Your privacy is important to us and we are committed to protecting your information. This Privacy Policy explains how information is collected and used by Pave LLC doing business as Pave ("Pave," "we," or "us"). This Privacy Policy applies to visitors of the Pave website at www.pavetheway.ai and the business customers ("Members") of Pave's services ("Service," and "Services").

Pave provides an AI-powered platform for independent education consultants and counseling organizations to manage the college admissions workflow. Members are professional counselors; the students and parents whose data Members upload are not direct users of the Service.

By using the Service, you agree to the collection and use of information in accordance with this policy. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy.

Note to International Users

Pave's jurisdiction is in the United Arab Emirates. If you are a Member accessing Pave from a region with laws or regulations governing personal data collection, use, and disclosure that differ from the laws of the UAE, please be advised that through your continued use of pavetheway.ai, which is governed by United Arab Emirates law, this Privacy Policy, and Pave's Terms and Conditions, you may be transferring your personal information across borders, and you consent to that transfer.

Information That Pave Collects

Information You Voluntarily Provide to Us

When you sign up for and use the Services, send us an email, consult with our customer service team, or communicate with us in any way, you are voluntarily giving us information that we collect. That information may include your name, email address, IP address, phone number, and credit card information (processed by Stripe - see Payments below). By giving us this information, you consent to this information being collected, used, disclosed, transferred, and stored by us as described in our Terms and Conditions and in this Privacy Policy.

Information You Enter on the Platform

When you add information on the platform, we have and may access the data in your account in order to provide you with customer support. This information includes student profiles, parent contact details, notes, essays, application materials, communications, and any other content you save within your account. We understand that the data you send to us is confidential and treat it as such. Access is restricted to certain Pave staff members to provide support and develop our Services.

Information You Import from External Services

If you choose to connect external services to Pave (such as Google Calendar), we collect information from those services as you have authorized. The specific data we collect from Google services is described in detail in the section "How We Use Google User Data" below.

Information We Collect Automatically

When you use our Services or browse our Website, we may collect information about your visit, your usage of the Services, and your web browsing. That information may include your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with our Website. We may collect this information as part of log files as well as through the use of cookies or other tracking technologies.

Information from Your Use of the Service

We may receive information about how and when you use the Services, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, the features you use, the time spent interacting, and actions you have taken within the application. This type of information helps us to improve our Services and provide you with customer support.

Cookies and Tracking

A cookie is a small amount of data, which often includes an anonymous unique identifier, that is sent to your browser from a website's computers and stored on your computer's hard drive.

We and our partners may use various technologies to collect and store information when you use our Services, including cookies and similar tracking technologies on our Website (such as pixels and web beacons), to store your preferences, keep you logged in, analyze trends, administer the system, track users' movements around the system, and gather demographic information about our user base as a whole. We may use third-party analytics tools such as Google Analytics. These third parties have their own privacy policies governing how they use such information.

You may elect to remove or block cookies within your web browser; however, this may affect your ability to use all features of the System and services of our third-party partners.

Web Beacons

We may use web beacons in emails we send to Members. When we send emails, we may track behavior such as who opened the emails and who clicked the links. This allows us to measure the performance of our email communications and to improve our features for specific segments of Members. To do this, we include single pixel gifs, also called web beacons, in emails we send. Web beacons allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details.

How We Use Google User Data

Our application offers optional integrations with Google services, including Google Sign-In and Google Calendar. When you choose to connect these services, we only request the minimum data needed to provide the functionality.

We request the following Google OAuth scopes:

• openid
• https://www.googleapis.com/auth/userinfo.email
• https://www.googleapis.com/auth/userinfo.profile
• https://www.googleapis.com/auth/calendar.events

When you choose to sign in with Google, we receive the email address, display name, and profile image contained in your Google ID token. We use this information only to create and manage your account within our platform, authenticate you, and display your profile information in the interface. We do not request or retain your Google password, and we do not use this profile data for advertising or sell it to third parties.

