Privacy Policy

Updated: March 1, 2023

1. Overview

Clear Path Financial Training, LLC (“Clear Path Financial Training,” “we,” “us,” and “our”) respects your privacy and is committed to protecting it through compliance with this Privacy Notice (“Privacy Notice”). This Privacy Notice describes the types of Information we may collect from you when you visit the website at https://clearpathfinancialtraining.com or use the Services offered there (the “Platform”), and that you may provide in electronic messages to Clear Path Financial Training. It also describes our practices for collecting, using, maintaining, protecting, and disclosing that Information.

Please read this Privacy Notice to understand our policies and practices regarding your Information and how we will handle it. If you do not agree with our policies and practices, do not use the Platform. By accessing or using the Platform, you agree to this Privacy Notice.

Clear Path Financial Training may change this Privacy Notice at any time, at its discretion. Your continued use of the Platform after we make changes is deemed to be acceptance of those changes, so please check the Privacy Notice periodically for updates.

This Privacy Notice is subject to and governed by the Clear Path Financial Training Terms of Service (“Terms of Service”) available on the Platform. The Services are part of the Platform and are described further in the Terms of Service.

2. The Types of Information That Clear Path Financial Training Collects About You and How Clear Path Financial Training Collects Information About You

Clear Path Financial Training may collect two types of information from you when you visit the Platform: Personal Information and Non-Personal Information (collectively “Information”).

• “Personal Information” refers to data by which you may be personally identified, such as name, email address, employer, job title and department, telephone number, and other information listed in Section 12.

• “Non-Personal Information” means data that is about you but does not identify you specifically. If you do nothing during your visit to our Platform but browse, read pages, or view content, we will gather and store Information about your visit that does not identify you personally.

We collect Information:

• Directly from you when you provide it to us.

• Through our communications with you.

• From third parties.

• Automatically as you navigate through the Platform.

• Automatically, on an aggregate level when you utilize our Services.

• Through analytics.

Information You Provide Directly to Clear Path Financial Training. The Information that you provide us directly through our Platform may include:

• Information that you provide when you subscribe to our Services or purchase our products.

• Information you provide when you create an account on our Platform or subscribe to our mailing list.

• Information that you provide by filling in forms on our Platform.

• Information that you provide when you report a problem with our Platform. We may ask you for additional Information to resolve the problem.

• Information that you provide in connection with an inquiry you have.

• Records and copies of your correspondence (including email addresses) if you contact us.

• Your responses to surveys.

• Details of transactions you carry out through the Platform.

Information Automatically Collected from You. The Information that Clear Path Financial Training may automatically collect and store about you when you visit the Platform may include:

• Your location.

• The Internet Protocol Address and domain name used. The Internet Protocol address is a numerical identifier assigned either to your internet service provider or directly to your computer. We use the Internet Protocol address to direct internet traffic to you.

• The type of browser and operating system you used.

• The date and time you visited the Platform.

• The web pages or Services you accessed at the Platform.

• The website you visited prior to coming to the Platform; and

• Cookies, which are small text files that a web server (such as Clear Path Financial Training or its chosen web hosting company server) places on a user’s computer.

When accessing a cookie, the Clear Path Financial Training server reads a number associated with a browser but is unable to determine any data about a user. With that number, our web server can tailor its content to the needs of the specific browser, and we can optimize the Platform for your use. You can remove or reject cookies using your browser or device settings, but in some cases doing so may affect your ability to use our products and Services.

Google Analytics Advertising Features. We also may have the following Google Analytics Advertising Features Implemented: Demographics and Interest reporting, Remarketing, GDN Impression Reporting and Double Click Campaign Manager. These features collect data using Google advertising cookies and anonymous identifiers. Clear Path Financial Training and third-party vendors use these first-party cookies to access the success of online marketing campaigns, inform future campaigns and improve usability on the Platform. To learn how to opt-out of the Google Analytics Advertising Features we use, please see Google Analytics’ currently available opt-outs for the web at https://tools.google.com/dlpage/gaoptout.

3. How Clear Path Financial Training Uses Information It Collects About You and the Purposes for the Collection and Use

We use Information that we collect about you or that you provide to us, including any Personal Information, for the following purposes:

• To present our Platform and the Platform Content (as defined in the Terms of Service) to you.

• To provide you with the products or Services that you request from us. For example, if you inquire regarding our Services, we will use the contact information you give us to communicate with you about the Services we provide.

