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Privacy Policy

Effective 6 September 2026 · Version 1.7

Applies to users of Path2Negotiate, with additional rights for users in the European Union, European Economic Area, United Kingdom, and other jurisdictions where applicable.

Privacy at a glance

This summary is for convenience only. The full Policy below is what governs.

This Privacy Policy (the "Policy") explains how Path2Negotiate ("Path2Negotiate", "we", "us", or "our") collects, uses, shares and protects personal data about you when you access or use the Path2Negotiate website and related online services (together, the "Service"). For the purposes of the EU General Data Protection Regulation (Regulation (EU) 2016/679, the "GDPR") and equivalent laws, Path2Negotiate is the controller of the personal data described in this Policy.

This Policy should be read together with our Terms of Use. Capitalized terms that are not defined here have the meaning given to them there. This Policy explains how we process personal data; it is not itself a consent mechanism. Where we rely on consent, we ask for it separately.

Contents

1. Introduction and scope

This Policy applies to personal data we process about visitors to our website, registered users and customers of the Service, wherever you access it. It does not apply to the practices of third parties we do not own or control, including payment networks and other websites linked from the Service. Those third parties have their own privacy policies, which we encourage you to review.

The operating entity is Gestoa, established in Spain. Path2Negotiate is a Gestoa product; the two are separate services and this Policy covers Path2Negotiate only. We process personal data under the GDPR and the Spanish Organic Law 3/2018 ("LOPDGDD"), under the UK GDPR and the Data Protection Act 2018 for users in the United Kingdom, and under applicable United States state privacy laws.

Path2Negotiate is a training product, not an assessment or HR tool.

2. Information we collect

2.1 Information you provide to us

2.2 Training Activity Data

Using the Service generates information we call "Training Activity Data":

No audio is ever stored. A spoken answer is streamed for transcription and the recording is discarded; we keep its duration and the resulting text. Training Activity Data reflects your use of practice exercises. It is not a professional evaluation.

2.3 The public demo

The card on our home page can be answered without an account. Two separate things happen when you answer it.

2.4 Information collected automatically

2.5 Information we receive from third parties

2.6 Special category and sensitive data

We do not intentionally collect special categories of personal data under the GDPR, such as health data, biometric data, political opinions, religious beliefs or trade-union membership.

One part of the Service needs particular care. A drill asks you to talk about a real workplace situation, so what you say may incidentally contain details about colleagues, salaries or conflicts. Please avoid naming people, and do not include information about others.

2.7 Our record of your cookie choice

When you accept, reject or save cookie preferences we keep one line recording the choice, whether it withdrew something previously granted, whether you answered the banner or reopened it from the footer, whether your browser sent Global Privacy Control, which version of the Cookies Policy you were shown, which round of the consent question you were answering, and the time. We are required to be able to demonstrate that consent was given and that a withdrawal was acted on, and that line is how we do it.

It carries no account id, cookie id, browser fingerprint or user agent. The consent-round marker is a fixed label, identical for every visitor. The only element relating to you is your IP address put through a one-way keyed hash, which cannot be reversed without a secret held separately on our servers, so the record cannot be joined to your account or to your demo answer. See the Cookies Policy §5.1.

3. How we use information

We use personal data for the following purposes:

We do not use your Training Activity Data or your drill text for advertising, and we do not build a marketing profile from it. There is no advertising on the Service at all.

3.1 Legal bases for processing (EU/EEA/UK)

Processing activityPersonal data involvedLegal basis
Create and manage your account, and sign you inEmail address, sign-in provider identifier, profile settingsPerformance of a contract — Art. 6(1)(b)
Serve cards and drills, score them, schedule reviews, show progressTraining Activity Data, profile preferencesPerformance of a contract — Art. 6(1)(b)
Generate the counterpart's reply and grade the drill against its rubricDrill response text and the drill briefPerformance of a contract — Art. 6(1)(b)
Process payments and grant the access you bought; keep proof of a salePayment reference and status from Stripe, entitlements, access code redeemedPerformance of a contract — Art. 6(1)(b); legal obligation — Art. 6(1)(c)
Security, abuse detection, service availability, per-user spend ceilings, and logging staff actions on an accountDevice and log data, IP address, cost records, admin action logLegitimate interests — Art. 6(1)(f)
Understand whether the product works, and which campaigns bring qualified usersTraining Activity Data in aggregate, purchase-intent records, campaign sourceLegitimate interests — Art. 6(1)(f)
Support and service communicationsContact details, support messages, account informationPerformance of a contract — Art. 6(1)(b); legitimate interests — Art. 6(1)(f)
Product analytics using non-essential cookies and similar technologiesCookie ids, device data, usage eventsConsent — Art. 6(1)(a) and applicable ePrivacy rules
Keep a record that you gave or withdrew cookie consentHashed IP address, the choice made, browser opt-out signal, policy version, timestampLegal obligation — Art. 6(1)(c), read with Art. 7(1)
Comply with legal obligations and defend legal claimsRelevant account, transaction, support and log dataLegal obligation — Art. 6(1)(c); legitimate interests — Art. 6(1)(f)

