Privacy Policy

1. Who we are and how to contact us

Forge Gate Limited (trading as OwlPath), company number 17196398, registered in England and Wales, is the data controller for the personal data we process in connection with OwlPath.

For any privacy-related questions or to exercise your rights, contact us at privacy@owl-path.com. Our registered address is available on written request.

2. What data we collect and why

Account data

When you register, we collect your name and email address. We use this to provide your account, send service communications, and — if you subscribe to a paid plan — to manage your subscription via Stripe.

Lawful basis: Contract (necessary to provide the Service you have requested).

CV and job description content

When you use OwlPath, you upload or paste your CV and job descriptions. This content is processed to generate your match analysis, CV suggestions, cover letters, and other outputs. We store this content in your account so you can reuse it across multiple analyses.

Your CV may contain special category personal data (for example, details of disabilities or health conditions if you have disclosed them). We process this data only to the extent necessary to provide the analysis you have requested.

Lawful basis: Contract; and for special category data, your explicit consent given by voluntarily submitting the content.

Usage data

We collect data about how you use the Service — including pages visited, features used, and analysis history. This is used to improve the Service, troubleshoot issues, and enforce our usage limits.

Lawful basis: Legitimate interests (improving and securing the Service).

Payment data

Payment card details are collected and processed directly by Stripe. We store only a Stripe customer ID and subscription status — we never see or store your full card number.

Lawful basis: Contract.

Voice profile data (Pro plan)

If you use the cover letter feature, we extract a writing style profile from your CV text. If you optionally provide a writing sample to improve your profile, we store that sample and the extracted profile. This data is used solely to personalise cover letter generation for you.

Lawful basis: Contract; your explicit consent for optional writing samples.

3. How we use AI to process your data

OwlPath uses AI language models to generate analyses, suggestions, and cover letters. Your CV text and job description content is sent to our AI service provider (Anthropic) for processing. This is the core mechanism by which the Service works.

We do not use your data to train AI models. Our agreement with Anthropic does not permit them to use your data for model training. Your content is processed to generate your results and is not retained by Anthropic beyond what is needed to provide that response.

Automated processing, including match scoring and CV analysis, involves decisions made without human review. These outputs are advisory in nature — see our Terms of Service for full detail on the limitations of these outputs.

4. Who we share your data with

We share data only with the service providers necessary to operate OwlPath. These providers act as data processors under our instruction:

We do not sell your personal data to any third party. We do not share your data with advertisers or data brokers.

International transfers: Where providers are located outside the UK, transfers are made under appropriate safeguards, including UK Standard Contractual Clauses (SCCs) or an adequacy decision.

5. How long we keep your data

6. Your rights under UK GDPR

You have the following rights in relation to your personal data:

• Access — request a copy of the personal data we hold about you
• Rectification — request correction of inaccurate or incomplete data
• Erasure — request deletion of your data (subject to legal retention obligations)
• Restriction — request that we restrict processing of your data in certain circumstances
• Portability — request your data in a structured, machine-readable format
• Objection — object to processing based on legitimate interests
• Withdraw consent — where processing is based on consent, withdraw it at any time without affecting prior processing

To exercise any of these rights, contact us at privacy@owl-path.com. We will respond within one month. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

7. Security

We use industry-standard technical and organisational measures to protect your data, including encryption in transit (TLS) and at rest, access controls, and regular security reviews. No transmission over the internet is 100% secure — if you believe your data has been compromised, contact us immediately.

8. Cookies

OwlPath uses only essential cookies necessary for the Service to function:

• Session cookie — keeps you logged in during your session
• Authentication token — maintains your logged-in state securely

We do not use advertising cookies, tracking cookies, or third-party analytics cookies that identify you individually. We do not use Google Analytics or similar tracking services.

9. Children

The Service is not directed at children under 18. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with personal data, contact us and we will delete it promptly.

10. Changes to this policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or by a notice in the Service. The “Last updated” date at the top of this page reflects when changes were last made.

11. Contact and complaints

If you are unhappy with how we have handled your data, you have the right to complain to the Information Commissioner's Office (ICO).