If you link your Google Calendar, we use the https://www.googleapis.com/auth/calendar.events scope so we can securely sync events between the app and your Google account. We store the access and refresh tokens provided by Google, along with their expiration times and granted scopes, to keep your connection active. During sync, we read event metadata (such as titles, descriptions, start times, end times, and event IDs) from the calendar you select, typically within a limited time window (for example, approximately 30 days in the past and up to 12 months in the future), so that these events appear in your planner alongside tasks you create.

We also create new Google Calendar events representing study-plan items you add in the app and update or delete those events when you modify or remove the corresponding items. We do not access other Google data, and we do not use your Google Calendar data for advertising or sell it to unaffiliated third parties.

You can revoke our access to Google data at any time from your Google account security settings (https://myaccount.google.com/permissions) or by contacting us at the email below. Once revoked, we will delete the stored Google tokens and will no longer access your Google data.

How Pave Uses Information

We may use and disclose Personal Information only for the following purposes:

• To provide and improve our Services. We use both your personally identifiable information and certain non-personally-identifiable information (such as anonymous end-user usage data, cookies, IP addresses, browser type, clickstream data, etc.) to deliver the Services, improve the quality and design of pavetheway.ai and the Services, and to create new features, promotions, functionality, and Services by storing, tracking, and analyzing our users' preferences and trends.
• To process your content through AI features. Your data, including essays and other input content, may be processed through third-party AI platforms such as OpenAI, Anthropic, or Google to deliver the AI-assisted features described in the Service. Their use of your information is governed by their own privacy policies. Pave does not use your User Submitted Content to train its general-purpose AI models.
• To promote use of our Services. If we collect your Personal Information when you visit our Website and do not sign up for our Services, we may send you an email inviting you to sign up. If you use any of our Services and we think you might benefit from another feature we offer, we may send you an email about that. You can stop receiving our promotional emails by using the unsubscribe link at the bottom of every email we send.
• To send you informational and promotional content in accordance with your marketing preferences. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email.
• To bill and collect money owed to us. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use Stripe for secure credit card transaction processing, and we send billing information to Stripe to process your subscription and credit card payments.
• To send you System Alert messages. For example, we may inform you of temporary or permanent changes to our Services, such as planned outages, new features, version updates, releases, abuse warnings, and changes to our Privacy Policy.
• To communicate with our Members about their account and provide customer support.
• To enforce compliance with our Terms and Conditions and applicable law. This may include developing tools and algorithms that help us prevent violations and detect misuse - including misuse of AI features in ways that violate academic integrity or institutional admissions guidelines.
• To protect the rights and safety of our Members and third parties, as well as our own.
• To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
• To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
• To prosecute and defend a court, arbitration, or similar legal proceeding.
• To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
• To provide suggestions to you. This includes using tracking technology to identify features within the Service you are not utilizing and educating you on the benefits of the underutilized feature.
• To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website.

Student and Parent Data Collected By Our Members

Pave is a counselor-only platform. As you use our Services, you import into our system Personal Information you have collected from students, parents, and other individuals. We have no direct relationship with the students, parents, or any person other than you (the Member), and for that reason, you are responsible for making sure you have the appropriate permission for you to collect and for us to process information about those individuals - including, where applicable, verifiable parental or legal guardian consent for any individual under the age of 13.

Consistent with the uses of Personal Information covered above, we may transfer Personal Information of you or your students to integrated third-party service providers (such as the AI platforms described above) when you choose to use features that depend on those providers. All service providers we work with are subject to terms that protect Personal Information and restrict its use consistent with this policy.

If you are a parent or student and no longer want your data to be processed by Pave, please contact the Member (counselor) who uploaded your information directly to update or delete your data. You may also contact us at the email below and we will work with the Member to address your request.

We will retain Personal Information we process on behalf of our Members for as long as needed to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.

Information Sharing and Third Parties

We do not sell or share your personal information with third parties for their marketing purposes.

