1. INTRODUCTION & SCOPE

Clear Path Billing Solutions Inc. ("Clear Path," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy describes how we collect, use, share, and protect information when you interact with us through our website, client portal, email, SMS, phone, and other business communications.

What This Policy Covers

This Privacy Policy applies to:

• Clear Path's public website (clearpathbillingsolutions.com and related pages)

• Client portal access for prospective clients (pre-contract onboarding, intake forms, e-signature, account setup)

• Business communications (email, SMS, phone calls, video calls, portal chat)

• Automatically collected data (cookies, analytics, server logs, device information)

What This Policy Does NOT Cover

This Privacy Policy does not govern:

• Protected Health Information (PHI) processed under a signed Business Associate Agreement (BAA)—that is governed by HIPAA and your specific BAA

• Service agreements for active billing clients—governed by your signed Service Agreement and BAA

• Third-party websites linked from our site—we are not responsible for their privacy practices

2. ABOUT CLEAR PATH

3. CATEGORIES OF INFORMATION WE COLLECT

3.1 Information You Provide Directly

Website Contact Forms & Inquiries

When you contact us through our website or email, we may collect:

• Full name, email address, and phone number

• Company or practice name

• Your inquiry, message, or question content

• Any attachments or documents you upload

• Professional role or title

Client Portal (Pre-Contract Onboarding)

During onboarding, we collect:

• Practice name, address, and business details

• Owner or decision-maker name, email, phone number

• Type of healthcare services (mental health, chiropractic, family medicine, etc.)

• Number of clinicians and patient panels

• Electronic Health Record (EHR) system used

• Current billing arrangement and payers

• Desired onboarding timeline

• Portal account credentials (username and password—stored securely and encrypted)

• Electronic signature data and timestamp when you accept agreements

Blog Subscription

• Email address for blog updates and newsletter content

Direct Communications

• Email content, attachments, and metadata (sender, recipient, date, time)

• SMS message content and metadata (phone number, date, time, message length)

• Phone call recordings or notes (with your consent)

• Portal chat messages and metadata

• Video call recordings or transcripts (with your consent)

3.2 Information Collected Automatically

Cookies & Tracking Technologies

• Session and security cookies (required for site functionality)

• Framer hosting cookies (for CDN, performance, and security)

• Analytics identifiers (generic analytics tools; Google Analytics or similar may be deployed in 2026)

• Device identifiers (browser type, operating system, device model)

• IP address and approximate geolocation (city/region level, not precise)

Website & Portal Usage Data

• Pages visited and time spent on each page

• Links clicked and buttons pressed

• Forms submitted and completion status

• Referrer source (how you arrived at our site)

• Technical errors encountered

• Login frequency and times

• Documents viewed or downloaded

• Chat interactions and metadata

• Account activity logs

4. SOURCES OF INFORMATION

Clear Path collects information from multiple sources:

• Directly from you: Via contact forms, portal submissions, email, phone calls, SMS, video calls, or in-person meetings

• Automatically from your device: Via cookies, analytics tools, pixels, server logs, and device identifiers

• From service providers: Information you provide to third-party platforms on our behalf (e.g., Assembly.com, Zoho, e-signature providers)

• From referrals or partnerships: Information provided by colleagues, referral partners, or affiliated companies who refer you to Clear Path

• From your communications: Notes, call recordings/transcripts, and message logs stored in our CRM and communication systems (with your consent where required)

5. PURPOSES OF USE

We use the information we collect for the following purposes:

5.1 Core Business Operations

• Responding to inquiries: Replying to your questions and providing information you request

• Evaluating potential client relationships: Assessing fit and conducting due diligence on prospects

• Onboarding and account setup: Creating portal accounts, verifying information, and preparing for service delivery

• Executing agreements: Facilitating e-signature and execution of Service Agreements and Business Associate Agreements

• Providing services: Operating the portal, sending service notifications, billing information, and support communications

• Maintaining business records: Keeping records of client relationships, transactions, and communications for business continuity and legal compliance

5.2 Service Improvement & Security

• Service improvement: Analyzing how prospects and clients use our website and portal to identify enhancements

• Security and fraud prevention: Detecting and preventing fraudulent activity, unauthorized access, and security incidents

• Site operation and maintenance: Ensuring the website and portal remain functional, secure, and reliable

