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Positive Paths CIC understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website“Our Site”) and will only collect and use personal data in ways that are described here and in a way that is consistent with our obligations and your rights under the law. Please read this Privacy Policy carefully and ensure that you understand it.

Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

  • “Account” means an account required to access or use certain areas and features of Our Site;

  • “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14 below; and

  • “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.

Information About Us

Our Site is owned and operated by SUPPORTING POSITIVE PATHS C.I.C., a limited company registered in Scotland under company number SC440025. Registered address: 16/2 Timberbush, Timber Bush, Edinburgh, Scotland, EH6 6QH.

What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

  1. a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.

  2. b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.

  3. c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.

  4. d) The right to be forgotten, i.e., the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.

  5. e) The right to restrict (i.e., prevent) the processing of your personal data.

  6. f) The right to object to us using your personal data for a particular purpose or purposes.

  7. g) The right to withdraw consent. This means that if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

  8. h) The right to data portability. This means that if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

  9. i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15. It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first using the details in Part 15.

What Data Do You Collect and How?

Depending upon your use of Our Site, we may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about Our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children or data relating to criminal convictions or offences.

Data Collected

Identity Information including name and age band.

Contact information including billing address, delivery address, email address, telephone numbers, social media addresses.

Business information including business name, business address, job title.

Profile information including feedback and survey responses.

Technical information including internet protocol, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.

How we Collect the Data

Data you give to us: when you register to use our services; when you talk to us on the phone; when you use our website, mobile device apps, or web chat; when you email or send letters to us for any reason; when you engage with us on social media (your social media username if you interact with us through those channels); if you take part in our competitions or promotions; when you give us feedback, comments, and product reviews.

Data we collect when you use our services: profile and usage data including data we gather from the devices you use to connect to those services, such as computers and mobile phones using cookies and other internet tracking software; we use several products to analyse traffic to this website to understand our visitors’ needs and to continually improve our sites for them. We collect only anonymous aggregate statistics. For example, we do not tie a specific visit to a specific IP address; we use technologies to collect and store information about the device or browser you use when you visit ours and third-party sites and this may include using cookies or similar technologies to identify your browser or device; when you give us some feedback; when you use our website and subscribe to our newsletter or register to take part in any campaign or competition.

How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. Most commonly, we will use your personal data in the following circumstances:

  • To perform a contract: For example, where we have agreed to send you certain products or services.

  • For our legitimate interests: For example, to send you information about our products where you have shown interest.

  • To comply with a legal or regulatory obligation: For example, passing on details to law enforcement agencies.

  • With your consent: For example, when you opt in to receive email newsletters.

The following table describes how we will use your personal data and our lawful basis for doing so:

What We Do                         

Details of interactions with us through email, letter, telephone, social media, including sending you relevant personalised communications by post in relation to updates, offers, services, and products. For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, and how and when you contact us.

Webnews and newsletters to keep you informed about relevant products, including tailored special offers, promotions, events, competitions, and so on.

Supplying our products to you.

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).

To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences.

What Data We Use         

Full name, address, email address, and copies of your communication with us.        







Full name, address, email address.





Full name, address.



Identity, contact, and technical data.






Technical and usage data.  

Our Lawful Basis

We do this on the basis of our contractual obligations to you and our legitimate interests in providing you with the best service and understanding how we can improve our service, products, and business based on your experience.

This will be subject to your prior consent. If we did not have this information, then we wouldn’t be able to contact you. You can, of course, let us know at any time when you do not want to receive this information.

We do this on the basis of our contractual obligations to you and our legitimate interests in providing you with our product(s).

This is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business re-organisation or group restructuring exercise).


This is necessary for our legitimate interests (to define types of customers for our products, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy).

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on our products. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes, and you will be able to opt-out at any time.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to or incompatible with the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

How Long Will You Keep My Personal Data?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

How and Where Do You Store or Transfer My Personal Data?

We will store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation. We may store or transfer some or all of your personal data in the European Economic Area (the “EEA”). The EEA consists of all EU member states plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation GDPR and/or to equivalent standards by law.

