Terms, privacy, and consent.

ClearPath GI LLC

DRAFT FOR COUNSEL REVIEW — NOT EFFECTIVE UNTIL COUNSEL APPROVAL AND PUBLICATION.
This draft reflects product and operations decisions as of 2026-07-24. It is not legal advice.

Version: 3.0-DRAFT — Reminder + Care Outreach
Effective Date: [Counsel to set upon approval]
Entity: ClearPath GI LLC, a Georgia limited liability company
Address: 1956 Aquinas Ct, Marietta, GA 30064
Contact: support@clearpathgi.com

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NOTICE: CLEARPATH GI IS NOT A MEDICAL PROVIDER. This platform provides colonoscopy screening reminders and optional connections to participating healthcare organizations (Care Outreach). It does not provide medical advice, diagnosis, or treatment, and is not connected to any electronic health record system. All reminder schedules are based solely on information you provide. In a medical emergency, call 911 immediately.

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1. AGREEMENT TO TERMS

These Terms of Service ("Terms") constitute a legally binding agreement between you ("Member," "you," or "your") and ClearPath GI LLC ("ClearPath GI," "Company," "we," "us," or "our"). By creating an account, enrolling in the service, accessing the website at clearpathgi.com (the "Site"), or using any feature of the ClearPath GI platform (collectively, the "Service"), you agree that you have read, understood, and agree to be bound by these Terms in their entirety.

If you do not agree to these Terms, you must not use the Service.

These Terms should be read together with our Privacy Policy, which is incorporated herein by reference. Both documents are available at clearpathgi.com/legal.

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2. ELIGIBILITY

To use the Service, you must:

(a) Be at least 18 years of age.

(b) Reside in (and enroll with a verifiable ZIP / city / state within) one of the following U.S. states only:

Alabama (AL), Arkansas (AR), Florida (FL), Georgia (GA), Kansas (KS), Kentucky (KY), Louisiana (LA), Missouri (MO), Mississippi (MS), North Carolina (NC), Ohio (OH), Oklahoma (OK), South Carolina (SC), Tennessee (TN), Texas (TX), West Virginia (WV).

Enrollment from outside this service area will be declined. The Service is not available nationwide.

(c) Provide accurate, current, and complete information during enrollment and maintain the accuracy of that information at all times.

(d) Not be prohibited by applicable law from receiving the Service.

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3. DESCRIPTION OF SERVICE

3.1 What ClearPath GI Does

ClearPath GI provides a free, voluntary screening reminder service for members and a Care Outreach tool for participating healthcare organizations. Based solely on information you provide during enrollment, the Service:

• Schedules and delivers automated reminders about your next colonoscopy screening via SMS and/or email at timing intervals you select;
• Maintains a secure member dashboard where you can view, update, or manage your reminder preferences and contact information; and
• Facilitates optional connections between you and participating healthcare organizations in your area, subject to your explicit written consent and that organization's signed Business Associate Agreement with ClearPath GI.

3.2 What ClearPath GI Does NOT Do

ClearPath GI:

• Is not a medical provider, physician, hospital, practice, or licensed healthcare facility.
• Does not connect to, access, or retrieve data from any EHR, insurance database, or other clinical system.
• Does not determine when your next colonoscopy should be scheduled.
• Does not guarantee scheduling, appointments, or access to any specific healthcare provider.
• Does not monitor your health status and will not alert you or anyone else if you miss a reminder or fail to complete your screening.

3.3 Service Availability

The Service is provided on an "as is" and "as available" basis. We do not guarantee uninterrupted access. We reserve the right to modify, suspend, or discontinue any aspect of the Service at any time, with or without notice.

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4. ACCOUNT REGISTRATION AND SECURITY

4.1 Enrollment

To use the Service, you must complete enrollment, providing your full legal name, date of birth, phone number, email address (optional), ZIP code / city / state, and your next due month and year. Your phone number is verified via a one-time passcode (OTP) at enrollment.

4.2 Dashboard Login

After enrollment, your member dashboard is accessed through passwordless login using your verified phone number or email address and a one-time passcode. You are responsible for maintaining the security of your account access.

4.3 Account Lockout and Identity Verification

If you cannot access your dashboard because the information you provide does not match our records, contact privacy@clearpathgi.com. We may require a government-issued photo ID before restoring access.