We may disclose Personal Information to the following types of third parties for the purposes described in this policy:

• Service Providers. We share information with third-party service providers who help us provide and support our Services. Examples include: Stripe (payment processing), Google (authentication and calendar sync), OpenAI, Anthropic, and Google (AI processing of your content for in-product features), and Vercel (hosting and content delivery). The Personal Information shared with our third-party service providers is limited to what is required to deliver their service. These third parties are subject to terms that require them to use your Personal Information only for the provision of services to us and in a manner consistent with this policy.

Pave does not partner with third-party advertising networks or exchanges, and does not share your Personal Information for the purpose of serving you targeted advertising on other sites.

• Legal Disclosure. We may disclose your personal information if required to do so by law, subpoena, or if we believe such action is necessary to comply with legal obligations, protect our rights, or ensure the security and integrity of our Service.

Public Information and Third-Party Websites

• Social media platforms. We may maintain presences on social media platforms. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
• Links to third-party websites. Our Website includes links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Payments

When you purchase a subscription or service, payments are processed via Stripe. We do not store or have access to your full payment card information. Stripe's use of personal data is governed by their Privacy Policy.

Security

Notice of Breach of Security

If a security breach causes an unauthorized intrusion into our system that materially affects you or the students and parents whose data you have entered, Pave will notify you within 72 hours of becoming aware of the breach and will later report the action we took in response.

Safeguarding Your Information

We take reasonable and appropriate measures to protect Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. However, no method of transmission over the internet or electronic storage is 100% secure.

Pave accounts require a username and password to log in. You must keep your username and password secure and never disclose them to a third party. Because the information in your account is sensitive, account passwords are stored using industry-standard hashing, which means we cannot see your passwords. We cannot resend forgotten passwords; we can only reset them.

Our credit card processing vendor (Stripe) is PCI-DSS compliant and uses security measures to protect your information both during the transaction and after it is complete. We follow GDPR principles and offer a Data Processing Agreement.

Data Retention

As a system of record for its Members, Pave retains data at the sole discretion of Members and for as long as they have active subscriptions with Pave. We retain your personal information only for as long as necessary to provide our services and fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law.

After termination of a subscription, Pave will retain Member data for 30 days after cancellation for the convenience of Members in the event they decide to resume services with Pave. At the end of the data retention period, we securely delete and destroy personal information from Members. Members may request the immediate deletion of data by contacting Pave at the email below.

User Choices

Access, Correct, Amend, or Delete

We will give an individual access to any Personal Information we hold about them within 30 days of any request for that information. Individuals may request to access, correct, amend, or delete information we hold about them by contacting Pave at rahul@pavetheway.ai. Unless prohibited by law, we will remove any Personal Information about an individual - whether you, a parent, student, or other contact - from our servers at your or their request.

Revoking Google Access

As described in the "How We Use Google User Data" section above, you can revoke Pave's access to your Google data at any time from your Google account security settings (https://myaccount.google.com/permissions) or by contacting us. Once revoked, we will delete the stored Google tokens and will no longer access your Google data.

Children's Privacy

Pave's Services are not intended for children under the age of 13, and Pave does not knowingly collect personal information directly from children under the age of 13. Pave is a counselor-only platform - students do not create their own accounts.

If a Member uploads information about a student who is between the ages of 13 and 17, the Member is responsible for ensuring that appropriate parental or legal guardian consent has been obtained, in accordance with applicable child privacy laws (including but not limited to COPPA in the United States, GDPR-K in the EU, and equivalent UAE and international regulations).

If Pave learns that it has received personal information from a child under the age of 13 without verified parental consent, Pave will take appropriate action to delete that information.

Updates and Changes to Privacy Policy

Please note that we reserve the right, at any time, to add to, change, update, or modify this Privacy Policy. We will notify you of any changes by updating this page and revising the "Effective Date" at the top. If, in our reasonable discretion, the changes are material, we will post a notice on our Website or send you an email. Information collected will be subject to the Privacy Policy in place at the time of collection.

Contact

If you have general questions about our Privacy Policy and practices, or questions about your Personal Data, you may contact us at rahul@pavetheway.ai.