We do not transfer your data outside of the EEA. However, we may use third-party service providers that do, in which case, if they do transfer your personal information outside the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA and will ensure adequate safeguarding measures are in place. Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

  • Limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

  • Procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

  • If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it as specified in this Privacy Policy.

  • In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

How Can I Control My Personal Data?

In addition to your rights under the Data Protection Legislation set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us, which you may do by unsubscribing using the links provided in our emails).

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

Can I Withhold Information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site, you may be required to submit or allow for the collection of certain data.

How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests), a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data, within that time. In some cases, however, particularly if your request is more complex, more time may be required. You will be kept fully informed of our progress.

How Do You Use Cookies?

Below we list the different types of cookies that may be used on the Site. Note that to the extent information collected through cookies constitutes personal information, the provisions in the Privacy Policy apply and complement this Cookie Policy.

  • Essential Cookies: Essential cookies are necessary for the Site to work and enable you to move around it and to use its services and features. Without these absolutely necessary cookies, the Site will not perform as smoothly for you as we would like it to, and we may not be able to provide the Site or certain services or features you request.

    • Session: Session cookies are used to maintain the state of the application.

    • Load balancing: Load balancing cookies are used to distribute the assets across the globe and lighten the server load.

    • User ID: User ID cookies are used to ensure that users only see their own information.

    • Security: Security cookies are used for security controls and checks.

  • Preference Cookies: Preference cookies collect information about your choices and preferences and allow us to remember language or other local settings and customise the Site accordingly.

    • Language: Language cookies are used to store the language the user has selected and to show the correct options.

    • Location: The user’s approximate address (city, state, country, postal code) as determined by the IP address is retained in order to automatically select the proper country and show retailers and demonstration days within the area.

    • Mobile: If the user is viewing the Site on a mobile device, a cookie is set to indicate that the main website was selected (i.e., that the device is Flash enabled) or the non-Flash mobile site.

    • Reference site: The reference site is recorded to better understand the user’s preference.

    • Recently watched video: Date and title of recently watched video is recorded to be able to better understand the user’s preferences.

    • Flash Cookies: Flash cookies are used to enable audio and video content to be played.

    • Page history: Page history cookies are used to track the sequence of pages the user has visited. If the user gets an error message while visiting the Site, the cookie information gets saved to a log file for error reporting and resolution.

  • Social Plug-in Tracking Cookies: Such cookies are used to track members of social media networks for market research analytics and product development.

    • Facebook: Cookies are used to track Facebook members [and nonmembers] for market research, analytics, and product development.

    • Twitter: Such cookies are used to track members [and nonmembers] for market research, analytics, and product development.

  • Analytics Cookies: Analytics cookies collect information about your use of the Site and enable us to improve the way it works. For example, analytics cookies show us which are the most frequently visited pages on the Site, help us record any difficulties you have with the Site, and show us whether our advertising is effective or not. This allows us to see the overall patterns of usage on the Site rather than the usage of a single person.

    • Google Analytics: Google Analytic cookies collect aggregate statistical data to improve Site presentation and navigation.

    • Hotjar: These cookies let Hotjar know whether that visitor is included in the sample which is used to generate Heatmaps, Funnels, Recordings, etc., and when the customer first lands on a page with the Hotjar script. It is used to persist the random user ID unique to that site on the browser. This ensures that behaviour in subsequent visits to the same site will be attributed to the same user ID.

    • Jetpack: These cookies are installed by JetPack. Used for the internal metrics for user activities to improve user experience and for analysing referrer behaviour for JetPack on sites using WooCommerce.

  • Marketing Cookies: Advertising Cookies are used for marketing purposes.

    • Advertising: Deliver behavioural/targeted advertising.

    • Market Analysis: Conduct market analysis.

    • Campaign/Promotion: Measure effectiveness of campaign.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO. The ICO’s address:           

Information Commissioner’s Office

Wycliffe House

Water Lane




Helpline number: 0303 123 1113



How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

  • Email address:

  • Telephone number: (+44) 7903 962450.

  • Postal Address: 11 Timber Bush, Leith, Edinburgh, EH6 6QH.

Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes or if we change our business in a way that affects personal data protection. Any changes will be immediately posted on Our Site, and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 23/5/2024.

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