Privacy Policy

This Privacy Policy explains how PathwayPro collects, uses, stores and protects personal information across the app, website, product updates, support, and related communications.

Last updated: 14 June 2026

1. About this Privacy Policy

This Privacy Policy explains how PathwayPro collects, uses, stores and protects personal information when you:

  • download or use the PathwayPro mobile application;
  • visit the PathwayPro website;
  • subscribe to PathwayPro product updates or a mailing list;
  • contact us for support; or
  • otherwise communicate with us.

PathwayPro is an independent educational and revision product for candidates undertaking the RICS Assessment of Professional Competence.

PathwayPro is not affiliated with, endorsed by or approved by the Royal Institution of Chartered Surveyors.

2. Who we are

PathwayPro is operated by:

Bailey Ellis, trading as PathwayPro.

For the purposes of UK data protection law, the operator of PathwayPro is the controller of the personal information described in this Privacy Policy.

You can contact us using the following details:

Email: hello@pathwaypro.co.uk

If PathwayPro becomes operated by a limited company, this section should be updated to include the company’s full registered name, company number and registered office address.

3. Information collected through the PathwayPro app

3.1 No account is required

The current version of the PathwayPro app does not require you to create an account or provide your name, email address, telephone number or postal address.

We do not create an account for you automatically.

3.2 Quiz and progress information

The app may store information such as:

  • questions you have answered;
  • selected answers;
  • quiz scores;
  • competency progress;
  • questions saved for later review;
  • weak areas or incorrectly answered questions;
  • practice history;
  • app preferences; and
  • other settings necessary for the app to function.

This information is stored locally on your device.

PathwayPro does not currently transmit this information to its own servers, associate it with your identity or use it to create an online user profile.

Because this information is stored locally:

  • we cannot view your individual quiz results;
  • we cannot restore your progress if it is lost;
  • progress does not automatically transfer between devices;
  • deleting the app may permanently delete your locally stored progress; and
  • resetting or replacing your device may also result in the loss of locally stored information.

Depending on your Apple device and backup settings, locally stored app information may be included in a device backup managed by Apple. PathwayPro does not control or have access to your Apple or iCloud backups.

3.3 Information we do not collect through the app

The current version of the app does not intentionally collect:

  • precise or approximate location;
  • contacts or address book information;
  • photographs or videos;
  • microphone or camera recordings;
  • health or fitness information;
  • payment card information;
  • advertising identifiers;
  • browsing history outside the app;
  • biometric information; or
  • sensitive personal information.

The app does not display third-party advertising.

The app does not currently use third-party behavioural tracking, advertising SDKs or cross-app tracking.

The app does not currently use a third-party analytics or crash-reporting service.

If this changes in a future version, we will update this Privacy Policy and the App Store privacy information before or when the relevant change is introduced.

4. App Store purchases

The PathwayPro app is made available through Apple’s App Store.

When you download or purchase the app, Apple processes the transaction through your Apple Account. Apple may collect and process information including:

  • your Apple Account details;
  • purchase history;
  • payment information;
  • country or region;
  • device information; and
  • information required to complete and manage the transaction.

This information is processed by Apple under Apple’s own terms and privacy policies.

PathwayPro does not receive or store your full payment card details or Apple Account password.

Apple may provide PathwayPro with limited sales, financial, download, performance or diagnostic information through App Store Connect. This information may be aggregated or limited in a way that does not directly identify an individual user.

5. Information collected through our website

5.1 Information you provide

We may collect information that you voluntarily provide when you:

  • subscribe to product updates;
  • subscribe to product updates;
  • submit a contact form;
  • request support;
  • report a technical problem;
  • report an error in a question or answer;
  • provide feedback; or
  • make a business enquiry.

This information may include:

  • your name;
  • email address;
  • APC pathway;
  • job title or professional role;
  • employer, where voluntarily provided;
  • the content of your message;
  • screenshots or attachments you send us; and
  • any other information you choose to provide.

Please do not send us confidential client information, employer-sensitive information, special category personal data or personal data belonging to another person unless it is necessary and you have a lawful basis for doing so.

5.2 Technical website information

Our website hosting provider may automatically process limited technical information when you visit the website, including:

  • IP address;
  • browser type;
  • device type;
  • operating system;
  • requested pages;
  • date and time of access;
  • referring website;
  • error information; and
  • security and server logs.

