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Privacy Policy

ClearPath Treatment Solutions Privacy Policy

This Privacy Policy (“Policy”) describes how ClearPath Treatment Solutions (“ClearPath,” “us,” “we,” or “our”) collects, uses, discloses, and protects your Personal Data. It also informs you about the rights and choices you have with respect to your Personal Data and how you can contact us with questions. Please note, our privacy practices are subject to the applicable laws of the jurisdictions in which we operate. As used in this Policy, Personal Data means information that identifies you or your household, directly or indirectly, by reference to identifiers such as your name, identification number, location data, online identifier, one or more factors specific to your physical, physiological, genetic, mental, economic, cultural, commercial, professional, or social identity, or any other such data defined under applicable law as “personal data” (or the equivalent thereof). ClearPath Treatment Solutions connects individuals seeking addiction treatment services with treatment facilities and rehab centers that can provide appropriate care. To do so, ClearPath collects Personal Data that you provide through forms on our website (“Site”), through phone calls to our call center, or through our targeted advertising campaigns. Our Site and ClearPath’s ability to connect you with treatment facilities are collectively referred to herein as the “Services.” This Policy applies to our Site and all Services we provide.

Categories and Sources of Personal Data

From You Directly

When you fill out a form on our Site, call our specialized call center, or respond to our advertising campaigns requesting information about addiction treatment services, we collect the following Personal Data:

  • Identifiers – including name, address, email address, phone number, date of birth, and zip code
  • Consumer Health Data – We may ask you about substance use history, mental health conditions, co-occurring disorders, treatment history, current medications, and other health information relevant to determining appropriate treatment options. For example, we may ask about the substances being used, duration of use, previous treatment attempts, and immediate safety concerns.
  • Personal Records – including medical information, insurance information (including insurance provider, policy number, and coverage details), treatment preferences, and information about your treatment needs and goals.
  • Characteristics of protected classifications under state or federal law – including gender, marital status, veteran status, and pregnancy status
  • Sensitive Personal Data – such as information collected and analyzed concerning your health, substance use, and mental health status. We only collect sensitive personal data, as defined by applicable privacy laws, for the purposes allowed by law or with your consent. We do not collect or process sensitive Personal Data for the purpose of inferring characteristics about you.
  • Household and Financial Information – such as household income, number of dependents, employment status, and ability to pay for treatment services
  • Emergency Contact Information – including names and contact details of family members or other emergency contacts

Information We Collect Automatically

We and our third-party partners (such as advertising networks, analytics providers, and social media platforms) use tools such as cookies, pixels, and other similar technologies to automatically collect Internet or other electronic network activity information from devices you use while using our Services or interacting with emails or advertisements we may send to you. This information typically includes:

  • IP address
  • Geolocation
  • Browser type and version
  • Browser plug-in details
  • Browsing history
  • Operating system
  • Local time zone
  • Your interaction with our Site including date and time of each visitor request (e.g., web pages visited, forms completed, and time spent on each page)
  • Referring site and/or search engine
  • Device type (e.g., desktop, laptop, tablet, phone)
  • Language preference
  • Click and conversion data from our advertising campaigns

We also allow third parties to use online tracking technologies on our Site for analytics and advertising, including to tailor advertisements to your interests which may appear on our Site, on other websites, or in our communications. To the extent these online tracking technologies are deemed to be a “sale” or “sharing” under applicable U.S. state laws, you can opt-out as described under the section of this Policy titled “Exercising Your Right to Opt-Out of Sale, Share, and Targeted Advertising.”

Technology-Driven Operations

Clear Path leverages a modern, HIPAA-compliant tech stack—CallTrackingMetrics for call management, Salesforce for detailed lead tracking, and Google Ads, Facebook, SEMRush, and Ahrefs for SEO and campaign optimization—enabling our marketing and call center teams to drive targeted ad spend and deliver measurable results for your rehab facility.

How We Use the Personal Data We Collect

We use the above Personal Data for the following purposes:

  • To provide our Services, including connecting you with treatment facilities that can provide addiction treatment services appropriate for your needs
  • To pre-assess your treatment needs and verify your insurance coverage with your insurance provider
  • To facilitate admission to a treatment facility, including arranging travel and transportation to the facility
  • To communicate with you by phone (including through automated calling, live operators, or recorded messages), text messages, email, or postal mail regarding your treatment inquiry and available treatment options
  • To provide you with information about treatment facilities, programs, and services that may be of interest to you
  • To coordinate with treatment facilities on your behalf and facilitate warm transfers to appropriate facilities
  • To develop, maintain, and improve our Services and call center operations
  • For testing, research, analysis, and product development to better serve individuals seeking treatment
  • To detect, deter, prevent, or take action regarding incidents such as suspected fraud, malicious or illegal activities, or violations of our policies
  • To comply with legal and regulatory requirements, including HIPAA where applicable
  • Otherwise with your consent

