How ClearPath handles your information

ClearPath Health LLC ("ClearPath," "we," "us") provides an AI-powered healthcare navigation service (the "Service") that helps you understand your health records, prepare for appointments, and coordinate with providers and insurers.

This Privacy Policy explains what information we collect, how we use it, who we share it with, and the rights you have over it. It applies to clearpathhealth.care and the ClearPath web application.

ClearPath operates as a patient-directed access application: when you connect a health record system or insurer, you are exercising your own right of access under HIPAA to direct that information to an application of your choosing. This means ClearPath itself is not a HIPAA covered entity or business associate the way your doctor's office or insurer is — but we apply privacy and security practices built to that same standard.

Account information. Name, date of birth, phone number, email, mailing address, and login credentials.

Health information. When you connect an electronic health record system or insurance carrier, we receive the records you authorize — such as conditions, medications, lab results, clinical notes, claims, coverage, and prior-authorization status. We only receive what you affirmatively authorize through that connection's consent screen, and only for as long as that authorization remains active.

Conversations and call data. Messages you exchange with ClearPath's chat assistant, and — if you use our automated calling service — recordings, transcripts, and call metadata (who was called, when, and the outcome) for calls placed on your behalf.

Payment information. Subscription and telephony-usage billing is handled by Stripe. We do not store your card number; we retain only the billing records and usage totals needed to administer your subscription.

Usage and device data. Standard technical data (IP address, browser type, pages visited) collected for security and to keep the Service working correctly.

• To provide the Service: summarizing your records, preparing appointment materials, reviewing medications, and answering your questions about your own health information.
• To coordinate care on your behalf, including placing calls to schedule appointments or follow up on prior authorizations when you've chosen that option.
• To process your subscription and telephony charges.
• To detect, investigate, and prevent fraud, abuse, and security incidents.
• To comply with legal obligations.

We do not sell your personal or health information. Full stop.

When we ask before sharing, versus when we don't. Two of the categories below — your calling service and the prior-authorization call feature — involve ClearPath actively disclosing your information to a third party (a provider's office) on a specific occasion, not just processing it internally. For those, we ask first: before any scheduling call is placed, you'll see exactly what will be shared and with whom, and can approve it once, always, or decline; turning on the prior-auth calling feature in Settings requires the same kind of explicit confirmation before it takes effect. The other categories below (our infrastructure vendors, legal/safety disclosures, a business transfer) don't involve a fresh consent prompt each time — they're disclosed here, in this Policy, which you agree to when you accept it.

We share information only in these circumstances:

• Service providers who process data on our behalf, under contract and only for the purpose of running the Service: Amazon Web Services (hosting and storage), Anthropic (AI processing of health summaries and chat), Retell AI (automated phone calls), and Stripe (payment processing).
• The records systems and insurers you connect — to retrieve or update information at your direction.
• The third parties our calling service contacts on your behalf (e.g., a prescriber's office), limited to what's needed to complete the specific task you requested.
• Legal and safety reasons — if required by law, subpoena, or to protect the rights, property, or safety of ClearPath, our users, or the public.
• A merger, acquisition, or sale of assets — your information would be subject to the same protections described here, with notice to you. If ClearPath ceases operations without being acquired, we will notify you with reasonable advance notice, give you the opportunity to download your data before shutdown (see Section 9), and then delete any remaining information rather than transfer it to an unrelated party.

Marketing. ClearPath does not currently market third-party goods or services to you. If that ever changes, we will collect your separate, explicit consent before any such marketing or before sharing your information to facilitate it — not as an opt-out buried in a settings page, as an affirmative choice you make first.

ClearPath uses AI models — including Anthropic's Claude — to summarize records, answer questions, and prepare appointment materials. AI-generated content may contain errors. It is informational only, is not medical advice, and should be reviewed with your care team before you act on it. We do not use your health information to train AI models on behalf of third parties.

If you opt into ClearPath's calling service for scheduling or prior-authorization follow-up, an AI voice agent places calls on your behalf. The agent identifies itself as an automated assistant at the start of every call, states that the call may be recorded, and states who it's calling on behalf of.

Call recordings and transcripts are stored securely and used only to provide the Service, confirm outcomes, and improve call quality. By enabling the calling service, you consent to calls being placed using AI voice technology and to those calls being recorded, to the extent permitted by applicable law.

• Each person's health information is encrypted separately, with encryption keys that rotate automatically.
• Access is restricted to what's necessary to provide the Service.
• We maintain agreements with our infrastructure and AI vendors governing how health information is handled.

If a breach occurs. ClearPath draws health information from multiple sources (your connected EHRs and insurers) for your own use — which makes us a vendor of personal health records under the FTC's Health Breach Notification Rule, even though we're not HIPAA-covered. If unsecured personal health information is acquired or disclosed without authorization, we will notify each affected person without unreasonable delay and no later than 60 calendar days after discovery, notify the FTC as required under that Rule, and notify the media if a breach affects 500 or more residents of a single state, as the Rule requires. We follow this process in addition to, not instead of, any state breach-notification law that applies.

We retain your information for as long as your account is active, plus a limited period afterward to meet legal, billing, and dispute-resolution obligations. You can request deletion of your account and associated data at any time (see Section 9) — some records may be retained longer where required by law.

Depending on where you live, you may have the right to access, correct, delete, or obtain a copy of your personal information, and to opt out of certain processing. A number of US states now have comprehensive privacy laws granting these rights; if you live in one of them, those rights apply to you, and some states (including Washington, under its My Health My Data Act) extend specific additional protections to consumer health data.

To exercise any of these rights, use the Download my data and Delete my account controls in your account Settings, or contact us using the information in Section 11 if you need help. Account deletion cancels your subscription immediately; your encryption key is scheduled for deletion subject to a minimum 7-day window required by our cloud provider, after which the data is unrecoverable.

Re-affirming or withdrawing consent. If we make a material change to this Policy, continuing to use the Service after that change takes effect counts as re-affirming your consent to the updated terms. You can withdraw consent at any time, in two ways: disconnecting an individual EHR or insurer connection (on the Connect page) stops us from pulling any new data from that source going forward, though information already collected before disconnection isn't automatically erased; deleting your account withdraws consent entirely and triggers the full deletion process described above — nothing about your account is retained except the minimal record required to prove the deletion happened, which contains no health information.

The Service is not directed to, and is not knowingly used by, anyone under 18. We do not knowingly collect information from children.

We may update this Privacy Policy from time to time. If we make material changes, we'll notify you in the app or by email before they take effect. The "Last updated" date below reflects the most recent revision.

Questions about this Privacy Policy or your data? Email privacy@clearpathhealth.care.