Privacy Policy

Last updated: May 28, 2026

1. Who we are

Pathways PR ("Pathways," "we," "us") is a public relations and stakeholder communications practice operating as a division of OPEN Interactive. We work with data center developers, hyperscalers, infrastructure investors, utilities, and the communities that host digital infrastructure. This policy explains what information we collect through pathways.agency and through our engagements, how we use it, and the choices you have.

2. Scope

This policy covers information collected on our website, through contact and inquiry forms, during audits and retainer engagements, and through email or other direct communications with our team. It does not cover third-party sites we link to, or client-owned properties where Pathways provides services under a separate agreement.

3. Information we collect

Information you provide

• Contact details: name, company, role, email, phone, and project location when you submit an inquiry, request an audit, or engage us.
• Engagement context: site addresses, permitting status, interconnection details, community sentiment notes, stakeholder lists, messaging drafts, and other materials you share so we can deliver our Power-Plus-Permission, ICP, Social License, Audit, and Demand Creation services.
• Correspondence: emails, call notes, and documents exchanged during an engagement.

Information collected automatically

• Usage data: pages viewed, referring URLs, approximate location derived from IP, device and browser type, and timestamps.
• Cookies and similar technologies: strictly necessary cookies for site functionality and, where enabled, privacy-respecting analytics to understand aggregate traffic.

4. How we use information

• Respond to inquiries and scope potential engagements.
• Deliver contracted services, including ICP communications planning, permitting and social-license strategy, audits, and demand-creation campaigns for data center sites.
• Prepare deliverables such as stakeholder maps, messaging frameworks, media plans, and briefing materials.
• Send service updates, invoices, and engagement communications.
• Improve our website, content, and service offerings, and protect against fraud or misuse.
• Comply with legal, regulatory, and contractual obligations.

5. Confidentiality of sensitive engagement information

Data center projects frequently involve non-public site, power, permitting, and community-sentiment information. We treat all client-shared engagement information as confidential. Access is limited to Pathways personnel and approved subcontractors who need it to deliver the engagement, bound by confidentiality obligations. Where a master services agreement or NDA is in place, its confidentiality terms control over this section in the event of a conflict.

6. Legal bases (EEA/UK)

Where GDPR or UK GDPR applies, we rely on: performance of a contract (delivering services you request), legitimate interests (operating and improving our business, securing our site, marketing to professional contacts), consent (where required, e.g., certain cookies or marketing emails), and legal obligation.

7. Sharing of information

We do not sell personal information. We share information only with:

• Service providers that host our site, send email, manage CRM and analytics, and support our operations, under contracts that restrict their use of the information.
• Client teams and approved partners when necessary to deliver an engagement (e.g., a developer's legal, regulatory, or government-affairs counsel).
• Authorities when required by law, subpoena, or to protect rights, safety, or property.
• Successors in connection with a merger, acquisition, or sale of assets, subject to this policy.

8. Data retention

We keep information for as long as needed to provide services, meet contractual and legal obligations, resolve disputes, and enforce agreements. Engagement records are typically retained for the term of the engagement plus a reasonable archival period; inquiry submissions that do not lead to an engagement are deleted or anonymized on a routine cycle.

9. Security

We use administrative, technical, and physical safeguards designed to protect information, including access controls, encryption in transit, least-privilege practices, and vetted infrastructure providers. No system is perfectly secure; please do not send highly sensitive materials by unencrypted email — contact us to arrange a secure transfer.

10. International transfers

Our infrastructure providers may process information in the United States and other jurisdictions. Where required, we use appropriate transfer mechanisms such as Standard Contractual Clauses.

11. Your choices and rights

Depending on your jurisdiction (including the EEA/UK, California, and other U.S. states), you may have rights to access, correct, delete, port, or restrict processing of your personal information, to object to processing, and to withdraw consent. To exercise these rights, email privacy@pathways.agency. You may also unsubscribe from marketing emails using the link in any such message.

12. Cookies

We use a minimal set of cookies necessary to operate the site and, where enabled, aggregate analytics. You can control cookies through your browser settings. Disabling cookies may affect site functionality.

13. Children

Our services are directed to professionals. We do not knowingly collect personal information from children under 16.

14. Third-party links

Our site and deliverables may link to third-party resources. We are not responsible for the privacy practices of those parties; review their policies separately.

15. Changes to this policy

We may update this policy from time to time. Material changes will be reflected by updating the "Last updated" date above and, where appropriate, by additional notice.

16. Contact

Questions about this policy or our privacy practices? Email privacy@pathways.agency or write to Pathways PR, a division of OPEN Interactive.