• To provide customer support.

• To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collection.

• To analyze how our products and Services are used.

• To notify you about changes to our Platform or any products or Services we offer or provide though it.

• To provide you with information regarding your account.

• To communicate with you regarding our products and Services, including for marketing purposes.

• To personalize our Services and advertising to you.

• To diagnose Service or technical problems.

• To maintain security.

• In any other way we may describe when you provide the Information.

• To fulfill any other purpose for which you provide it.

• For any other purpose with your consent.

• To develop and improve our Platform, products, and Services and to develop new products and Services.

Platform statistics are compiled into traffic reports, which help Clear Path Financial Training understand, anticipate, and respond to user needs.

If we learn, for example, of heightened interest in certain aspects of the Clear Path Financial Training website, we are likely to highlight that information on the Platform home page. This Information helps us create a better overall experience for Platform users.

We will only retain your Personal Information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements and for other purposes described in this Privacy Notice. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements. In some circumstances you can ask us to delete your data: see your legal rights below for further information. And in some circumstances, we will anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

4. How Clear Path Financial Training Protects Your Information

We have implemented measures designed to protect your Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the internet is not completely secure. Although we are working to protect your Information, we cannot guarantee the security of your Information either in transmission or when stored. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

5. When Clear Path Financial Training Shares Your Information

We may use and disclose Non-Personal Information about our users without restriction. We may disclose Personal Information that we collect, or you provide as described in this Privacy Notice:

• To our subsidiaries and affiliates.

• To contractors, service providers, and other third parties we use to support our business, as described further below, including third party payment facilitators.

• To a buyer or other successor (potential or actual) in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Clear Path Financial Training assets, including any related due diligence.

• To fulfill the purpose for which you provide it.

• For any other purpose disclosed by us when you provide the Information.

• With your consent.

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

• To enforce or apply our Terms of Service.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Clear Path Financial Training or others.

Clear Path Financial Training does not sell any of your Personal Information.

6. Updating and Correcting Information

We believe you should have the ability to access and edit the Personal Information that you have provided to us. You may change any of your Personal Information in your account online at any time by linking to your account in accordance with instructions posted elsewhere on the Platform.

We encourage you to promptly update your Information if it changes. You may ask to have Information on your account deleted or removed; however, some Information, such as past transactions, logs of technical support calls, or other Information may not be deleted. In addition, it may be impossible to completely delete your Information without some residual Information due to our backup procedures.

7. Third Parties Providing Services On Our Behalf

We use third parties to host the Platform, design and operate the Platform features, and to perform administrative, analytics, and payment processing. Services these third parties provide include providing information to Clear Path Financial Training about the use of the Platform and viewing of our content. We may disclose your Information to these companies so they can carry out these services. These companies are bound by contractual obligations to keep Information confidential.

8. Information From Children

We do not knowingly collect, use, or disclose Information from children under 16. If we learn that we have collected the Personal Information of a child under 16, we will take steps to delete the information as soon as possible. If you are under 16, do not provide any Information about yourself to Clear Path Financial Training, including your name, address, telephone number or email address. If you become aware that Information of a child under 16 years of age has been provided, please contact us at admin@clearpathfinancialtraining.com.

9. Links to Other Websites and Services

We are not responsible for the practices employed by websites or services linked to or from the Platform, including the information or content contained therein. Our Privacy Notice does not apply to third-party websites or services.

10. Do Not Track

Some browsers incorporate a “Do Not Track” (“DNT”) feature that, when turned on, signals to websites and online services that you do not want to be tracked. At this time, the Platform does not respond to DNT signals.

11. Residents of the European Economic Area (“EEA”) and United Kingdom (“UK”)

If you are in the EEA or UK, you may have certain rights with respect to your Personal Information that are described below.

Controller of Personal Information.

Clear Path Financial Training is the Controller of your Personal Information.

Clear Path Financial Training business address is 10900 Research Blvd, Ste 160C, Austin, TX 78759.

Processing.

Clear Path Financial Training may process your Personal Information on one or more of the following legal bases:

• as necessary to enter a contract with you or a legal entity you represent, to perform our contractual obligations, to provide Services, to respond to requests from you, or to provide customer support.

• where we have a legitimate interest, as described in this Privacy Notice (see “How Clear Path Financial Training Uses Information It Collects About You and the Purposes for Collection and Use”);

• as necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or

• with your consent.

