Privacy Policy

Last Updated: 30.04.2025.

1. Introduction & Scope

1.1 Who We Are

Welcome to Career Paths, a Milan-based college consulting agency offering holistic and highly individualized academic and career consulting services to clients around the globe. Our goal is to provide comprehensive support, from elementary school guidance to college admissions and beyond.

1.2 Purpose of This Privacy Policy

This Privacy Policy explains what personal data we collect, how we use, store, and protect it, and the rights you have with respect to that data. It applies to all websites, services, and communications offered under the “Career Paths” name (hereinafter “we,” “us,” or “our”).

1.3 Legal Framework / Compliance

We are committed to protecting your personal data and ensuring our practices comply with the General Data Protection Regulation (GDPR), relevant Italian data protection regulations, and any other applicable international privacy laws. Since we are registered in Milan, Italy, local Italian law (including any guidance or requirements issued by the Garante per la Protezione dei Dati Personali) may also apply where relevant.

2. What Data We Collect

2.1 Personal Identifiable Information (PII)

We may collect personal data such as:

Name, date of birth, and address
Contact details (email address, phone number)
Academic history (transcripts, test scores, extracurriculars, awards)
Financial information related to scholarships or funding needs

2.2 Sensitive Data (Where Applicable)

In certain circumstances, we may collect or process special categories of data, such as:

Ethnic origin or health/disability information, if it is relevant for college applications or educational accommodations
Any other special categories of data processed as part of our holistic advising approach

We will obtain your explicit consent (or, if you are a minor, parental/guardian consent) before collecting this type of information.

2.3 Automatically Collected Data

Like most websites, we use cookies and similar technologies to collect information such as:

IP address
Browser type
Device identifiers

For more details, please see our Cookie Policy or the Cookie section below.

2.4 Children’s Data

We often provide services for minors (under 18), and we may need to collect data from or about individuals who are under the age of 13 (or 16, depending on local law). In these cases, we require parental or guardian consent before collecting or processing a child’s personal data. If you believe we have collected personal data from a child without proper consent, please contact us immediately (see Section 12) so that we can take appropriate steps to address the issue.

3. How We Collect Data

3.1 Direct Collection

We collect personal data directly from you when you:

Fill out online forms or questionnaires
Participate in phone or video consultations
Communicate with us via email
Meet us in person (e.g., workshops or special events)

3.2 Third-Party Sources

We may also receive personal data from:

Referrals (e.g., a teacher or counselor providing academic details with your consent)
Publicly available sources (e.g., certain social media profiles), when relevant and legally permissible

3.3 Cookies & Similar Technologies

We use cookies (small text files stored on your device) and similar technologies to:

Enable essential site features
Analyze website traffic and user interactions
Provide marketing or promotional materials (only with your consent, if required)

For more detailed information, see Section 9.

4. Purpose & Legal Basis for Processing

We process personal data for the following purposes and under these legal bases (GDPR Article 6):

Service Delivery (Article 6(1)(b)):
- To provide individualized college consulting, admissions guidance, and related services.
Legitimate Interests (Article 6(1)(f)):
- For business administration, analytics, and continuous improvement of our services.
Consent (Article 6(1)(a)):
- When we process sensitive data or send you marketing communications (if required by law).
Legal Obligations (Article 6(1)(c)):
- To comply with applicable laws, regulations, or court orders.

5. How We Use & Share Information

5.1 Internal Use

Personal data is accessed only by authorized staff or consultants at Career Paths who need it to deliver our services.

5.2 Third-Party Service Providers

We may share data with third parties who perform services on our behalf, such as:

Hosting or cloud service providers
Payment processors
Analytics or marketing tool providers

These providers are contractually obligated to protect your data and only process it under our instructions.

5.3 No Selling of Data

We do not sell or rent your personal data to third parties for their own marketing purposes.

5.4 International Transfers

If your data is transferred outside the European Economic Area (EEA), we will ensure it is protected by appropriate safeguards (such as Standard Contractual Clauses) as required by the GDPR.

5.5 Legal Disclosure

In certain circumstances, we may be required to disclose personal data to regulatory or law enforcement authorities (e.g., to comply with a subpoena or legal obligation).

6. Data Retention & Security

6.1 Retention Periods

We keep personal data only as long as necessary to fulfill the purposes for which it was collected, or to comply with legal obligations. The exact retention period may vary based on the type and sensitivity of the data, as well as any statutory or contractual requirements.

6.2 Security Measures

We implement industry-standard security measures to protect your personal data, including:

Encryption where appropriate
Secure servers and limited-access systems
Administrative safeguards such as staff training and confidentiality agreements

6.3 Data Breach Protocol

In the event of a data breach that poses a risk to your rights and freedoms, we will promptly notify the relevant supervisory authority (e.g., the Italian Garante per la Protezione dei Dati Personali) and affected individuals, as required by the GDPR.