4.4 Responsibility for Account Activity

You are solely responsible for all activities under your account. If you believe your account has been accessed without authorization, contact support@clearpathgi.com immediately.

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5. YOUR RESPONSIBILITY TO KEEP INFORMATION CURRENT

THIS IS A CRITICAL PROVISION. PLEASE READ CAREFULLY.

ClearPath GI sends reminders and facilitates care coordination based exclusively on the information you provide. You are solely responsible for keeping contact information, location, and screening timing accurate and up to date.

ClearPath GI is not liable for consequences arising from your failure to update outdated information, including reminders sent to old phone numbers or emails, organizations matched to an old ZIP/city, or continued reminders after you complete a procedure without updating your dashboard.

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6. SMS COMMUNICATIONS

6.1 Consent to Receive SMS

By consenting to SMS communications at enrollment, you agree to receive recurring automated text messages from ClearPath GI at the mobile number you provide, including one-time passcodes (OTPs), screening reminders, and service notifications.

Messages are sent from toll-free number +1 (877) 335-2167 (Toll-Free Verification with carriers may be pending or completed — confirm status before launch). Message and data rates may apply.

6.2 Opt-Out

Text STOP to +1 (877) 335-2167 at any time. You will receive one final confirmation message and no further SMS unless you re-consent. Opting out of SMS does not delete your account or affect email reminders.

6.3 Help

Text HELP to +1 (877) 335-2167, or email support@clearpathgi.com.

6.4 No PHI in SMS Message Bodies

SMS message bodies will not contain your name, procedure date, or clinical details. Messages notify you that a reminder or account notice is available and direct you to log in to your secure dashboard. Your phone number is necessarily used as the delivery destination.

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7. EMAIL COMMUNICATIONS

7.1 Consent to Receive Email

By providing your email address and consenting to email communications, you agree to receive automated emails including OTPs, reminders, and service-related updates.

7.2 Opt-Out

Click Unsubscribe in any reminder email, or update your preferences in your dashboard. Unsubscribing from reminders does not delete your account or affect SMS reminders.

7.3 No PHI in Email Message Bodies

Email bodies will not contain clinical details, procedure dates, or your name in the reminder content. Emails direct you to log in to your secure dashboard to view reminder details. Your email address is necessarily used as the delivery destination.

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8. GEOGRAPHIC LIMITATIONS AND PRACTICE AVAILABILITY

8.1 Service Area

Member reminder functionality is available only in the sixteen (16) states listed in Section 2(b).

8.2 Practice Network Limitations

Participating Care Outreach organizations may not exist in every ZIP or city within the service area. Reminder delivery does not depend on a participating practice being nearby. If no participating organization covers your area, reminders still function, but no practice will receive your shared record.

8.3 No Guarantee of Practice Contact

Enrollment does not guarantee that any healthcare organization will contact you, accept you as a patient, or schedule you for a procedure.

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9. DATA SHARING WITH HEALTHCARE ORGANIZATIONS

9.1 Consent-Based Only

ClearPath GI shares your information with participating healthcare organizations only with your explicit written consent.

9.2 BAA Required

Organizations must also have an active, signed Business Associate Agreement with ClearPath GI before they can see any patient details. Consent alone is not sufficient.

9.3 What Organizations May See

If you consent to data sharing, healthcare organizations holding an active Care Outreach agreement for your ZIP code or city and an active BAA may view your name, phone number, ZIP code, city, state, and next screening month/year to contact you about scheduling. They do not receive your email address or date of birth through Care Outreach.

9.4 Your Record Reflects What You Tell Us

Participating organizations see only the information you have entered. ClearPath GI is not responsible for the accuracy of information you have not updated.

9.5 Revocation

You may revoke data-sharing consent at any time through your member dashboard. Revocation takes effect immediately for future access. Past access cannot be retroactively revoked.

9.6 Deleted Accounts

If you delete your account, your record is removed from all organization-facing views immediately. Deleted records are retained internally for ten (10) years for compliance purposes and are not accessible to any participating organization during that period.

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10. INTELLECTUAL PROPERTY

The Service is owned by ClearPath GI and protected by applicable intellectual property laws. You are granted a limited, non-exclusive, non-transferable, revocable license to access and use the Service for personal, non-commercial use only.

