Privacy Policy (Education) for B2C Learners

Version 1.0 — Effective October 7, 2026
Effective Date: October 7, 2026
Last Updated: October 7, 2026

Clear Path Framework LLC (“Clear Path,” “we,” “us,” or “our”), respects the privacy of learners and their families.

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you use our website, enroll in or participate in our virtual academic planning pathway, communicate with us, or otherwise interact with us.

This policy applies to:

Parents and legal guardians;
Learners, including learners under 18;
Website visitors;
Families using Florida PEP scholarship funds through the EMA marketplace; and
Individuals who contact us about enrollment or services.

By submitting information to us, enrolling a learner, or using our website or services, you acknowledge this Privacy Policy. When a learner is a minor, the parent or legal guardian is responsible for reviewing this policy and providing any required consent.

Clear Path provides a virtual, structured academic planning pathway through scheduled check-ins and live virtual group tutoring sessions. Our services may include:

Goal setting;
Academic planning and pathway guidance;
Progress reviews;
Document tracking;
Live virtual group tutoring;
Check-in attendance and participation tracking;
Parent updates; and
Related educational resources. Clear Path is not a school, does not issue credits, diplomas, or transcripts, and does not determine eligibility for or award scholarship funds. Clear Path is not an educational institution subject to the Family Educational Rights and Privacy Act (“FERPA”). However, we apply FERPA-style protections to learner records as a matter of company policy and handle learner information with care.

2. Information We Collect

Depending on how you interact with us, we may collect the following categories of information.

2.1 Parent or Guardian Information

We may collect:

Parent or guardian name;
Mailing address;
Email address;
Telephone number;
Relationship to the learner;
Account and enrollment information;
Communication preferences; and
Information needed to verify authority to act for a learner.

2.2 Learner Information

We may collect:

Learner name;
Date of birth or age;
Grade level;
School district;
Educational interests and learning goals;
Progress notes;
Check-in attendance and participation records;
Documents submitted for enrollment or scholarship verification;
Information voluntarily provided by a parent, guardian, or learner; and
Other information reasonably necessary to deliver the pathway. Please do not submit medical, disability, psychological, or other highly sensitive information unless it is reasonably necessary for the service and you are authorized to provide it.

2.3 Scholarship and Enrollment Information

For families using PEP scholarship funds through the EMA marketplace, we may collect:

Scholarship type;
EMA marketplace account information;
Scholarship or enrollment documentation;
Purchase request or funding information;
Verification information;
Information needed to document services; and
Information needed to respond to requests from the scholarship program administrator or a government agency. Scholarship families generally pay $0 out of pocket for approved services. We may still maintain records showing the applicable service, funding source, enrollment status, and $0 family payment record.

2.4 Communications

We may collect information contained in communications with us, including:

Emails;
Telephone calls;
Text messages, if used;
Enrollment questions;
Parent updates;
Support requests;
Feedback; and
Notes relating to communications about the learner or services. We will notify participants before recording a call, virtual check-in, or other communication when notice or consent is required.

2.5 Technical and Website Information

When you visit our website or use online services, we may collect:

Internet Protocol (“IP”) address;
Browser type;
Device type;
Operating system;
Approximate location derived from technical information;
Pages viewed;
Links clicked;
Dates and times of website activity;
Referring website;
Usage information;
Cookie identifiers; and
Other standard log information. We use this information to operate, secure, maintain, and improve our website and services.

3. How We Collect Information

We may collect information:

Directly from a parent, guardian, or learner;
Through enrollment forms;
Through account or profile creation;
During virtual check-ins and live virtual group tutoring sessions;
Through parent updates;
Through document uploads;
Through email, telephone, or other communications;
From the EMA marketplace or scholarship program administrator;
From service providers that support our operations;
Through website cookies and similar technologies; and
From public or governmental sources when reasonably necessary for verification or compliance. We may combine information collected from different sources for the purposes described in this policy.

4. How We Use Personal Information

We may use personal information to:

Provide the academic planning pathway;
Provide live virtual group tutoring sessions;
Schedule and manage check-ins;
Track academic goals and progress;
Track attendance and participation;
Track and manage submitted documents;
Send parent updates;
Communicate about enrollment and services;
Respond to questions and requests;
Process scholarship-funded enrollment;
Document $0 out-of-pocket scholarship enrollment;
Submit or respond to information requests from the EMA marketplace or scholarship administrator;
Meet scholarship, funding, tax, accounting, and record-keeping obligations;
Process payments for self-pay services, if applicable;
Maintain and secure accounts, systems, and the website;
Detect, prevent, and respond to fraud, misuse, security incidents, or unlawful activity;
Enforce our Terms and Conditions;
Comply with legal obligations; and
Improve our services and operations. We do not use learner information for behavioral advertising. We do not sell personal information.

