2026-09-20-draft · Not in force until counsel publishes
PathWork Privacy Supplement
What Accumentum processes when you use PathWork, in addition to the Accumentum privacy policy that already covers PathProof.
1. Controller
Accumentum LLC is the controller for PathWork platform records. Privacy contact: legal@accumentum.net. This supplement adds to the Accumentum privacy policy and controls where they differ on PathWork.
2. What we process
In addition to your Accumentum account:
- Expert profile: professional identity you already published on Proof, offers, rates, availability, Accumentum-verified activity, PathLock status, and eligibility state.
- Buyer and request data: name, organization if given, intake, scoped-request text.
- Session data: bookings, slots, notes, action items, completions, refunds, reviews.
- Payment data: amounts funded, released, refunded, the 12% take, invoice references, and identifiers from the payment provider. Card numbers stay with the provider.
- Eligibility data: PathLock currency, completeness checks, strikes, pauses. Government-ID and biometric templates, if a payout provider collects them, stay with that provider. Accumentum receives outcomes.
- Tax data required of a U.S. reporting platform: legal name, address, TIN, and consideration paid.
- Trust and safety: reports, moderation, attestations (including moonlighting and unclassified-work), IP address and user agent at acceptance.
3. Why
We process this to run PathWork and form Sessions (contract), to collect and release funds and report tax (contract and legal obligation), to enforce banned work and prevent fraud (legal obligation and legitimate interests), to send booking notices (contract), and to send optional match alerts you can turn off (legitimate interests or consent where required).
4. Who sees what
A published Proof page is public because the expert chose to publish it. PathWork does not hide surnames on Proof — Proof is the identity layer. Session intake, notes, and payout details are visible to the two parties and to Accumentum staff who need them for disputes, tax, or safety. A scoped request is visible to staff until matched. Reviews of completed Sessions are public on the expert’s PathWork section.
5. Recipients
The other party to a Session; Stripe (or successor) for payments; PathLock as already connected on Proof; hosting and error monitoring under instruction; tax authorities as required; courts and advisors when required to defend a claim.
6. Retention (draft)
Expert offers: while PathWork is active and twelve months after pause or close. Unmatched scoped requests: twenty-four months. Bookings, invoices, and payment records: seven years from the end of the tax year, or longer if IRS or state law requires. Session notes: three years after completion. Tax information: as required for 1099 reporting. Attestations and moderation: five years. When a period ends we delete or anonymize, except records we must keep.
7. Automated processing
Filters and completeness scores are automated. They do not by themselves refuse an account. A human takes decisions to revoke, strike, or allocate disputed funds. PathLock currency is a machine check of a connection the expert already authorised.
8. Your rights
Depending on where you live, you may access, correct, delete, or export PathWork records, or object to processing based on legitimate interests. Erasure does not remove invoices, 1099 records, or an open dispute. Draft contact: legal@accumentum.net.
9. Data the expert sees from a buyer
If a buyer hands the expert personal data to do the session, the buyer is controller of that data and the expert is processor. Accumentum is not controller of that off-platform file unless it is uploaded into PathWork. Do not upload customer PII, CUI, or special-category data.