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11. PROHIBITED CONDUCT

You agree not to: use the Service for any unlawful purpose; provide false or misleading information; attempt to access another member's account; interfere with the security or availability of the Service; use automated scripts or scrapers; transmit harmful code; use the Service to harass or harm any person; reverse-engineer any portion of the Service; or use the Service for unauthorized commercial purposes.

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12. ACCOUNT TERMINATION AND DELETION

12.1 Your Right to Delete

You may delete your account at any time through your dashboard or by contacting privacy@clearpathgi.com.

12.2 Retention After Deletion

Following deletion, ClearPath GI retains your health information for ten (10) years from the date of deletion or last account activity, whichever is later. After this period, records are securely destroyed or permanently de-identified, except where a legal hold applies.

12.3 Our Right to Suspend or Terminate

ClearPath GI reserves the right to suspend or terminate your access at any time, with or without notice, for any reason including violation of these Terms.

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13. DISCLAIMER OF WARRANTIES

THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE," WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, UNINTERRUPTED AVAILABILITY, OR ACCURACY OF CONTENT.

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14. LIMITATION OF LIABILITY

TO THE MAXIMUM EXTENT PERMITTED BY LAW, CLEARPATH GI SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, PUNITIVE, OR SPECIAL DAMAGES OF ANY KIND, INCLUDING DAMAGES ARISING FROM: MISSED REMINDERS OR SCREENINGS; ACTIONS OR INACTIONS OF PARTICIPATING ORGANIZATIONS; YOUR FAILURE TO MAINTAIN CURRENT ACCOUNT INFORMATION; UNAUTHORIZED ACCOUNT ACCESS; OR ACTS OF THIRD-PARTY SERVICE PROVIDERS.

BECAUSE THE SERVICE IS FREE TO MEMBERS, CLEARPATH GI'S TOTAL CUMULATIVE LIABILITY FOR ANY CLAIM SHALL NOT EXCEED ONE HUNDRED DOLLARS ($100.00).

COUNSEL FLAG: Enforceability of liability caps, class-action waivers, and one-year claim periods for a free consumer health-adjacent service should be confirmed for Georgia and the sixteen serviced states.

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15. INDEMNIFICATION

You agree to indemnify, defend, and hold harmless ClearPath GI from and against any claims, liabilities, damages, and expenses arising out of your violation of these Terms, your use of the Service, your provision of false information, or your violation of applicable law.

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16. CLASS ACTION WAIVER

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, ALL CLAIMS MUST BE BROUGHT IN YOUR INDIVIDUAL CAPACITY. YOU WAIVE ANY RIGHT TO PARTICIPATE IN A CLASS ACTION, COLLECTIVE ACTION, OR REPRESENTATIVE PROCEEDING AGAINST CLEARPATH GI.

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17. GOVERNING LAW

These Terms are governed by the laws of the State of Georgia, without regard to conflict-of-law principles.

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18. DISPUTE RESOLUTION

Disputes that cannot be resolved informally shall be submitted exclusively to the Superior Court of Cobb County, Georgia, or the United States District Court for the Northern District of Georgia (Atlanta Division). All claims must be brought within one (1) year of when they arose, to the extent permitted by law.

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19. MODIFICATIONS

ClearPath GI may modify these Terms at any time. Material changes will be communicated by updating this document and, where required, by email or SMS notification and re-consent workflows. Continued use of the Service after notice constitutes acceptance of modifications where permitted by law.

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20. GENERAL PROVISIONS

20.1 Entire Agreement. These Terms, the Privacy Policy, and enrollment consents constitute the entire agreement between you and ClearPath GI regarding the Service.

20.2 Severability. If any provision is found invalid, the remaining provisions remain in full force.

20.3 Waiver. Failure to enforce any provision does not constitute a waiver.

20.4 No Assignment. You may not assign rights under these Terms without our written consent.

20.5 Force Majeure. ClearPath GI is not liable for delays caused by circumstances beyond our reasonable control.

20.6 Notices. Notices to ClearPath GI: support@clearpathgi.com or 1956 Aquinas Ct, Marietta, GA 30064.

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21. CONTACT INFORMATION

General: support@clearpathgi.com
Privacy and HIPAA: privacy@clearpathgi.com
Practice and Organization: clinic@clearpathgi.com
Mail: ClearPath GI LLC, 1956 Aquinas Ct, Marietta, GA 30064

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Version 3.0-DRAFT — For counsel review only. Not legal advice.