Your Rights.

Subject to applicable law, you may have the right to:

• Ask whether we hold Personal Information about you and request copies of such Personal Information and information about how it is processed.

• Request that inaccurate Personal Information is corrected.

• Request deletion of Personal Information that is no longer necessary for the purposes underlying the processing, processed based on withdrawn consent, or processed in non-compliance with applicable legal requirements.

• Ask us to restrict the processing of Personal Information where the processing is inappropriate.

• Object to the processing of Personal Information.

• Request portability of Personal Information that you have provided to us (which does not include Information derived from the collected Information), where the processing of such Personal Information is based on consent or a contract with you and is carried out by automated means, and lodge a complaint with the appropriate data protection authorities. You can exercise your rights of access, rectification, erasure, restriction, objection, and data portability by contacting us at admin@clearpathfinancialtraining.com.

When you consent to our processing your Personal Information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.

The categories of Personal Information that Clear Path Financial Training collects are identified in Section 2, “The Types of Information That Clear Path Financial Training Collects About You and How Clear Path Financial Training Collects Information About You.”

Additional information about how long Clear Path Financial Training will retain your Information and how it shares your Information is found in Section 3, “How Clear Path Financial Training Uses Information It Collects About You and the Purpose for the Collection and Use,” and Section 5, “When Clear Path Financial Training Shares Your Information” above.

12. California Privacy Rights

Under California law, California residents have certain rights regarding their Personal Information, including the rights listed below. California law requires us to identify these rights to you. Subject to some exceptions, you have:

• The right to know the categories of Personal Information that we have collected and the sources from which we obtained the Information.

• The right to know the business purposes we have for sharing Personal Information.

• The right to know the categories of third parties with whom we have shared Personal Information.

• The right to access the specific pieces of Personal Information we have collected, and the right to request the deletion of your Information.

• The right to opt-out of the sale of your Personal Information, as a “sale” is defined under the California Consumer Privacy Act of 2018 (“CCPA”), and in some cases the sharing of your Personal Information. Note that Clear Path Financial Training does not sell your Personal Information.

• The right to correct your Personal Information.

• The right to restrict processing of sensitive Personal Information, such as social security numbers, passport numbers, racial or ethnic origin, and financial account and payment card information.

Personal Information Collected

We may collect the following Personal Information about you:

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet

• Protocol address, email address, account name, or other similar identifiers.

• Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) such as a name, signature, address, telephone number, or credit card number.

• Protected classification characteristics under California or federal law such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

• Commercial Information such as products or Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

• Internet or other similar network activity such as information on a consumer’s interaction with a website, application, or advertisement.

• Geolocation data such as physical location.

• Inferences drawn from other Personal Information such as profiles reflecting a person’s preferences.

Additional information about the categories of Personal Information collected and the categories of sources from which Personal Information is collected is in Section 2 of the Privacy Notice. The purpose for collecting the Personal Information listed above is in Section 3 of the Privacy Notice. The third parties with which Clear Path Financial Training may share the Personal Information listed above is in Section 5 of this Privacy Notice.

Exercising Your Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described in this California section, please submit your request to admin@clearpathfinancialtraining.com.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period. If we deny your request, we will provide reasons for the denial. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

Clear Path Financial Training will not discriminate against you for exercising any of your CCPA rights.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Platform that are California residents to request certain information regarding Clear Path Financial Training disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact Clear Path Financial Training at the email address in Section 14 below.

13. Your Choices About Information

We may, from time to time, send you emails regarding new products and Services that we feel may interest you. In addition, if you indicated upon registration that you are interested in receiving offers or information from us and our partners, we may occasionally call or send you direct mail about products and Services that may be of interest to you. Only Clear Path Financial Training (or agents working on behalf of Clear Path Financial Training and under confidentiality agreements) will send you these solicitations, and only if you have previously indicated that you wish to receive them. If you do not want to receive solicitations from us, you can “opt-out” by accessing your account online and editing your account information to no longer receive such offers and mailings.

If you no longer wish to receive marketing or promotional communications from us, click on the “unsubscribe link” provided in such communications or send us an email to admin@clearpathfinancialtraining.com. You can also login to your account and change the applicable communication settings so that you no longer receive such communications.

If you opt out of receiving marketing/promotional emails, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.

Please report your concerns about collection or use of Personal Information through the Platform to admin@clearpathfinancialtraining.com.