Privacy Policy

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CLEAR PATH TREATMENT SERVICES LLC

Privacy Policy

Version 1.0

Effective Date: July 1, 2026

0. Introduction

This Privacy Policy describes how Clear Path Treatment Services LLC, including its DBAs Clear Path Treatment Services, Clear Path Treatment, and Clear Path (collectively, "Clear Path," "the Company," "we," "us," or "our"), collects, uses, discloses, and safeguards information collected through https://clearpathtreatment.org (the "Website") from visitors and prospective patients.

This Privacy Policy applies to general personal information collected through the Website. It does not replace, limit, or modify the Company's separately published HIPAA Notice of Privacy Practices, which governs Protected Health Information (PHI) and 42 C.F.R. Part 2 records of admitted Patients. If you become a Patient, the HIPAA Notice of Privacy Practices controls with respect to your health information.

1. Definitions

Company / Clear Path: Clear Path Treatment Services LLC, an Oregon limited liability company, and its DBAs.

Website: https://clearpathtreatment.org and any related online forms, portals, or communication systems operated by the Company.

Personal Information: Information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular individual or household, as defined under applicable state privacy law, including the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA").

Protected Health Information (PHI): Individually identifiable health information protected under HIPAA, governed by the Company's separate HIPAA Notice of Privacy Practices.

Cookies: Small text files and similar technologies placed on a visitor's device, described in Section 6 below.

2. Information We Collect

●  Identifiers you voluntarily submit, such as name, email address, telephone number, and mailing address.

●  Information submitted through admissions inquiry, contact, or insurance verification forms, which may include information about a prospective patient's substance use history, mental health history, and insurance details.

●  Technical and usage data, such as IP address, browser type and version, device and operating system information, referring/exit pages, pages viewed, time spent on pages, and approximate geolocation derived from IP address.

●  Cookies and similar tracking technologies, as described in Section 6.

●  Communications you send to the Company, including emails, voicemail, and text messages.

3. How We Use Information

●  To respond to inquiries and communicate with you regarding the Services and potential admission.

●  To verify insurance benefits when requested.

●  To operate, maintain, secure, and improve the Website.

●  To detect, investigate, and prevent fraudulent, unauthorized, or illegal activity.

●  To comply with applicable legal, regulatory, and accreditation obligations.

●  To analyze aggregate trends in Website usage for quality improvement and marketing effectiveness.

3.1 Marketing Communications

Where you submit your contact information for purposes of receiving marketing or promotional communications, the Company will only send such communications consistent with your indicated preferences and applicable law, including the CAN-SPAM Act and the Telephone Consumer Protection Act (TCPA). You may opt out of marketing emails using the unsubscribe link included in such emails, and of text messages by replying "STOP."

4. Disclosure of Information

The Company does not sell Personal Information collected through the Website. The Company may share information with:

●  Service providers and vendors who perform functions on the Company's behalf (for example, website hosting, email delivery, analytics, and insurance verification platforms), under contractual obligations to protect the information and use it only for the purposes specified by the Company.

●  Insurance carriers and payers, when you have requested insurance verification or authorized such disclosure.

●  Government agencies, regulators, or law enforcement when required by applicable law, subpoena, or valid legal process.

●  A successor entity in connection with a merger, acquisition, financing, or sale of all or substantially all of the Company's assets, subject to applicable law.

●  Any other party with your prior written authorization.

5. Data Security and Retention

5.1 Data Security

The Company maintains administrative, technical, and physical safeguards designed to protect information against unauthorized access, use, disclosure, alteration, or destruction, appropriate to the size and complexity of the Company's operations and the sensitivity of the information involved. Representative safeguards include encryption of data in transit, role-based access controls, multi-factor authentication for administrative access where supported, regular patching and vulnerability management, security monitoring, and workforce training. No method of transmission over the internet or method of electronic storage is completely secure, and the Company cannot guarantee absolute security.

5.2 Breach Notification

In the event of a breach involving unsecured Personal Information, the Company will provide notification as required by applicable Oregon law (ORS 646A.600 et seq.) and, where PHI is involved, in accordance with HIPAA and the HITECH Act, as described in the HIPAA Notice of Privacy Practices.

5.3 Data Retention

Information collected through the Website is retained only as long as reasonably necessary to fulfill the purposes described in this Policy, comply with legal and regulatory obligations, resolve disputes, and enforce the Company's agreements, after which it is securely deleted or de-identified using commercially reasonable destruction methods.

6. Cookie Policy

6.1 What Are Cookies

Cookies are small text files placed on your device by a website to store information such as preferences, session data, and analytics identifiers. The Website may also use similar technologies such as pixels, web beacons, and local storage.

6.2 Categories of Cookies Used

Essential: Required for core Website functionality, such as form submission and security; cannot be disabled without affecting the Website.

Functional: Remember preferences such as language or display settings to improve your experience.

Analytics / Performance: Help the Company understand how visitors use the Website in order to improve content and navigation (e.g., aggregated, pseudonymous usage statistics).

Security: Help detect and prevent fraudulent or unauthorized activity.

Marketing (if applicable): May be used by approved third-party advertising or marketing platforms to measure the effectiveness of outreach. The Company will identify any such technologies in use and provide opt-out mechanisms as required by law.

6.3 Managing Cookies

You can control or delete cookies through your browser settings. Disabling cookies may impair certain Website functionality. Where required by applicable law, the Company will provide a cookie consent banner or preference center allowing you to accept or decline non-essential cookies before they are set. The Website may use third-party analytics or hosting providers that place their own cookies, governed by their own privacy and cookie policies.