This information is used to deliver the website, maintain security, diagnose faults and prevent misuse.

5.3 Cookies

The current PathwayPro website is intended to use only cookies or similar technologies that are necessary for the website to function.

We do not currently use advertising cookies or behavioural profiling cookies.

We do not currently use Google Analytics, Meta Pixel or similar non-essential tracking technologies.

If we introduce non-essential analytics, advertising or tracking technologies, we will:

  • update this Privacy Policy;
  • provide appropriate information about the relevant technology; and
  • request consent where required.

6. How we use personal information

We may use personal information for the following purposes:

Providing and maintaining the app and website

We use technical information where necessary to make the website and app available, investigate faults, maintain security and improve reliability.

Responding to support requests

We use your contact details and message information to:

  • respond to your enquiry;
  • investigate technical problems;
  • help resolve support requests;
  • respond to reports of inaccurate content; and
  • communicate with you about your request.

Managing product updates

Where you subscribe to product updates, we use your email address and any pathway information you provide to:

  • confirm your subscription;
  • provide relevant product updates; and
  • understand general interest in different APC pathways.

Sending marketing communications

We will only send promotional emails to individual users where we have the appropriate permission or another lawful basis to do so.

You can unsubscribe at any time by:

Withdrawing consent will not affect the lawfulness of processing that took place before consent was withdrawn.

Improving PathwayPro

We may use feedback, support trends, aggregated App Store information and reports of incorrect content to:

  • improve questions and explanations;
  • identify common technical problems;
  • prioritise future features;
  • improve accessibility and usability; and
  • understand general product performance.

We will not use your personal information to make automated decisions that have legal or similarly significant effects on you.

Meeting legal obligations

We may process information where reasonably necessary to:

  • comply with applicable law;
  • maintain appropriate business and tax records;
  • establish, exercise or defend legal claims;
  • respond to lawful requests from public authorities; or
  • protect our rights, users and systems.

7. Our lawful bases

Under UK data protection law, we must have a lawful basis for processing personal information.

Depending on the circumstances, we rely on the following bases:

Contract and steps taken at your request

We may process information where necessary to:

  • provide support relating to the app;
  • respond before entering into an agreement with you; or
  • perform obligations connected with your use of PathwayPro.

Consent

We rely on consent where you:

  • subscribe to promotional updates;
  • subscribe to marketing communications; or
  • consent to an optional use of information.

You may withdraw your consent at any time.

Legitimate interests

We may rely on our legitimate interests to:

  • operate and secure the website;
  • respond to general enquiries;
  • identify and resolve faults;
  • prevent fraud or misuse;
  • protect our intellectual property;
  • improve app content and usability; and
  • maintain appropriate business records.

When relying on legitimate interests, we consider whether the processing is necessary and whether your rights and interests override our interests.

Legal obligation

We may process information where required to comply with a legal or regulatory obligation.

8. How we share personal information

We do not sell personal information.

We do not share personal information with advertisers or data brokers.

We may share limited personal information with the following categories of recipient where necessary:

Apple

Apple manages App Store distribution, payments, downloads and related platform services under its own terms and privacy policies.

Website and infrastructure providers

Our website hosting, domain, security and technical service providers may process limited technical information to host and protect the website.

Email and mailing-list providers

If you contact us or join a mailing list, an email hosting or mailing-list provider may process your email address and communications on our behalf.

Professional advisers

We may share information with accountants, lawyers, insurers or other professional advisers where reasonably necessary.

Authorities and legal recipients

We may disclose information where:

  • required by law;
  • required by a court or regulator;
  • necessary to protect legal rights;
  • necessary to investigate suspected fraud or misuse; or
  • necessary to protect the safety of users or others.

Business transfers

If PathwayPro or substantially all of its assets are sold, transferred or reorganised, relevant personal information may be transferred to the new operator, subject to appropriate confidentiality and data protection arrangements.

Service providers acting on our behalf are expected to use personal information only for the agreed purpose and to protect it appropriately.

9. International transfers

Some service providers, including Apple and technology providers, may process information outside the United Kingdom.

Where UK personal information is transferred internationally, we will take reasonable steps to ensure an appropriate legal safeguard is used where required. Depending on the destination and provider, this may include:

  • a UK adequacy regulation;
  • the UK International Data Transfer Agreement;
  • the UK Addendum to approved standard contractual clauses; or
  • another lawful transfer mechanism.

