Privacy policy

Who we are

The Pathway to Progress ("we", "us") is a registered non-governmental organisation (NGO) in Ghana (Registration number CG065470924). We are the data controller for the information described here. Contact us at admin@thepathwaytoprogress.com or by post:

66 Artillery Regiment, Volta Barracks
Ho, Volta Region
Ghana

If you live in Washington State or another US state with a consumer health data law, please also read our consumer health data privacy policy.

What we collect and why

Free email course and tips: Your email address, the free course you chose (for example the acne course), the page you signed up on and, if you reached that page from one of our ads or links, the campaign details carried in that link (such as the campaign name or search keyword). If you arrived from one of our Google ads, and you are outside the European Economic Area, the United Kingdom and Switzerland or you chose "Allow" in our cookie notice, we also keep the click reference number Google adds to the link; it does not contain your name. We use this to send the free 5-day course and the weekly tips you asked for, and to see which of our ads and pages help people find us. If you came from one of our Google ads, we may tell Google Ads that the click reference led to a confirmed sign-up, so our free ads reach people who find the course useful; we never send Google your email address or name. Our email service also records whether each email is opened and which links in it are clicked; we look at this only to see which tips are useful. Links in our emails can take you to other websites, which have their own privacy policies; we do not add your email address or name to those links. The course you chose is an interest, not a diagnosis, and we never ask about medical conditions or history. Legal basis: your consent, which you give by submitting the clearly labelled sign-up form and then confirming your email. We keep a record of when you signed up, which form you used and which version of the sign-up wording you saw, so we can show what you agreed to.
Emails you send us: Your email address, name and whatever you write. We use it to reply and to improve our content. Legal basis: our legitimate interest in responding to correspondence.
Website analytics: We use Google Analytics and Google Ads measurement to understand which guides people read, roughly where visitors come from, and whether our outreach is working. Google's measurement tags load on every page. For visitors in the European Economic Area, the United Kingdom and Switzerland, until you choose "Allow" in the cookie notice (or if you choose "No thanks"), they set no cookies and send Google only limited signals without cookies, such as the time, your browser type, the page and whether you arrived from an ad, which Google uses for aggregate modelling. Elsewhere, Google's cookies are on by default and you can switch them off with "Cookie choices" at the bottom of any page. We have switched off Google's use of this data for personalised advertising. Legal basis: consent where required, otherwise legitimate interest in understanding how the site is used.
Server logs: Our hosting provider records standard technical information (IP address, browser type, pages requested, time) for security and to keep the site running. Legal basis: legitimate interest.

We do not collect medical records, we do not ask for your medical history, and we use the course you chose only to send you the right lessons. We never sell or rent your information, and we never pass your details to any retailer or manufacturer.

Who we share it with

We do not sell, rent or trade personal information, and we do not share it with skin care companies or advertisers. We use a small number of service providers who process data only on our instructions:

MailerLite, which stores the email list, sends the course and tips and records opens and clicks.
Netlify, which hosts the website and receives sign-up form submissions before they are passed to our email service.
An automation service (such as Zapier or Make), if we use one to pass sign-ups from the form to our email service. It handles your email address and the hidden form details for that purpose only.
Google (Google Analytics and Google Ads), for website analytics and to measure whether people who arrive from our outreach find the site useful. We do not share your email address with Google. Google Fonts also serves the typefaces on this site, which means your browser sends its IP address to Google when a page loads. You can read how Google uses information from sites that use its services.

We may disclose information if the law requires it or to protect someone's safety. Some providers store data outside your country; where that happens we rely on their standard contractual safeguards.

How long we keep it

Sign-up form copies held by our hosting provider and any automation service: deleted once the sign-up has reached our email service, and at least once a month.
Tips subscribers: until you unsubscribe. We then delete your details within 30 days, keeping only your email address on a suppression list so we never message you again.
Emails to us: up to two years, then deleted unless needed for a legal reason.
Analytics: aggregated reports indefinitely; identifiable analytics data for no longer than 14 months.
Anonymous records of cookie choices (the choice, the notice version and the time, nothing that identifies you): two years.

Your choices and rights

Unsubscribe at any time using the link in any email.
Access, correct or delete what we hold about you, or object to or restrict how we use it, by emailing admin@thepathwaytoprogress.com. We respond within 30 days.
Withdraw consent at any time; it will not affect anything done before you withdrew it. For cookies, use "Cookie choices" at the bottom of any page.
Complain to your local data protection authority if you are unhappy with how we have handled your information. We would rather hear from you first so we can put it right.

Children

The tips service is for people aged 16 and over. We do not knowingly collect information from anyone younger; if you believe a child has signed up, email us and we will remove the details.

Cookies and storage on your device

Google Analytics sets cookies to distinguish visitors, and Google Ads measurement can set cookies that tell us whether someone who clicked one of our ads went on to sign up. For visitors in the European Economic Area, the United Kingdom and Switzerland, these are switched off by default (Google Consent Mode) and only switched on if you choose "Allow" in the cookie notice. Everyone can change their choice at any time with "Cookie choices" at the bottom of every page; choosing "No thanks" switches Google's cookies off and removes the ones already set on this site. We do not use advertising or tracking cookies to follow you across other websites.

The site itself sets no cookies. It keeps a few small notes in your browser's storage:

ptp-consent (kept until you clear it): your cookie choice, the notice version and when you made it. This is needed to respect your choice.
ptp-utm (cleared when you close the tab): the campaign details and click reference from the link you arrived on, so they can go with your sign-up.
ptp-signup (cleared when you close the tab): a note that you have just signed up, so the sign-up is counted once.
ptp-confirmed (kept until you clear it): a note that you confirmed your email, so the confirmation is counted once.

In the European Economic Area, the United Kingdom and Switzerland, ptp-utm, ptp-signup and ptp-confirmed are only kept if you chose "Allow".

Security

The site is served over HTTPS. Subscriber lists are held with providers that use encryption and access controls, and only people who need access to run the tips service have it. No system is perfectly secure, so we collect as little as we can.

Changes to this policy

We will post changes here with a new date. If a change affects how we use what you have already given us, we will tell subscribers directly.