7. Your Rights Under GDPR (and Other Applicable Laws)

Where the GDPR applies, you have the right to:

Access: Request a copy of the personal data we hold about you.
Rectification: Ask us to correct or update any inaccurate or incomplete data.
Erasure (“Right to be Forgotten”): Request that we delete your personal data when it is no longer needed, or if processing is unlawful.
Restriction: Ask us to limit the processing of your personal data under certain circumstances.
Objection: Object to the processing of your data if it is based on our legitimate interests or for direct marketing.
Data Portability: Receive your personal data in a structured, commonly used format for transfer to another service provider.
Withdraw Consent: Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.

To exercise any of these rights, please contact us using the details in Section 12.

8. Children’s Privacy

8.1 Protection of Minors

We acknowledge that a significant portion of our clients may be minors. We handle children’s data with the highest level of care and strict confidentiality.

8.2 Parental or Guardian Consent

If you are under 13 (or 16 in certain jurisdictions), we require verifiable parental or guardian consent before collecting or processing your personal data.
We will take steps to verify that consent has been granted.

If you are a parent or guardian and believe that your child has provided us with personal data without your consent, please contact us immediately (see Section 12) so we can take appropriate action.

9. Cookies & Tracking Technologies

9.1 Types of Cookies We Use

We may use the following types of cookies on our website:

Essential Cookies: Necessary for basic site functionality.
Analytics Cookies: Help us understand how users interact with our website (e.g., Google Analytics).
Functional Cookies: Enhance user experience (e.g., remembering preferences).
Marketing/Advertising Cookies: May be used to deliver targeted advertising, only with proper consent where required.

9.2 Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC (“Google”), to collect information about how visitors use and navigate our site. Google Analytics places cookies on your device to generate information about your use of our website (including your IP address). That information is transmitted to and stored by Google on servers that may be located outside the European Economic Area (EEA), including in the United States.

To comply with privacy regulations, we have configured Google Analytics to anonymize IP addresses where possible. This means that Google will typically truncate/anonymize the last octet of your IP address prior to storing it. Google will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on site activity, and providing us with other services related to website usage and internet usage.

You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on or by adjusting your browser settings to reject all or certain cookies. For more information on how Google handles user data, please review Google’s Privacy Policy.

9.3 Cookie Management

You can manage or delete cookies at any time by adjusting your browser settings. Some functionalities on our website may be limited if you choose to disable cookies.

Blocking Cookies: You can usually choose to block cookies (including third-party cookies) through your browser settings. However, doing so may affect the functionality of our site.
Deleting Cookies: You can delete previously set cookies in your browser settings.
Opt-Out Mechanisms: Certain third parties, including Google, may offer their own direct opt-out methods (e.g., Google Analytics Opt-out Browser Add-on).

9.4 Third-Party Tracking

Besides Google Analytics, we may use other third-party analytics or advertising services that employ cookies or similar technologies. Please refer to each provider’s website for information on how they handle your data and how to opt out of tracking. If you have any questions about our use of cookies and tracking technologies, feel free to contact us (see Section 12).

10. External Links & Third Parties

Our website may contain links to other sites or services that are not operated by Career Paths. We are not responsible for the privacy practices of these external sites. When you leave our website, we encourage you to read the privacy policies of every site you visit.

For more detailed information, please also see our Terms and Conditions page.

11. Updates to This Privacy Policy

11.1 Policy Changes

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The “Last Updated” date at the top of this page indicates when the policy was most recently revised.

11.2 Notification of Changes

If we make material changes, we will notify you via email (if we have your email address) or by posting a prominent notice on our website.

12. Contact Information

12.1. Data Protection Contact

If you have questions about this Privacy Policy or wish to exercise any of your rights, please contact our data protection officer (DPO) or privacy team at:

Email: client.support@careerpaths.it
Phone: +39 366 405 6933

12.2 Complaint to Supervisory Authority

If you believe we have infringed upon your rights under applicable data protection laws, you have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali) or the supervisory authority in your country of residence.

13. Disclaimer / Liability

13.1 Service Provision & Liability Limits

Career Paths provides consulting and advisory services related to academic and career guidance. We do not guarantee specific results or admissions outcomes, as each student’s academic or admissions success depends on various individual factors beyond our control, including decisions made by third parties such as schools or universities.
Past client successes or experiences do not guarantee or imply future results. By using our services, you expressly acknowledge and accept these limitations.

13.2 Individualized Nature of Services

Each plan we offer is highly individualized and tailored to the specific needs of the student.
Unauthorized replication or resale of our proprietary methods or materials is prohibited.

13.3 No Liability for External Misuse

We are not responsible for any misuse of personal information by the client or any third party once data is shared outside of our secure systems.

13.4 Acknowledgment & Acceptance

By using our services, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.