COUNSEL FLAG — AKS / STARK: The Care Outreach model (paid organization access to a consented member reminder database by geography) must be formally reviewed for Anti-Kickback Statute and Stark Law compliance before executing any organization agreements.

COUNSEL FLAG — HIPAA ROLE: Confirm ClearPath’s classification for independent member enrollments before first production PHI.

ClearPath GI LLC

DRAFT FOR COUNSEL REVIEW — NOT EFFECTIVE UNTIL COUNSEL APPROVAL AND PUBLICATION.
This draft reflects product and operations decisions as of 2026-07-24. It is not legal advice.

Version: 3.0-DRAFT — Reminder + Care Outreach
Effective Date: [Counsel to set upon approval]
Privacy Officer: David Anderson (Platform Administrator)
Security Officer: David Anderson (same individual — small-entity designation)
Privacy Contact: privacy@clearpathgi.com
Address: 1956 Aquinas Ct, Marietta, GA 30064

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Notice to Members: This Privacy Policy describes how ClearPath GI LLC collects, uses, stores, and shares your information when you use our colonoscopy screening reminder service and optional Care Outreach connections with participating healthcare organizations. Because this service involves health information, certain information you provide is Protected Health Information (PHI) under HIPAA. Please read this policy carefully.

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0. COUNSEL DECISIONS STILL OPEN (DO NOT PUBLISH THIS SECTION)

#	Question	Options for counsel
A	HIPAA role for independent enrollments (no clinic partner)	(1) Business Associate only when acting for a CE; (2) hybrid “BA + consumer privacy steward”; (3) other. Public label “data steward” is provisional.
B	Is Auth0/Okta a Business Associate?	Company intends BAAs only with Convex and Vercel. Auth0 receives phone/email for OTP login.
C	Are Twilio / Resend Business Associates?	Design goal: no PHI in SMS/email bodies (generic notice + login link). Phone/email identifiers are still disclosed to vendors. Conduit analysis needed.
D	Should this document be titled “Notice of Privacy Practices” or “Privacy Policy”?	Especially if ClearPath is not a Covered Entity for the direct-enrollment path.
E	State overlays for the 16 serviced states	See docs/legal/COUNSEL_REVIEW_PACKET.md.

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1. WHO WE ARE

ClearPath GI LLC ("ClearPath GI," "we," "us," or "our") is a Georgia limited liability company operating a voluntary colonoscopy screening reminder platform and, for participating healthcare organizations, a Care Outreach coordination tool.

We are not a covered healthcare provider, health plan, healthcare clearinghouse, electronic health record (EHR) vendor, or insurer. We do not provide medical advice, diagnosis, or treatment. We do not access or connect to any EHR or insurance system.

HIPAA role (provisional — see §0):

• When a covered healthcare organization partners with us for Care Outreach features that use member contact information for scheduling coordination, we intend to act as that organization's Business Associate under HIPAA and require a signed BAA before any patient details are visible to that organization.
• When you enroll independently of any practice relationship, we still treat your health-related information as sensitive, apply the safeguards in this Policy, and seek counsel confirmation of the correct legal classification before first production use.

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2. SERVICE AREA

Enrollment is limited to members with a verifiable ZIP / city / state in the following U.S. states:

AL, AR, FL, GA, KS, KY, LA, MO, MS, NC, OH, OK, SC, TN, TX, WV.

Enrollment outside this service area is declined. Care Outreach practice availability within a serviced state is not guaranteed for every ZIP or city.

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3. INFORMATION WE COLLECT

3.1 Information You Provide at Enrollment

Category	Examples	HIPAA Status
Identity	Full legal name, date of birth	PHI
Contact	Phone number, email address	PHI
Location	ZIP code, city, state	PHI
Clinical scheduling	Next colonoscopy month and year	PHI

3.2 Information Generated by the Service

• Account activity: login timestamps, dashboard updates, consent and opt-out records;
• Communication records: logs of SMS and email messages sent, delivery status (not full clinical content in outbound vendor bodies);
• Audit logs: actions taken on your account, including by ClearPath GI administrative personnel;
• Reminder records: scheduled and sent reminders, timing, and channel;
• Consent evidence: document version, timestamp, IP address, and user agent associated with consent events.

3.3 Technical Information

• Browser and device data: IP address, browser type, operating system (used for security and rate-limiting);
• Session tokens: authentication sessions managed via Auth0 and ClearPath-controlled session cookies;
• Cookies: strictly necessary session cookies required for authentication. See Section 8.