Where we rely on consent you may withdraw it at any time, without affecting processing carried out before you did.

3.2 When providing data is required

An email address is required to have an account at all, and payment details are required to buy access. Your role, company size and time zone are optional; the Service works without them, and they exist so that we can tell who the product is reaching and show you dates in your own zone.

4. Cookies and similar technologies

We use cookies, local storage and similar technologies to keep you signed in, remember your preferences, and — with your consent — measure how the public site is used. We group them into two categories:

There is no advertising category, because there is no advertising.

We ask for consent before setting any non-essential technology. Every optional signal is set to denied before the tag container is allowed to load, our banner offers refusing as plainly as accepting, uses no pre-ticked boxes, and lets you change your mind at any time from the footer of any page. If your browser sends a recognised opt-out signal such as Global Privacy Control, we honour it automatically and nothing optional runs at all, unless you tell us otherwise in the banner for this site.

TechnologyProviderPurposeCategoryDuration
Session / authentication cookieSupabase, on our behalfKeeps you signed in and secures your sessionStrictly necessaryUntil you sign out or it expires
Consent and theme preference (local storage)Path2NegotiateRemembers your cookie choice and light/dark settingStrictly necessaryUntil you clear site data
Product analytics cookiesAmplitudeIdentifies this browser and its session so a return visit is not counted as a new person; remembers the campaign you arrived fromAnalytics — consent requiredUp to 12 months
Tag containerGoogle Tag ManagerLoads the analytics tag according to your consentStrictly necessary to deliver the aboveNo cookie

Full detail, cookie by cookie, is in our Cookies Policy.

5. How we share information

We do not sell personal data, and we do not share your Training Activity Data or your drill text with advertisers for any purpose. We share personal data only as described below.

Service providers and processors — vendors that process data on our behalf, under our instructions, and under a data-processing agreement as required by GDPR Art. 28:

ProviderWhat it doesWhat it receives
SupabaseDatabase, authentication and sign-in emailAccount and Training Activity Data, held in the EU (eu-west-1, Ireland)
VercelHosting and server functionsRequest and technical data; functions run in Dublin (dub1)
AnthropicPlays the drill counterpart and grades against the rubricYour drill response text and the drill brief
DeepgramSpeech-to-text for spoken drill answersDrill audio, in transit only — converted to text and not retained
StripePayments and checkoutYour card details, entered on Stripe's own checkout page. We receive the result, never the card
AmplitudeProduct analyticsUsage and device data, only with your consent; EU ingestion endpoint
GoogleTag management only — no Google AnalyticsThe request that fetches the tag container: IP address, browser and page address

Beyond those providers, we disclose personal data only:

6. Analytics and automated processing

6.1 Analytics

We use one analytics tool, Amplitude, to understand which steps people complete and where they give up. It runs on the public pages and, once you are signed in, inside the product as well — only ever with your consent. Amplitude sends our data to its EU endpoint. It is loaded through Google Tag Manager, which is a tag loader and nothing more: it decides when Amplitude may run and collects no analytics of its own.

6.2 Automated processing and AI

A drill is scored automatically. A large language model plays the counterpart and grades your answer against a reviewed, per-drill rubric written in advance by us. Recognition cards involve no model — they are scored in our own database against an authored answer key.

Scoring produces training feedback and a per-tactic standing. It does not produce legal or similarly significant effects about you within the meaning of Article 22 GDPR, it is not shared with your employer, and it is not used in any decision about your employment, credit or eligibility. If you think a score is wrong, write to us and a person will look at it.

7. Data retention

We keep personal data for as long as necessary for the purposes described in this Policy, then delete or anonymise it.