Depending on the circumstances, we process personal information based on one or more of the following grounds:

Performance of a contract or enrollment arrangement;
Steps taken at a parent’s or guardian’s request before enrollment;
Compliance with a legal, scholarship, funding, accounting, or record-keeping obligation;
Consent;
Protection of the security and integrity of our services; and
Legitimate business needs that are not outweighed by the individual’s privacy interests. When a learner is a minor, the parent or legal guardian represents that they have the legal authority to provide information and consent on the learner’s behalf. A parent or legal guardian may withdraw consent where consent is the basis for processing. Withdrawal does not affect processing that occurred before withdrawal and may prevent us from continuing to provide certain services.

We may disclose personal information in the following circumstances.

6.1 Scholarship and Government Entities

We may share information with:

The scholarship program administrator;
The EMA marketplace;
Applicable state agencies;
Government agencies responsible for funding, verification, compliance, or oversight; and
Other entities when disclosure is required to administer or verify scholarship-funded services. We share only information reasonably necessary for the applicable purpose, subject to the requirements of the applicable program or agency.

6.2 Service Providers

We may share information with service providers that help us operate our business, such as providers of:

Website hosting;
Enrollment and form tools;
Scheduling;
Video conferencing;
Learning or communication platforms;
Document storage;
Payment processing;
Information technology;
Customer support;
Security;
Accounting; and
Legal or professional services. We require service providers to use personal information only for authorized business purposes and to maintain appropriate confidentiality and security protections.

6.3 Legal and Safety Disclosures

We may disclose information when reasonably necessary to:

Comply with a subpoena, court order, law, or legal process;
Respond to a lawful request from a government authority;
Protect the rights, safety, or property of Clear Path, a learner, a parent, or another person;
Investigate fraud, security incidents, or unlawful activity;
Enforce our agreements; or
Protect against legal liability.

6.4 Business Transfers

If Clear Path is involved in a merger, acquisition, financing, sale of assets, reorganization, bankruptcy, or similar transaction, personal information may be transferred as part of that transaction, subject to applicable law.

6.5 No Sale or Advertising Use

We do not sell personal information. We do not share learner information for cross-context behavioral advertising or use learner records to create advertising profiles.

7. Learner Records and Scholarship Information

Clear Path is not a school or educational institution subject to FERPA. We therefore do not claim that FERPA directly governs our records. As a matter of policy, we use FERPA-style protections for learner records. This means we seek to:

Limit access to authorized personnel and service providers;
Use learner records only for legitimate service, administrative, funding, safety, or legal purposes;
Avoid unnecessary disclosure;
Maintain reasonable security controls; and
Respond appropriately to parent or guardian requests concerning learner information. Scholarship administrators, the EMA marketplace, and state agencies may have their own privacy practices and record requirements. Information provided to those entities may be handled under their respective policies and legal obligations. Clear Path does not determine whether a family or learner qualifies for a scholarship and does not award scholarship funds.

8. Cookies and Similar Technologies

We may use cookies, pixels, local storage, log files, and similar technologies to:

Keep the website functioning;
Remember preferences;
Maintain security;
Understand website traffic and usage;
Diagnose technical problems; and
Improve website performance. Some cookies may be placed by service providers that support website functionality, analytics, security, or embedded content. You may control cookies through your browser settings. You may be able to block, delete, or limit cookies, but doing so may affect website functionality. Where required by law, we will provide additional cookie choices or consent tools. Our website may respond to certain browser-based privacy signals where required by applicable law. Because we do not sell personal information or use learner information for targeted advertising, we do not use cookies for those purposes.

9. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this policy, unless a longer period is required or permitted by law. Our general retention practices are:

Learner records: During the learner’s active enrollment and generally for up to seven years after the end of the relationship, unless a longer period is required for legal, safety, dispute, or scholarship purposes;
Scholarship and EMA documentation: For the period required by the applicable scholarship program, funding administrator, EMA marketplace, state agency, or other applicable authority, which may extend beyond the end of enrollment;
Billing and payment records: Generally for at least seven years after the applicable transaction or relationship, or longer if required for tax, accounting, audit, dispute, or legal purposes;
Communications: For as long as reasonably necessary to respond to the communication, administer services, document decisions, resolve disputes, or comply with legal obligations;
Technical and cookie information: For periods appropriate to the purpose for which it was collected, subject to system, security, and provider settings; and
Backups: For a limited period consistent with backup and disaster-recovery practices. When information is no longer needed, we may delete it, de-identify it, or securely dispose of it, subject to technical limitations and applicable retention obligations.

10. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. Safeguards may include:

Access controls;
Password and account protections;
Limited access based on job responsibilities;
Secure transmission where available;
Service-provider confidentiality requirements;
System monitoring;
Backup and recovery procedures; and
Staff practices designed to protect confidential information. No system or method of transmission is completely secure. We cannot guarantee that personal information will never be accessed, disclosed, altered, or destroyed through an incident beyond our reasonable control. If we determine that a security incident requires notice under applicable law, we will provide notice in the manner and within the time required by law.