7. Your Choices and Rights

Subject to applicable law, you may request to access, correct, or request deletion of certain personal information the Company holds about you, opt out of marketing communications, and decline non-essential cookies through your browser settings. To exercise these rights, contact the Company using the information at the end of this document. The Company will take reasonable steps to verify your identity before responding and may decline requests that conflict with legal recordkeeping obligations, including healthcare recordkeeping requirements.

8. Minors & Children's Privacy (COPPA)

The Company's residential substance use disorder treatment programs are currently designed for, and limited to, adults eighteen (18) years of age and older. The Website's general informational content may be viewed by visitors of any age; however, online inquiry, admissions, or contact forms should only be completed by individuals eighteen (18) years of age or older, or by a parent or legal guardian submitting information on behalf of another person.

Consistent with the Children's Online Privacy Protection Act (COPPA), the Company does not knowingly collect personal information from children under thirteen (13) years of age through the Website. If the Company becomes aware that it has inadvertently collected personal information from a child under thirteen without verifiable parental consent, it will take reasonable steps to delete that information promptly. A parent or guardian who believes the Company may have collected information from their child should contact the Company immediately using the information at the end of this document.

9. California Privacy Notice (CCPA/CPRA)

9.1 Applicability

This Notice supplements this Privacy Policy and applies solely to California residents whose Personal Information the Company collects through the Website, to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, "CCPA/CPRA"), applies to the Company's processing of such information.

9.2 Categories of Personal Information Collected

In the twelve (12) months preceding the Effective Date, the Company may have collected the following categories of Personal Information through the Website, as defined under the CCPA/CPRA: identifiers (such as name, email, phone number); information protected under California law (such as health-related information you voluntarily provide in an inquiry, which may also constitute sensitive personal information); internet or other electronic network activity information (such as browsing and usage data); and inferences drawn from the foregoing to create a profile reflecting preferences.

9.3 No Sale or Sharing of Personal Information

The Company does not sell Personal Information, as that term is defined under the CCPA/CPRA, and does not "share" Personal Information for cross-context behavioral advertising, except to the extent disclosed in Section 6 with respect to any third-party analytics or marketing technologies in use, which the Company will identify and provide opt-out mechanisms for as required by law.

9.4 Your California Rights

Subject to applicable exemptions — including the exemption for protected health information governed by HIPAA — California residents may have the right to: know and access the specific pieces and categories of Personal Information collected; request deletion; request correction of inaccurate information; limit the use of sensitive personal information; and not be discriminated against for exercising any of these rights. You may submit a verifiable consumer request using the contact information at the end of this document. The Company will verify your identity before responding and may decline requests that fall within an applicable exemption.

10. Oregon Consumer Privacy Notice (OCPA)

10.1 Applicability

This Notice supplements this Privacy Policy and applies to Oregon residents whose Personal Information the Company collects through the Website, to the extent the Oregon Consumer Privacy Act, ORS 646A.570–646A.589 ("OCPA"), applies to the Company's processing of such information. The OCPA applies only to entities that, during a calendar year, control or process the personal data of 100,000 or more Oregon consumers, or of 25,000 or more Oregon consumers while deriving 25% or more of annual gross revenue from the sale of personal data. This Notice is provided regardless of whether the Company currently meets these thresholds, and will be updated to reflect the Company's actual obligations once that determination is made by counsel.

10.2 Relationship to HIPAA and 42 C.F.R. Part 2

The OCPA does not exempt HIPAA-covered entities generally, but it does exempt Protected Health Information (PHI) regulated by HIPAA, and information maintained in the same manner as PHI, at the data level. Accordingly, your PHI and Part 2 Records remain governed exclusively by the Company's separate HIPAA Notice of Privacy Practices, while other categories of personal information you provide through the Website (for example, general contact or browsing information) may independently be subject to the OCPA.

10.3 Your Oregon Rights

Subject to applicable exemptions, Oregon residents may have the right to: confirm whether the Company is processing their personal data and access that data; correct inaccuracies; request deletion; obtain a portable copy of their data; obtain a list of the specific categories of third parties to which their personal data has been disclosed; and opt out of the sale of personal data, targeted advertising, and certain profiling. Where required, the Company will honor opt-out requests submitted through a recognized universal opt-out mechanism, such as Global Privacy Control.

10.4 Submitting a Request

You may submit a request to exercise these rights using the contact information at the end of this document. The Company will respond within 45 days, may extend that period by an additional 45 days where reasonably necessary, and will not charge a fee for the first request in a 12-month period. The Company will not discriminate against you for exercising any OCPA right. If you are not satisfied with the Company's response, you may appeal using the same contact information, and may also submit a complaint to the Oregon Department of Justice. The OCPA is enforced exclusively by the Oregon Attorney General and does not provide a private right of action.

11. Changes to This Policy

The Company may revise this Privacy Policy from time to time. The current version, with its effective date, will be posted on the Website. Material changes affecting how previously collected information is used will be communicated as required by applicable law.

12. Revision History

Version: 1.0

Effective Date: July 1, 2026

13. Contact Information

Clear Path Treatment Services LLC

Physical Address: 34 NE 20th Ave, Portland, OR 97232

Email: info@clearpathtreatment.org

Phone: (971) 438-0103

Website: https://clearpathtreatment.org