10. How long we retain information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected.

Our intended retention periods are:

App progress

Quiz progress and settings stored locally remain on your device until:

  • you clear or reset the relevant information;
  • you delete the app;
  • the device removes the information; or
  • you erase or replace the device.

PathwayPro does not have access to locally stored progress and therefore cannot delete it remotely.

Support correspondence

Support enquiries and related correspondence may be retained for up to 24 months after the request has been resolved.

We may retain information for longer where reasonably necessary to address an ongoing complaint, legal claim or repeated technical issue.

Product update and marketing information

Product update or marketing information is retained until:

  • you unsubscribe;
  • you withdraw consent;
  • it is clear that you are no longer engaging with our communications.

When you unsubscribe, we may retain a minimal suppression record so that we do not accidentally send further marketing messages to the same address.

Website and security logs

Routine website logs are generally retained for up to 30 days.

Security-related records may be retained for longer where necessary to investigate malicious activity, fraud, attempted unauthorised access or another security incident.

Legal, financial and business records

Information required for tax, accounting, legal or regulatory purposes may be retained for the period required by applicable law.

When information is no longer required, we will delete it, anonymise it or securely dispose of it.

11. Data security

We use reasonable organisational and technical measures designed to protect personal information against:

  • accidental loss;
  • unauthorised access;
  • alteration;
  • disclosure;
  • misuse; and
  • destruction.

These measures may include:

  • limiting access to information;
  • using reputable technology providers;
  • password and account security;
  • encrypted website connections;
  • maintaining software updates; and
  • reviewing access when it is no longer required.

No method of electronic storage or transmission is completely secure. We cannot guarantee absolute security, but we take reasonable steps appropriate to the nature of the information we process.

12. Your data protection rights

Depending on the circumstances, you may have the right to:

Be informed

You have the right to understand how your personal information is collected and used.

Access

You may ask for confirmation of whether we process your personal information and request a copy of that information.

Rectification

You may ask us to correct inaccurate or incomplete personal information.

Erasure

You may ask us to delete personal information in certain circumstances.

Restriction

You may ask us to restrict how personal information is used in certain circumstances.

Data portability

Where applicable, you may ask to receive personal information you provided in a structured, commonly used and machine-readable format.

Object

You may object to certain processing, including direct marketing and some processing based on legitimate interests.

Withdraw consent

Where processing is based on consent, you may withdraw your consent at any time.

These rights are not absolute and may be subject to legal exceptions.

Because PathwayPro does not receive or store your locally held quiz progress, we cannot provide, correct or delete that information remotely. You can normally remove it by clearing the app’s local information or deleting the app.

To exercise a data protection right, email:

hello@pathwaypro.co.uk

We may need to request reasonable information to verify your identity before responding.

13. Complaints

Please contact us first if you have a concern about how your information has been handled. We will try to resolve the issue.

You also have the right to complain to the UK Information Commissioner’s Office.

The Information Commissioner’s Office is the United Kingdom’s independent data protection regulator. Contact and complaint information is available on the ICO website.

If you live outside the United Kingdom, you may also have the right to contact the data protection regulator in your country or region.

14. Children’s privacy

PathwayPro is designed for individuals undertaking or preparing for professional surveying qualifications. It is not directed towards children.

We do not knowingly collect personal information from children under 16 through the app or website.

If you believe a child has provided personal information to us, please contact hello@pathwaypro.co.uk so that we can investigate and, where appropriate, delete it.

15. Third-party links

The app or website may contain links to third-party websites or services, including Apple and official professional resources.

We do not control the privacy practices of third parties. You should review their privacy information before providing personal information to them.

16. Changes to this Privacy Policy

We may update this Privacy Policy to reflect:

  • changes to the app;
  • new website functionality;
  • new service providers;
  • changes to data practices;
  • legal or regulatory developments; or
  • improvements to the wording.

The latest version will be published on this page with an updated “Last updated” date.

Where a change is material, we may also provide an additional notice within the app, on the website or by email where appropriate.

17. Contact us

Questions, requests and complaints concerning this Privacy Policy can be sent to:

Email: hello@pathwaypro.co.uk. Operated by: Bailey Ellis, trading as PathwayPro.