pathhog privacy policy v1.0

This Privacy Policy explains how Pathhog Pte. Ltd. ("Pathhog", "we", "us") collects, uses, discloses and safeguards information about creators and viewers (together, "users") of our website/app and related services, including the creator-facing Pathboard features. If you are a creator, this Notice works together with the Pathhog Creator Terms. If you are a viewer, it works together with the Pathhog User Terms.

1. WHO WE ARE & SCOPE

Pathhog helps creators present public Instagram content as a navigable Pathboard and may monetise some links via affiliate programs. This Notice applies to personal data we process when you use our services, contact us, or interact with our websites/apps.

2. INFORMATION WE COLLECT

We collect information in these categories:

2.1 Information you provide

• Account/profile information (name, email, username/handle, optional photo)
• Creator onboarding and payout information (business name, tax info where required, payout/bank details)
• Communications (support requests, feedback)

2.2 Information collected automatically

• Device and usage data (IP address, approximate location, browser/app type and version, OS, user agent, language, timestamps)
• Event and interaction data (page views, outbound link clicks, Pathboard interactions)
• Cookies and similar technologies that support analytics, security, session management and affiliate attribution

2.3 Information from public sources (creators only)

• Publicly available Instagram content you control: profile name/handle, bio, profile links, public posts/reels/videos, captions, timestamps, public like/comment counts, public location tags and hashtags, and promo codes in your bio

2.4 Information from partners

• Affiliate networks/partners may provide reporting necessary to reconcile commissions (e.g., conversions, clawbacks, fraud flags)
• Analytics, measurement, anti-fraud and payout providers may supply signals or status to operate the service

We do not collect private or login-protected Instagram content and we do not circumvent Instagram technical controls.

3. HOW WE USE INFORMATION

• Provide, operate and secure the services (including Pathboards)
• Build your Pathboard by transforming public Instagram text into structured entries using automated systems including large-language models (e.g., extracting place names, categories and short tips; producing a crystallised bio; detecting promo codes)
• Verify creator account ownership (code-in-bio validation)
• Detect and prevent fraud and invalid activity
• Measure performance, run analytics, and improve features
• Provide creator reporting, calculate revenue share, and make payouts
• Communicate with you (service messages, support, product updates; with your consent, marketing)
• Comply with law and enforce our terms

We do not sell your raw creator data.

4. LEGAL BASES FOR PROCESSING (WHERE APPLICABLE)

• Contract (to provide the services you request, including creator payments)
• Consent (e.g., marketing communications; creator validation; where required)
• Legitimate interests (service security, fraud prevention, analytics and feature improvement, aggregated reporting) balanced against your rights
• Legal obligations (tax, accounting, compliance)

5. HOW WE SHARE INFORMATION

We do not sell or rent personal data. We share information with:

• Service providers acting on our behalf (hosting/cloud, analytics/measurement, LLM processing, email/support, payout/payment, anti-fraud)
• Affiliate partners/networks to reconcile commissions and combat fraud
• Corporate transactions (merger, acquisition, financing, sale of assets) subject to confidentiality
• Legal and safety (to comply with law, respond to lawful requests, or protect rights, safety and property)

We require service providers to process data only under our instructions and with appropriate safeguards.

6. RETENTION

• Creator Instagram public content: retained while your Pathboard is active and up to 30 days after revocation/closure solely to complete reporting/payouts and comply with legal/accounting obligations, then deleted or de-identified. Backups are isolated from live systems and used only for those purposes.
• Personal data you provide (e.g., payout details, email): deleted or de-identified within 30 days after revocation/closure, except where we must retain it for taxes, legal compliance, fraud prevention or claims handling.
• Consent and verification logs: retained as long as reasonably necessary for legal, compliance and audit.
• Derived/aggregated analytics that do not identify you may be retained to improve our services.

7. YOUR CHOICES AND RIGHTS

Depending on your location, you may have rights to:

• Access the personal data we hold about you
• Correct inaccurate or incomplete data
• Delete personal data (subject to legal/operational exceptions)
• Withdraw consent where processing relies on consent
• Object to or restrict certain processing, and data portability (EU/UK)
• Opt out of targeted advertising or sale/share of personal data (US state laws where applicable)

To exercise rights, contact hello@pathhog.com. We may request verification before fulfilling a request. You can manage marketing preferences via unsubscribe links and in-app settings.

8. INTERNATIONAL DATA TRANSFERS

We may process and store data in countries other than where you reside. Where required, we use appropriate safeguards (e.g., Standard Contractual Clauses, contractual protections) to protect your data when transferred internationally.

9. SECURITY

We implement reasonable technical and organisational measures to protect personal data (access controls, encryption in transit, network and application security, backups). No method of transmission or storage is 100% secure.

10. CHILDREN

The services are not directed to children under 13 (or minimum age in your country). We do not knowingly collect personal data from children. If you believe a child has provided personal data, contact us to delete it.

11. COOKIES AND SIMILAR TECHNOLOGIES

We use cookies, SDKs and similar technologies for essential functions, analytics/measurement, security and affiliate attribution (e.g., identifying unique clicks and reconciling commissions). You can control cookies via browser settings and, where required, through our consent tools. Disabling cookies may affect functionality. We do not respond to Do Not Track signals.

12. CHANGES TO THIS NOTICE

We may update this Notice. If changes are material, we will provide at least 30 days' notice in the service and/or by email where appropriate. Changes apply prospectively from the stated effective date. Your continued use after the effective date constitutes acceptance.

13. CONTACT US

Pathhog Pte. Ltd.
466A Clementi Ave 1, Singapore 121466
Email (general): hello@pathhog.com
Data Protection Officer (DPO): data@pathhog.com

14. REGION-SPECIFIC DISCLOSURES (SUMMARY)

EU/UK: Pathhog is the controller for personal data described here. Legal bases are listed in Section 4. Data subject rights in Section 7 apply. Transfers outside the EEA/UK rely on appropriate safeguards.

US States (e.g., CA, CO, CT, VA, UT): We do not sell personal data in the traditional sense. We may engage in processing that could be considered "sharing" or "targeted advertising" under state laws; you may have opt-out rights. Contact us at hello@pathhog.com.

Singapore: We process personal data in accordance with the PDPA. You may request access and correction as described in Section 7.