• Performance monitoring: Analyzing site performance, identifying technical errors, and optimizing user experience

• Testing and troubleshooting: Improving features and resolving technical issues

5.3 Legal & Compliance

• Compliance with legal obligations: Meeting HIPAA requirements, responding to lawful requests, and fulfilling regulatory obligations

• Dispute resolution: Maintaining records to address disputes or legal claims

• Tax and accounting: Maintaining records for tax, audit, and accounting purposes

• Regulatory audits: Supporting compliance reviews and regulatory investigations

5.4 Business Communications

• Marketing and outreach: Sending follow-up emails to prospects who started onboarding, informing them of our services

• Blog subscription: Sending blog updates and newsletters to subscribers who have opted in

• Service announcements: Notifying you of important updates, changes, or announcements about Clear Path

• Consent management: Recording and maintaining records of your consent choices for SMS, marketing, and optional communications

6. HOW WE SHARE YOUR INFORMATION

6.1 Categories of Recipients

We may share information with the following categories of third parties:

Service Providers & Data Processors

• Cloud hosting and productivity platforms (Microsoft 365, Microsoft Azure, Outlook, Teams) for data storage, email, file management, and business operations

• Client portal and e-signature providers (Assembly.com, Zoho products, similar platforms) for onboarding, document management, and contract execution

• Analytics providers (Google Analytics and similar tools) for understanding site usage and improving our services

• Email and communication service providers (Microsoft Outlook, Microsoft Teams) for sending and managing business communications

• Customer relationship management (CRM) systems and business software for managing client relationships and business records

• Accounting and bookkeeping software for billing, financial records, and accounting

• Professional advisers (accountants, attorneys, consultants) for business, legal, tax, and compliance matters

Affiliated Entities

• Affiliate companies or sister entities that provide administrative, operational, or support services to Clear Path (including entities located in Canada) are contractually bound to use information only for providing services to us and not for their own independent marketing or purposes

Legal & Compliance

• Law enforcement, regulators, or government entities if required by law, court order, subpoena, or lawful government request

• Parties to business transactions (acquirers, investors, merger/acquisition counterparties) in the event of a merger, acquisition, bankruptcy, or similar corporate transaction

• Other parties with your explicit consent for purposes you authorize in writing

6.2 Data Sharing Practices

Clear Path does not:

• Sell personal information to third parties for their independent marketing or commercial purposes

• Engage in targeted advertising using personal information shared with data brokers

• Share your information with advertising networks or for behavioral profiling by third parties

• Disclose your information for sale or rental to list brokers

Service providers are:

• Contractually required to use information only as necessary to provide services to Clear Path

• Required to maintain appropriate security and confidentiality

• Prohibited from using information for their own purposes unless you have separately consented

7. COOKIES, ANALYTICS & TRACKING TECHNOLOGIES

7.1 What Are Cookies?

Cookies are small files stored on your device that help websites function, remember preferences, and track how you use them. We use several types of cookies:

7.2 Types of Cookies We Use

Essential / Necessary Cookies

• Purpose: Required for site security, user authentication, form completion, portal functionality

• Examples: Session tokens, CSRF protection, login verification

• Consent required? No—these are necessary for the site to function

• Duration: Typically session-based or until logout

Analytics Cookies

• Purpose: Help us understand visitor behavior (pages visited, time spent, referrer source, error tracking)

• Current status: We currently use generic analytics tracking; we will deploy Google Analytics (GA4) or similar tools later in 2026 for detailed insights

• Consent required? Yes for optional analytics—we will request consent via cookie banner

• Duration: Typically 12–24 months; older data is aggregated or deleted per provider policy

• Providers: Google Analytics, Framer analytics, similar tools

Preference Cookies

• Purpose: Store your choices for language, timezone, accessibility settings, or consent preferences

• Consent required? Optional; you can adjust in browser settings

• Duration: Until you clear cookies or change settings

Third-Party Cookies

• Hosting provider (Framer): May set cookies for CDN optimization, performance tracking, security

• Analytics services: May set cookies if enabled

• Embedded content: YouTube, social media widgets, or other embedded services may set third-party cookies

7.3 Cookie Consent & Your Control

• Consent banner: When you first visit our site, a cookie consent banner appears, allowing you to:

  • Accept all cookies

  • Reject optional cookies (analytics, preferences)