We do not use Google Analytics, Meta Pixel, advertising cookies, tracking pixels, Sentry (or similar third-party error trackers that would receive production PHI), or any behavioral marketing technology on any portion of our Site.

We do not collect diagnosis codes, clinical notes, insurance identifiers, Social Security numbers, or payment card / bank account numbers from members.

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4. HOW WE USE YOUR INFORMATION

We use your information for the following purposes only:

(a) Delivering the Service: Scheduling and sending screening reminders via SMS and/or email at your selected intervals.

(b) Identity Verification: Sending one-time passcodes (OTPs) to verify your phone number or email at enrollment and login.

(c) Care Coordination: When you provide explicit consent, sharing your information with participating healthcare organizations so they may contact you about scheduling your screening.

(d) Account Management: Maintaining your dashboard, processing account updates, and responding to your requests.

(e) Security and Fraud Prevention: Monitoring for unauthorized access, applying rate limits, and maintaining platform integrity.

(f) Legal Compliance: Retaining records as required by HIPAA and applicable law; responding to lawful legal process; breach investigation and notification.

(g) Internal Improvement: Aggregated, de-identified usage data may be used internally to improve the platform. We do not use individually identifiable PHI for this purpose.

We do not use your information for advertising or marketing to third parties. We do not sell your personal information or PHI.

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5. HOW WE SHARE YOUR INFORMATION

5.1 With Healthcare Organizations — With Your Consent Only

With your explicit written consent, and only to organizations that hold an active, signed Business Associate Agreement with ClearPath GI plus an active Care Outreach agreement covering your ZIP code or city, we may share:

• Full name
• Phone number
• ZIP code, city, and state
• Next screening due date month and year (as entered by you)

We do not share your email address or date of birth with healthcare organizations through Care Outreach.

If you revoke your data-sharing consent, all participating organizations immediately lose access to your record going forward. Past access cannot be retroactively withdrawn.

5.2 With Infrastructure Vendors (Subprocessors)

Vendor	Purpose	Planned BAA / classification
Convex, Inc.	Database and backend (stores PHI)	BAA planned / to be executed
Vercel, Inc.	Application hosting (processes PHI in transit)	BAA planned / to be executed
Auth0 (Okta)	Identity and authentication (phone/email for OTP and staff login)	No BAA planned — counsel to classify
Twilio Inc.	SMS delivery (phone as destination; no PHI in message body by design)	No BAA planned — counsel to confirm conduit posture
Resend	Email delivery (email as destination; no PHI in message body by design)	No BAA planned — counsel to confirm conduit posture
Mapbox	Organization facility address geocoding only (not used for member ZIP/city selection)	Not a BA — no patient PHI by design

Message-content rule: Outbound SMS and email reminder bodies contain a generic notice and a secure login link only. They do not include your name, date of birth, procedure date, or other clinical details. Screening details are available only after you authenticate to your dashboard. Admin-editable templates are subject to this rule; violating content must not be published.

Identifier disclosure: Your phone number or email address is necessarily disclosed to Twilio or Resend to deliver the message. OTP flows similarly disclose the destination identifier to Auth0 and/or Twilio Verify.

5.3 As Required by Law

We may disclose your information when required by valid court order, subpoena, search warrant, or other lawful legal process, or to comply with mandatory reporting obligations.

5.4 Business Transfers

If ClearPath GI is acquired or transfers its assets, your information may be transferred as part of that transaction, subject to the incoming entity's agreement to honor this Privacy Policy and applicable HIPAA obligations.

5.5 No Sale of Data

ClearPath GI does not sell, rent, broker, or otherwise transfer your personal information or PHI to any third party for commercial or marketing purposes, under any circumstances.

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6. DATA RETENTION

Category	Retention Period
PHI and health-related records	10 years from account deletion or last activity, whichever is later
Account metadata (non-PHI)	As required for legal, audit, and security purposes
Audit / communication / reminder records	Target 10 years (on-platform rolling retention plus off-platform archive where configured)
Disclosure accounting ledger and consent evidence	10 years from account deletion (with the regulatory archive), then securely destroyed; exceeds the HIPAA ≥6-year accounting floor

After the applicable retention period, records are securely destroyed or permanently de-identified, except where a legal hold applies.