11. Children’s Privacy

Our services may be used by learners under 18, including learners under 13. A parent or legal guardian must provide authorization and any required consent before we collect or process personal information from a minor learner for enrollment or services. We do not knowingly collect personal information directly from a child under 13 without the notice and verifiable parental consent required by applicable law. For learners under 13:

We seek consent from a parent or legal guardian;
We collect only information reasonably necessary to provide the pathway, administer enrollment, comply with scholarship requirements, or meet legal obligations;
We do not condition participation on providing more personal information than reasonably necessary;
We do not use learner information for behavioral advertising;
We do not sell learner information; and
Parents or legal guardians may request access to, correction of, or deletion of their child’s information, subject to legal and operational limitations. If you believe that a child under 13 provided personal information without appropriate parental consent, please contact us using the information in Section 17.

12. Privacy Rights

Depending on where you live and subject to applicable law, you may have the right to:

Confirm whether we process your personal information;
Access or obtain a copy of personal information;
Correct inaccurate or incomplete information;
Request deletion of personal information;
Request restriction of certain processing;
Request portability of information provided to us in a usable format;
Withdraw consent where consent is the basis for processing;
Object to certain processing;
Opt out of the sale of personal information or targeted advertising, if applicable;
Appeal a decision concerning a privacy request, where required by law; and
Submit a complaint to an applicable privacy regulator. These rights are not absolute. We may retain or use information when necessary to provide services, comply with legal or scholarship obligations, maintain records, protect security, establish or defend legal claims, or exercise rights provided by law.

12.1 California Residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act and related regulations, as amended from time to time. These rights may include the right to:

Know and access categories and specific pieces of personal information collected about you;
Request correction of inaccurate personal information;
Request deletion of personal information, subject to exceptions;
Obtain information about how personal information is collected, used, and disclosed;
Opt out of the sale or sharing of personal information;
Limit certain uses or disclosures of sensitive personal information where applicable;
Receive equal service and price, subject to lawful exceptions; and
Appeal a denied request where required by law. We do not sell personal information and do not share learner information for cross-context behavioral advertising. California requests may be submitted using the contact information in Section 17. We will not discriminate against you for exercising a privacy right. We may verify your identity before completing a request and may require additional information where the request concerns a minor learner or another person’s records.

12.2 Florida Residents

If you are a Florida resident, you may have rights under the Florida Digital Bill of Rights and other applicable law, subject to statutory thresholds, exemptions, and limitations. These rights may include rights to:

Access personal information;
Correct inaccuracies;
Delete personal information;
Obtain a portable copy of certain information;
Opt out of targeted advertising, the sale of personal information, or certain profiling activities, where applicable; and
Appeal a decision concerning a privacy request where required by law. We do not sell personal information or use learner information for targeted advertising. We may verify your identity and authority before responding to a request.

12.3 Requests Concerning a Learner

A parent or legal guardian requesting information about a learner may need to provide:

Their name and contact information;
The learner’s name;
Their relationship to the learner;
Proof of identity; and
Proof of parental or legal authority, if reasonably necessary. We may contact the other parent, guardian, or applicable authority when needed to verify authority or protect the learner’s privacy and safety.

13. How to Submit a Privacy Request

To submit a privacy request, contact us using the information in Section 17 and include:

Your full name;
Contact information;
The nature of your request;
The individual whose information is involved;
The state or jurisdiction where you reside; and
Any information reasonably necessary for verification. We may use reasonable methods to verify your identity and authority. Verification may include confirming information already associated with the account or enrollment record. We will not request sensitive information solely for verification unless reasonably necessary. We generally respond within the time required by applicable law. If additional time is permitted and needed, we will explain the reason for the delay. If we deny a request, we will explain the reason where required by law and provide appeal instructions where applicable.

14. Third-Party Links and Services

Our website or communications may contain links to third-party websites, platforms, or services. These third parties may have their own privacy policies and practices. We are not responsible for the privacy, security, content, or practices of third-party websites or services. You should review the privacy policy of each third party before submitting information.

15. Communications

We may contact parents or guardians about:

Enrollment;
Scheduling;
Check-ins;
Attendance;
Progress updates;
Document requests;
Scholarship or EMA administration;
Account or service issues;
Security matters; and
Changes to this Privacy Policy or related agreements. You may opt out of nonessential marketing communications by following the unsubscribe instructions in the communication or contacting us. We may continue sending operational or legally required communications.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post the revised policy on our website and update the “Last Updated” date. If a change materially affects how we use personal information, we will provide additional notice or obtain consent where required by law. The version in effect at the time information is collected generally governs that information, unless applicable law requires otherwise.

17. Contact Us

For privacy questions, requests, complaints, or concerns, contact:
Clear Path Framework LLC
7901 4th St N, Suite #30707, St. Petersburg, FL 33702
Privacy Contact: privacy@clearpathsystem.net
General Contact: hello@clearpathsystem.net Please do not include unnecessary sensitive information in an initial email.