  • Customize your choices per category

• Your browser controls: You can manage cookies through your browser settings, including blocking all cookies or specific categories

• Clearing cookies: You can delete all cookies at any time; this may affect site functionality until new cookies are set

• Opting out of analytics: Disable analytics cookies via the consent banner, your browser's do-not-track setting, or opt-out tools provided by analytics vendors

7.4 Similar Technologies

In addition to cookies, we may use:

• Pixels and beacons: Small tracking images that report on page visits, email opens, or form submissions

• Local storage: Browser-based storage similar to cookies, used for site functionality and preferences

• Device identifiers: Unique identifiers assigned to your device or browser

• Server-side tracking: Server logs recording your IP address, user-agent, pages accessed, and timestamps

All of these serve the same purposes as cookies: improving functionality, analytics, security, and performance.

8. DATA SECURITY

8.1 Security Measures

Clear Path implements appropriate safeguards to protect your information:

• Encryption in transit: All data transmitted between your device and our systems is encrypted using TLS 1.2+ protocol (HTTPS)

• Encryption at rest: Sensitive data is encrypted while stored on servers and cloud infrastructure, including encryption provided by Microsoft 365 and Azure

• Access controls: Access to personal information is limited to authorized Clear Path staff and service providers who need it to perform their job functions; we implement role-based access control and least-privilege principles

• Multi-factor authentication (MFA): MFA is required for staff access to systems handling sensitive information

• Staff training: Clear Path staff receive annual training on data protection, information security, HIPAA requirements, and secure handling of business communications

• Security monitoring: We employ automated and manual monitoring to detect, log, and respond to security incidents

• Secure backup and recovery: Regular encrypted backups are maintained with secure recovery procedures

• Incident response plan: Clear Path has procedures in place to respond to, investigate, and report security incidents and breaches

8.2 Limits of Security

While we use industry-standard safeguards, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of all information. You are responsible for:

• Maintaining the confidentiality of your portal login credentials

• Not sharing your password with others

• Logging out of your account when finished

• Notifying us immediately of suspected unauthorized access (contact info@clearpathbillingsolutions.com)

8.3 Data Location & International Access

• Data storage: Personal information is stored exclusively within the United States using cloud infrastructure (Microsoft 365 and Azure)

• International staff access: Authorized Clear Path staff and service providers located outside the United States (including Canada) may access data via secure remote access (encrypted cloud PCs with multi-factor authentication), subject to strict access controls and security agreements

• PHI location: Protected Health Information (PHI) remains stored exclusively within the United States and is never transferred to or stored in systems outside the U.S., in compliance with HIPAA requirements

9. PROTECTED HEALTH INFORMATION (PHI) & HIPAA BUSINESS ASSOCIATE AGREEMENTS

9.1 What This Policy Does Not Cover

This Privacy Policy applies to information collected during pre-contract evaluation and general website use. It does not govern Protected Health Information (PHI) or clinical data.

9.2 PHI Processing Under Business Associate Agreements

Before a Business Associate Agreement is signed:

• Clear Path does not collect, and you should not provide, Protected Health Information (PHI) as defined by HIPAA through the website or portal

• Any PHI inadvertently submitted before BAA execution should be reported to us immediately so we can securely delete it

After a Service Agreement and BAA are signed:

• Any PHI you provide to Clear Path is processed as a HIPAA Business Associate

• PHI handling is governed by:

  • The HIPAA Privacy Rule, Security Rule, and Breach Notification Rule

  • Your signed Business Associate Agreement (BAA) with Clear Path

  • Clear Path's internal HIPAA policies, procedures, and security standards

  • NOT by this general website privacy policy

9.3 HIPAA Rights

If you are a covered entity or your practice is subject to HIPAA:

• Your rights regarding PHI are outlined in your covered entity's Notice of Privacy Practices

• Additional rights regarding PHI processing are outlined in your signed Business Associate Agreement with Clear Path

• Those rights are not outlined in this website privacy policy

• If you have questions about HIPAA rights or PHI handling, refer to your BAA or contact privacy@clearpathbillingsolutions.com

10. DATA RETENTION

10.1 General Retention Principles

We retain personal information for as long as reasonably necessary to:

• Fulfill the purposes for which it was collected

• Maintain business records and honor contractual obligations

• Comply with legal, tax, audit, and regulatory obligations

• Resolve disputes or defend legal claims

• Comply with HIPAA and BAA requirements (where applicable)

10.2 Retention Periods by Data Category

Prospects Who Do Not Sign an Agreement

• Portal submissions and intake forms: Retained for as long as reasonably necessary to evaluate and follow up on your inquiry (typically 90–180 days after your last interaction) and for a limited period thereafter (up to 2–3 years) to support potential future engagement or lead scoring; then securely deleted unless we have a legal obligation to retain longer

• Communication records: Retained according to the timeframes in the categories below

Signed Clients

• Service Agreements and BAAs: Retained for the life of the business relationship plus at least 6–7 years after termination or until a longer period is required by law

• Client portal and account information: Retained while the business relationship is active; after termination, retained for at least 6–7 years for tax, audit, legal, and business records purposes

• PHI-related records: Retained according to HIPAA minimum necessary standards and as specified in your BAA.

Email, Chat, and Business Communications

• General business emails: Retained as long as necessary to operate our business, provide services, manage the client relationship, and comply with legal obligations; we may retain certain communications longer if part of business records, disputes, regulatory compliance, or audit trails

• Portal chat and messages: Retained using the same principles as email communications

• Call notes and recordings: Retained according to the same principles as email communications (you will be notified when calls are recorded)

• SMS messages: Retained for operational purposes (service reminders, account notifications) as long as the business relationship is active; service-related SMS may be retained longer if necessary for disputes, legal compliance, or business records

Website Analytics & Cookies

• Analytics data: Typically retained for 12–24 months; older data is aggregated or deleted per our analytics provider's policies

• Server logs: Typically retained for 90 days for security and troubleshooting purposes

• Cookie data: Retained according to cookie type (session-based, until logout, or per provider policy)

Deletion Requests

• If you request deletion of your information, we will delete or anonymize it within a reasonable timeframe, except where we are required by law, contract, or legitimate business need to retain it (e.g., tax records, dispute resolution, fraud investigation, legal liability)

• We will provide written explanation of any retention exceptions

11. YOUR PRIVACY RIGHTS & CHOICES

11.1 Access

You have the right to request information about what personal information Clear Path holds about you.

How to request:

• Email: privacy@clearpathbillingsolutions.com with subject line "Data Access Request"

• Include sufficient details to locate your information (name, email, phone number, account number if applicable)

• Timeline: We will respond within 30–45 business days (or as required by law)

• We may request verification of your identity to protect your privacy

11.2 Correction & Accuracy

You have the right to request that we correct inaccurate, incomplete, or outdated information.

How to request:

• Email: privacy@clearpathbillingsolutions.com with subject line "Data Correction Request"

• Specify what information should be corrected and why

• Timeline: We will respond within 30–45 business days

• We may verify the correction with you if needed

11.3 Deletion

You have the right to request that we delete your personal information, subject to reasonable exceptions:

• We may retain information if deletion would violate a legal obligation

• We must retain information as part of a business record, contract, tax obligation, or dispute resolution

• We may retain de-identified or aggregated information that cannot be linked back to you

How to request:

• Email: privacy@clearpathbillingsolutions.com with subject line "Data Deletion Request"

• Timeline: We will respond within 30–45 business days and explain any exceptions or limitations

• We may ask you to verify your identity

11.4 Opt-Out of Marketing Communications

If you receive marketing or promotional emails from Clear Path (e.g., follow-up outreach to prospects who started onboarding, or blog subscription emails):

Email marketing:

• Click the "Unsubscribe" link in any marketing email, or

• Contact: info@clearpathbillingsolutions.com or 380-269-4100

Blog subscription:

• Click "Unsubscribe" in the newsletter email, or

• Contact: info@clearpathbillingsolutions.com

Note: We do not currently use SMS for promotional marketing; SMS is used only for transactional service-related messages. You cannot opt out of transactional SMS, but you can disable SMS communications entirely (see Section 11.5 below).

