Section 1
Data Controller
Intuitive Logic Limited (company number 16687846), operating Pathfinder.college, is the data controller for personal data processed through this service. Our registered address is 1 Heathway, Ascot, Berkshire, SL5 8NX, United Kingdom. We are responsible for ensuring that your data is handled lawfully, fairly and transparently in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Section 2
Our Legal Framework
We operate under:
- UK GDPR and the Data Protection Act 2018
- The UK Children's Code (Age Appropriate Design Code), published by the ICO, which we apply because some of our users may be under 18
- The Data (Use and Access) Act 2025, which updates the UK GDPR framework including provisions relating to automated decision-making
- The Privacy and Electronic Communications Regulations 2003, which govern cookies and electronic marketing
Section 3
Data Minimisation
We collect only the personal data needed to deliver Pathfinder. We do not collect data speculatively or for purposes beyond those described in our Privacy Policy.
Section 4
Purpose Limitation
Personal data collected for one purpose is not repurposed without your consent. Your ikigai list data is collected for one purpose: to generate your personalised report and Game Plan. It is not used for advertising, commercial profiling or any other secondary use.
Section 5
Automated Processing
Pathfinder uses AI to analyse your submitted data and generate your report. We are transparent about this, and our AI Policy explains how it works.
Pathfinder's AI processing does not constitute automated decision-making with legal or similarly significant effects, as defined by UK GDPR and ICO guidance. Your report does not determine access to employment, education, funding, credit or any other consequential outcome. It is a reflective tool that you are free to use, question or ignore.
Section 6
Children's Code Compliance
Because some of our users may be under 18, we apply the standards of the UK Children's Code to all users:
- The best interests of young users are the primary consideration in design and data decisions
- Only data needed to deliver the service is collected
- No user is profiled for advertising or commercial targeting
- Privacy settings are set to maximum protection by default
- The platform does not use manipulative design to encourage data sharing
- This legal page is written in plain language
- We do not collect precise geolocation data
Section 7
Data Processing Agreements
We maintain data processing agreements with all third-party processors who handle personal data on our behalf. Each agreement confirms that data is processed only on our instructions, that appropriate security measures are in place, and that data is not used for the processor's own purposes. Our processors are listed in our Privacy Policy.
Section 8
International Data Transfers
Some of our processors process data in the United States. These transfers are made under the UK-US Data Bridge or the UK International Data Transfer Agreement. We do not transfer data to countries without adequate protection unless appropriate safeguards are in place.
Section 9
Data Subject Rights
Under UK GDPR you have the right to access, correct, delete, restrict and port your personal data. You may object to processing based on legitimate interests and withdraw consent at any time.
To exercise any of these rights, contact the founder Valentine Stockdale via this WhatsApp link. We respond within 5 working days and complete requests within one month.
Section 10
Complaints
If you believe your data protection rights have been infringed, you have the right to lodge a complaint with the Information Commissioner's Office at ico.org.uk or by calling 0303 123 1113.
We encourage you to contact us first so we can resolve your concern directly.
Last updated September 2026. This policy is reviewed and updated as our tools and practices evolve.