How We Disclose Your Personal Data

We disclose your Personal Data to the following parties:

 

To Treatment Facilities and Providers

When you submit a request for treatment information through our Site, call our call center, or respond to our advertising, you:

  • Direct us to share your Personal Data with treatment facilities, rehab centers, detox programs, sober living facilities, and other addiction treatment providers in our network
  • Agree that we and treatment facilities in our network may contact you by phone (including through automated calling, live operators, or using recorded messages), text messages, email, or postal mail to discuss treatment options, verify insurance, facilitate admission, and provide follow-up care information, even if you have opted into the National Do Not Call List or any similar opt-out mechanism
  • If you later wish not to be contacted by any specific treatment facility, you will need to contact that facility directly (read the facility’s privacy policy to learn how to exercise your privacy choices with that provider)

Insurance Verification Services

We share your Personal Data with insurance verification services to confirm your insurance coverage, benefits, and eligibility for treatment services.

 

Our Service Providers and Contractors

We use trusted service providers and contractors to help us provide, improve, protect, and market our Services. These may include:

    • Call center technology and telecommunication providers
    • CRM and lead management systems (such as Salesforce)
    • Call tracking and analytics services (such as CallTrackingMetrics)
    • Advertising platforms (such as Google Ads and Facebook Ads)
    • Travel arrangement and transportation coordination services
    • Data analytics and business intelligence providers
    • IT security and infrastructure providers

These service providers may have access to your Personal Data to perform services on our behalf and are contractually obligated to protect your information.

 

To Comply with Legal Processes or Enforce Our Rights

We may disclose your Personal Data when necessary to:

  • Conform to legal requirements or comply with legal process
  • Respond to lawful requests from public authorities, including to meet national security or law enforcement requirements
  • Enforce or apply our Terms of Service and other agreements
  • Protect the rights, safety, or property of ClearPath, our service providers, our users, or the public
  • Address immediate safety or health concerns

As Part of a Merger or Sale of Business

We may disclose your Personal Data in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

 

Sale, Share, and Targeted Advertising

Our Services operate as a lead generation platform for addiction treatment facilities. When you request information about treatment services, we sell or share your Personal Data—including your Identifiers, Consumer Health Data, Personal Records, Characteristics of protected classifications, and household information—with treatment facilities and providers to help connect you with appropriate care. These facilities may be addiction treatment centers, detox programs, sober living facilities, mental health treatment providers, or other entities that provide or facilitate addiction treatment services. These providers, or their affiliates, may contact you based on the consent you have provided.

 

You may opt out of the selling of this Personal Data by exercising your opt-out rights as disclosed below.

 

Further, as explained in the section titled “Information We Collect Automatically,” our Site shares your Personal Data with third-party analytics providers and advertising networks for targeted advertising purposes. This disclosure of data may be deemed a “sale” or “share” of Personal Data under applicable state privacy laws. You may opt out of the selling and sharing of this Personal Data by exercising your opt-out rights as described in the section titled “Exercising Your Right to Opt-Out of Sale, Share, and Targeted Advertising.”

Your Personal Data Rights

You may have certain rights and choices regarding our processing of your Personal Data. Depending on your jurisdiction, applicable law may entitle you to additional consumer rights, including the right:

  • To know the categories and/or specific pieces of Personal Data collected about you, including the source of your Personal Data, whether your Personal Data is sold or disclosed, the purpose for collection, and with whom your Personal Data was disclosed
  • To request deletion of Personal Data, if permissible by law
  • To correct inaccurate Personal Data we retain about you
  • To opt-out of “sale” and/or “share” of your Personal Data, targeted advertising, and profiling
  • To limit the use of your sensitive Personal Data
  • To nondiscrimination based on the exercise of your privacy rights
  • To appeal a decision regarding your request

Exercising Your Right to Know, Delete, and Correct

Depending on where you live, you may exercise the right to know (sometimes also referred to as the right to access), delete, and correct your Personal Data. To do so, please contact us at:

 

Exercising Your Right to Opt-Out of Sale, Share, and Targeted Advertising

Depending on where you reside, you can opt-out of:

  1. The sale of your Personal Data to treatment facilities, providers, and other entities in our network by contacting us using the information above
  2. Our use of online tracking technologies for targeted advertising by contacting us using the information above or by adjusting your browser settings

Please note that some features of our Site may not be available to you if you opt out. We do not knowingly sell or share Personal Data of consumers under 16 years of age.