11.5 SMS Communication

Opt-In to SMS

You can enable SMS communications by:

• Checking a consent box on an intake form or portal settings, or

• Verbally consenting during an onboarding call (which we document in our system), or

• Providing your phone number with the understanding that SMS will be used for service-related communications

Opt-Out of SMS

You can opt out of SMS at any time by:

• Replying "STOP" to any SMS message, or

• Contacting: info@clearpathbillingsolutions.com or 380-269-4100

• Timeline: We will process your opt-out within 1–2 business days

SMS Message Frequency

• Typically 1–5 automated messages per month during onboarding and service phases

• Additional messages may be sent if you communicate directly with Clear Path via SMS

• Message and data rates may apply; check with your carrier for SMS plan details

SMS Keywords

• STOP: Reply "STOP" to opt out of future SMS messages

• HELP: Reply "HELP" to request information about how to use SMS or to contact support

11.6 Your State Privacy Rights

Depending on where you live, you may have additional rights under state consumer privacy laws (such as California's CCPA, Colorado's CPA, Connecticut's CTDPA, Virginia's VCDPA, or Delaware's DPDPA). Residents of states with comprehensive consumer privacy laws may have the right to:

• Access: Request and obtain information about personal data we hold

• Correct: Request correction of inaccurate information

• Delete: Request deletion of personal information (subject to reasonable exceptions)

• Opt-out: Opt out of targeted advertising, profiling, or sale of personal information

If you believe you have rights under a state privacy law:

• Email: privacy@clearpathbillingsolutions.com

• Indicate your state of residence and specify your request clearly

• Timeline: We will respond within 30–45 business days (or as required by law)

• We will honor applicable rights to the extent required by law

11.7 How to Exercise Your Rights

Submit a Request

• Email: privacy@clearpathbillingsolutions.com with a clear description of your request

• Mailing address: Clear Path Billing Solutions Inc., 8 The Green # 20081, Dover, DE 19901, United States

• Phone: 380-269-4100

Timeline

• We will respond to verified requests within 30–45 business days (or as required by applicable law)

Verification

• We may ask you to verify your identity by providing information that matches our records

• Verification protects your privacy and ensures we respond to authorized requests

No Discrimination

• We will not discriminate against you for exercising your privacy rights

• We will not deny, charge different prices for, or provide different service or quality of service based on your exercise of privacy rights

• Exception: We may offer incentive programs where you consent to collection and use of personal information

12. CHILDREN'S PRIVACY

Clear Path's website and services are not directed to children under 13. We do not knowingly collect personal information from children under 13.

If you are under 13: Do not use our services. If you have provided information to Clear Path, contact us immediately so we can delete it.

If you are a parent or guardian: If you believe we have collected information about a child under 13, please contact us immediately at privacy@clearpathbillingsolutions.com, and we will delete the information.

Clear Path complies with the Children's Online Privacy Protection Act (COPPA) and does not knowingly collect, solicit, or market to children under 13.

13. THIRD-PARTY LINKS & SERVICES

Our website and portal may contain links to third-party websites and services (vendor sites, integrations, external resources, or social media). This Privacy Policy applies only to Clear Path's website and portal.

We are not responsible for:

• The privacy practices of third-party sites

• The content, accuracy, or security of third-party services

• Your use of third-party links or services

Your responsibility:

• We encourage you to review the privacy policies and terms of service of any third-party sites before providing your information

• Your use of third-party sites is governed by their own terms, not by this policy

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect:

• Changes in our data practices or technology

• Legal requirements or regulatory changes

• Service improvements or new features

• User feedback

14.1 How We Notify You

• Updated effective date: The "Last Updated" date at the top of this policy will change

• Prominent notice: Material changes will be prominently posted on our website

• Email notification: For material changes that significantly affect your privacy rights or how we use your information, we may email you at the address associated with your account

• Your continued use: Your continued use of the website and portal after changes are posted constitutes your acceptance of the updated policy

14.2 Material Changes

Material changes are those that significantly affect:

• Your privacy rights or how we collect information

• How we use or share your information

• Your choices regarding your information

15. CONTACT US FOR PRIVACY QUESTIONS

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact:

Privacy Inquiries:

• Email: privacy@clearpathbillingsolutions.com

• Phone: 380-269-4100

General Inquiries:

• Email: info@clearpathbillingsolutions.com

• Phone: 380-269-4100

Mailing Address:
Clear Path Billing Solutions Inc.
8 The Green # 20081
Dover, DE 19901
United States

We will respond to your inquiry within a reasonable timeframe, typically within 5–10 business days for general questions and 30–45 days for formal privacy rights requests.

END OF PRIVACY POLICY