Following account deletion: Your record is immediately removed from all organization-facing dashboards. New Care Outreach disclosures stop. Deleted records (including historical disclosure and consent evidence for that account) are retained internally for the periods above and are accessible only to ClearPath GI administrative personnel for compliance purposes. They are not shared with any healthcare organization after deletion.

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7. DATA SECURITY

ClearPath GI implements the following safeguards:

• Encryption in transit: TLS (HTTPS) for all communications. HSTS and Content Security Policy (CSP) headers enforced.
• Encryption at rest: Selected PHI fields (name, date of birth, phone, email) encrypted using AES-256-GCM field-level encryption, in addition to Convex platform-level encryption. Location and screening month/year used for matching may be stored in indexed form for Care Outreach matching.
• Access controls: Platform administrative access is limited to authorized administrators. Organization access to patient details requires an active BAA and is logged.
• Authentication: Passwordless OTP via Auth0 for members; staff portals use Auth0 Universal Login with MFA required for production organization and admin access.
• Session management: Sessions expire automatically after 15 minutes of inactivity.
• Rate limiting: Automated limits on sensitive operations.
• Audit logging: Significant actions on member records are logged.
• Incident response: Written incident / breach response procedures are maintained for counsel review (docs/compliance/INCIDENT_RESPONSE_SOP.md — draft).

No system is completely secure. If you believe your account has been compromised, contact privacy@clearpathgi.com immediately.

Breach Notification: In the event of a security breach affecting your PHI, we will notify you in accordance with HIPAA's Breach Notification Rule (45 C.F.R. Part 164, Subpart D) and applicable state breach notification laws in our service area.

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8. COOKIES AND TRACKING

8.1 Types of Cookies We Use

Strictly Necessary Cookies: Session cookies and local storage entries required to keep you signed in and operate core security features. These cannot be disabled without breaking the Service.

We do not use: advertising or retargeting cookies; social media tracking pixels; Google Analytics or similar behavioral analytics; any third-party marketing tracking.

8.2 Managing Cookies

You may manage cookies through your browser settings, but disabling strictly necessary cookies may prevent you from using the Service.

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9. YOUR RIGHTS

9.1 HIPAA Privacy Rights (as applicable)

(a) Right to Access: You may request access to and a copy of your PHI. Contact privacy@clearpathgi.com.

(b) Right to Correct / Amend: Update most fields anytime in your member dashboard. If you believe information you cannot change yourself is inaccurate or incomplete, email privacy@clearpathgi.com. We acknowledge requests within 5 business days and respond within 60 days (or as required by law).

(c) Right to an Accounting of Disclosures: You may request a list of disclosures of your PHI for up to the ten (10) years prior to your request (while those records remain in the regulatory archive), subject to applicable exceptions. After the retention period, archived records for a deleted account are securely destroyed.

(d) Right to Restrict Disclosures: You may request restrictions on certain uses or disclosures. Care coordination sharing may be revoked immediately through your dashboard.

(e) Right to Confidential Communications: You may request that we communicate with you by a specific means. Contact privacy@clearpathgi.com.

(f) Right to File a Complaint: You may file a complaint with our Privacy Officer at privacy@clearpathgi.com or with the U.S. Department of Health and Human Services Office for Civil Rights at hhs.gov/hipaa/filing-a-complaint. We will not retaliate against you for filing a complaint.

9.2 General Privacy Rights

• Update your information through your member dashboard.
• Delete your account through your dashboard or by contacting us.
• Revoke consent for SMS, email, or data sharing as described in the applicable consent document.

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10. CHILDREN'S PRIVACY

The Service is not directed to individuals under 18. We do not knowingly collect personal information from anyone under 18. If we learn we have inadvertently done so, we will promptly delete it.

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11. CHANGES TO THIS POLICY

We may update this Privacy Policy to reflect changes in our practices, the law, or our services. Material changes will be communicated by updating this document and, where required, by email or SMS notification and re-consent workflows.

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12. CONTACT AND PRIVACY REQUESTS

Privacy Officer / Security Officer: David Anderson
Email: privacy@clearpathgi.com
Mail: ClearPath GI LLC, Attn: Privacy Officer, 1956 Aquinas Ct, Marietta, GA 30064

We acknowledge requests within 5 business days and respond within the timeframes required by applicable law.

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Version 3.0-DRAFT — For counsel review only. Not legal advice. Do not publish until counsel approval and consent-artifact republication.