 

Right to Limit the Use of Your Sensitive Personal Data

As mentioned above, we only collect sensitive Personal Data, as defined by applicable privacy laws, for the purposes allowed by law or with your consent. We collect health-related sensitive Personal Data specifically to connect you with appropriate addiction treatment services. Because this use is necessary to provide the Services you have requested, ClearPath does not offer a general right to limit the use of sensitive Personal Data. However, you may always withdraw your consent or request deletion of your information as described above.

 

Right to Appeal a Decision

Depending on where you live, you may appeal a decision made by us relating to your request or your exercise of a right described above. To do so, please contact us using the information above. Please include your full name, the basis for your appeal, and any additional information to consider.

 

Right to Non-Discrimination

We do not discriminate against you for exercising any of the rights described in this Policy. 

Submitting a Request through an Authorized Agent

Depending on where you live, you may permit an authorized agent to submit a request to exercise the rights described above. If you are an authorized agent trying to exercise rights on behalf of a consumer, please contact us with supporting verification information, which includes proof that you are authorized to act on behalf of the consumer and proof of your own identity. We reserve the right to deny your request if we cannot verify your identity or authority to act on behalf of the consumer. Where we deny your request in whole or in part, we will inform you of the denial, provide an explanation of our actions, and the reason(s) for the denial.

 

How Long We Retain Your Personal Data

Except as otherwise permitted or required by applicable law or regulation, to satisfy any legal or regulatory obligations, or to resolve disputes, we will retain your Personal Data for as long as necessary to fulfill the purposes for which we collected it.

In determining what constitutes an appropriate retention period for Personal Data, we consider:

  • Applicable legal and regulatory requirements, including healthcare privacy laws
  • The amount, nature, and sensitivity of the Personal Data
  • The potential risk of harm from unauthorized use or disclosure
  • The purposes for which we process your Personal Data and whether those purposes can be achieved through other means
  • Our legitimate business needs, including for quality assurance, training, and potential follow-up care coordination

Security of Your Personal Data

We implement reasonable administrative, technical, and physical security measures designed to protect your Personal Data from unauthorized access, use, disclosure, alteration, or destruction. However, no internet transmission or electronic storage method is 100% secure. While we strive to protect your Personal Data, we cannot guarantee its absolute security.

 

California’s “Shine the Light” Law

Under California Civil Code Section 1798.83 (the “Shine the Light” law), California residents may opt-out of the disclosure of your Personal Data to third parties for their direct marketing purposes by contacting us using the information provided above.

 

Do Not Track Policy

We do not respond to web browser “do not track” signals. As such, your navigation of our Service may be tracked as part of the gathering of quantitative user information described above. If you arrive at our Service by way of a link from a third-party site that does respond to “do not track” requests, the recognition of any “do not track” request you have initiated will end as soon as you reach our Service.

 

Opt-Out of SMS

With your consent, we may use your Personal Data to contact you by SMS message about treatment options and services. We may send text messages using an autodialer, artificial or prerecorded voice, or other automation technology. To withdraw your consent to receive SMS messages, simply text “STOP” to any message you receive from us.

 

Minors and Children’s Privacy

Our Services are not designed for or intended to be used by individuals under the age of 18. We do not knowingly collect or receive Personal Data from individuals under 18 without parental consent. If you are under 18 years of age, do not use our Services or provide any Personal Data without parental or guardian consent. If we learn that Personal Data of persons under 18 years of age has been collected without proper consent, we will take appropriate steps to delete this information.

 

Health Information Privacy

While ClearPath is not a healthcare provider and is not directly covered by HIPAA (Health Insurance Portability and Accountability Act), we recognize the sensitive nature of the health information you share with us. We implement privacy practices designed to protect your health information and only share it with treatment facilities and service providers for the purposes described in this Policy. Treatment facilities in our network are typically covered by HIPAA and will handle your information according to their own HIPAA-compliant privacy practices once your information is transferred to them.

 

Third-Party Links

Our Site may contain links to third-party websites, including treatment facility websites and other resources. We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

 

Amendments

We reserve the right to update or modify this Policy from time to time. If we make any material changes to this Policy or the way we use, disclose, or collect Personal Data, we will notify you by revising the “Effective Date” at the top of this Policy and may provide additional notice through our Site or by email. Users are bound by any changes to the Policy when they use our Services after notice of such changes has been communicated. We encourage you to review this Policy regularly to ensure that you are familiar with our current practices.

 

Contact Us

If you have questions or concerns about this Privacy Policy or our privacy practices, please contact us at:

Clear Path Treatment Solutions
Email: [email protected]
Phone: (844) 844-0684
Address:
1150 NW 72nd Ave,
Tower 1 #455-16269
Miami, FL 33126

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