Data categoryRetention
Drill audioNever stored. Transcribed in transit, then discarded.
Account and profile dataFor the life of your account. Deleted when you delete your account.
Training Activity Data — attempts, drill turns, verdicts, progress, streaksFor the life of your account, then deleted with it.
Entitlements and access-code redemptionsFor the life of your account.
Transaction and tax recordsFor the period required by applicable tax and accounting law, which in Spain is generally up to 6 years. These survive account deletion because the law requires it.
Purchase-intent recordsFor the life of your account, then retained in aggregate.
Support communicationsUp to 3 years after the last exchange, unless needed for a dispute or a legal claim.
Anonymous demo answersKept indefinitely as aggregate product data. They identify nobody, so there is nothing to delete.
Analytics dataPer Amplitude's retention settings — see the Cookies Policy.
Cookie-consent recordsUp to 3 years from the choice, which is the period we could be asked to evidence it for. They carry no account id, so they are not removed by deleting your account — there is nothing in them to connect to it.

Deleting your account removes the account row and everything keyed to it — every attempt, drill turn, verdict and progress record. We may retain data longer only where the law requires it, or to resolve a dispute or enforce our agreements.

8. Data security

We maintain technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse and alteration.

No method of transmission or storage is completely secure and we cannot guarantee absolute security. Tell us promptly at info@gestoa.com if you suspect unauthorised use of your account. Where the law requires it we will notify you and the relevant authority of a personal-data breach.

9. International data transfers

Our database, our server functions and our analytics data are all in the EU: Supabase in Ireland, Vercel functions in Dublin, Amplitude on its EU endpoint.

Some providers process personal data outside the EEA, including in the United States — Anthropic, Deepgram, Stripe and Google — and Amplitude, although it stores our data in the EU, is a US company whose staff may access it in support.

10. Your privacy rights — EU, EEA and UK

If you are in the European Union, the European Economic Area or the United Kingdom you have the following rights, subject to the conditions and exceptions in the GDPR and UK GDPR:

Write to info@gestoa.com and we will respond within one month of receiving your request, unless the GDPR permits an extension because of complexity or volume. We will not discriminate against you for exercising your rights.

Automated decision-making and profiling. We do not use your activity to make decisions producing legal or similarly significant effects within the meaning of Article 22 GDPR. See §6.2.

Right to complain. You may lodge a complaint with a supervisory authority — in Spain the Agencia Española de Protección de Datos (aepd.es), in the UK the Information Commissioner's Office (ico.org.uk), or the authority where you live or work. We would appreciate the chance to address your concerns first.

11. Additional privacy rights for certain US residents

This section applies only where Path2Negotiate is subject to the relevant US state privacy law. Depending on your state, you may have rights under laws such as the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), and comparable laws in states including Virginia, Colorado, Connecticut and Utah:

We do not sell personal data, we run no advertising, and we do not engage in targeted or cross-context behavioural advertising. Our use of analytics cookies could be treated as "sharing" under some state laws if you switch analytics on. You can opt out in the cookie banner from the footer of any page, or by enabling Global Privacy Control, which we honour for every visitor automatically and without you having to answer anything, unless you switch analytics on for this site yourself.

Categories collected and disclosed. In the preceding twelve months we collected the categories described in §2 — identifiers, account and commercial information, internet and usage activity, approximate location, and Training Activity Data — and disclosed them to the types of recipients in §5 for the purposes in §3. To exercise a right, write to info@gestoa.com. We verify requests using the information associated with your account and respond within the time the law allows.

12. Children's privacy

The Service is intended only for adults who are at least 18 years old. It is not directed to children and we do not knowingly collect personal data from them. If you are a parent or guardian and believe a child has given us personal data, write to info@gestoa.com and we will delete it. We do not knowingly sell or share the personal data of minors.

13. Third-party links and services

The Service links to third-party websites and services we do not own or control, including Stripe's checkout page and the sign-in providers. This Policy does not apply to them and we are not responsible for their privacy practices. We encourage you to review the privacy policy of every third party you interact with.

14. Changes to this Policy

We may update this Policy from time to time. If we make material changes we will post the updated Policy here with a new effective date and, where required by law or where the change materially affects your rights, give additional notice by email or in the app. Changes take effect when posted, unless stated otherwise or unless a later date is required by law. Where the law requires consent for a new processing activity, we will ask for it before starting.

15. How to contact us

Questions, requests and complaints about this Policy or our handling of personal data: info@gestoa.com.