- Legitimate interests. Operating the website, responding to
inbound correspondence, maintaining the security and integrity of our
systems, and keeping reasonable records of business communications.
- Performance of a contract or pre-contractual steps. Where
your message relates to an agreement with us, a product we publish, or the
preparation of one.
- Legal obligation. Where we are required to process or
retain information in order to comply with a law that applies to Hidden
Pathways LLC.
- Consent. For any processing that does not fall within the
above bases — for example, if we ever add an opt-in mailing list
— and which you can withdraw at any time.
Sharing with third parties
Hidden Pathways LLC does not sell personal information. We share information
only in the following narrowly defined circumstances.
- Service providers. We use third-party providers to host
this website, deliver it over a content delivery network, and handle email.
These providers process only the information necessary to deliver their
service and are bound by their own privacy and security commitments.
- Legal and regulatory requirements. Where we are required
to disclose information to comply with a law, court order, or lawful
request from a competent authority.
- Protection of rights. Where disclosure is reasonably
necessary to investigate fraud, prevent abuse of the website or our
software, protect property, or defend legal claims.
- Business transfers. In the unlikely event of a merger,
acquisition, reorganisation, or sale of assets, personal information may be
transferred as part of the transaction, subject to continued protection
under this policy or an equivalent successor policy.
Retention
We retain personal information only for as long as we have a specific,
documented reason to keep it. In practice this means correspondence is kept
for as long as it remains useful for ongoing support or business
record-keeping, and is then archived or deleted in line with reasonable
retention practices.
Technical logs generated by our hosting and delivery providers are kept for
short operational periods in line with those providers’ standard
retention policies, unless we have a specific reason to retain them longer
(for example, to investigate a security incident).
Security
We take reasonable administrative, technical, and organisational measures to
protect personal information from unauthorised access, disclosure, alteration,
and destruction. These measures include the use of reputable hosting
providers, transport encryption, access controls, and the principle of
collecting no more information than we need.
No transmission of information over the internet can be guaranteed to be
fully secure. If you believe your interaction with us is no longer secure
— for example, if you suspect that a message from “HPaths”
did not actually come from us — please contact us at hello@hpaths.com and we will
investigate.
International transfers
Hidden Pathways LLC is located in Ukraine, and the service providers we use
to host and deliver this site operate globally distributed infrastructure.
As a result, information received through this website may be processed in
countries outside your own jurisdiction. Where applicable law requires
safeguards for such transfers, we rely on the measures provided by our
service providers, including contractual commitments and recognised transfer
frameworks.
Your rights
Depending on where you are located, you may have some or all of the
following rights in relation to the personal information we hold about you.
- The right to request access to the personal information we hold about you.
- The right to request correction of inaccurate or incomplete information.
- The right to request deletion of information we no longer need a legal basis to keep.
- The right to object to processing based on our legitimate interests.
- The right to request restriction of processing in specific circumstances.
- The right to receive a copy of your information in a portable format.
- The right to withdraw consent, where processing is based on consent.
- The right to lodge a complaint with a competent data protection authority.
To exercise any of these rights, write to hello@hpaths.com. We will respond
within a reasonable time, and in any case within any specific timeframe
required by the law that applies to your request.
Children’s privacy
The HPaths website is not directed to children, and we do not knowingly
collect personal information from children through this site. If you believe
a child has sent us information, please contact us so that we can delete it.
Changes to this policy
We may update this policy from time to time as the website, our products, or
our legal obligations change. The version currently in effect is the one
shown on this page, with the effective date noted at the top.
Substantive changes will be reflected in an updated effective date and,
where practical, in a short summary at the top of the page describing what
has changed and why.
How to contact us
For any questions, concerns, or formal requests related to this policy,
write to hello@hpaths.com with a
subject line beginning “Privacy:”. Where the law that applies to
your request specifies a response window, we will honour it. Otherwise, we
will aim to reply within a reasonable time.
You may also write to Hidden Pathways LLC at the registered business address
recorded in the official Ukrainian company register under our legal name.