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Privacy Policy
How Clear Path Consulting LLC collects, uses, shares and protects personal information — and the choices you have.
Contents
- Who we are
- Scope of this policy
- Information we collect
- How we use information
- Legal bases for processing
- Cookies and tracking
- Advertising and campaign data
- How we share information
- International transfers
- How long we keep information
- How we protect information
- Your rights and choices
- US state privacy rights
- Children’s privacy
- Third-party sites
- Changes to this policy
- How to contact us
1. Who we are
Clear Path Advertising is the trading name of Clear Path Consulting LLC (“we”, “us”, “our”), a business-to-business advertising and offer management company with its place of business at 3089 Kellogg Creek Rd, Acworth, GA, 30102, USA. We are the controller of the personal information described in this policy unless we state otherwise.
Questions about this policy or about how we handle personal information should go to contact@clearpath-advertising.com.
2. Scope of this policy
This policy covers personal information we collect through:
- this website and any forms, downloads or subscriptions on it;
- direct business communications such as email, calls and meetings;
- our commercial relationships with advertisers, publishers and prospective partners; and
- campaign and offer data we process in the course of providing our services.
It does not cover the independent privacy practices of advertisers, publishers or platforms we work with. Where an offer is distributed through a publisher and a user submits information on an advertiser’s landing page, that advertiser is the controller of the information submitted, and their own privacy notice governs it.
3. Information we collect
3.1 Information you give us
- Contact and enquiry details — name, company, work email, website, role, vertical, indicative budget or audience volume, and the content of your message.
- Partner onboarding information — business details, traffic sources, payment and tax details where required to pay a publisher, and compliance documentation.
- Correspondence — records of communications with our team, including notes taken during calls.
3.2 Information collected automatically
- Device and usage data — IP address, browser type and version, operating system, referring URL, pages viewed, time on page, and approximate location derived from IP.
- Cookie and similar identifiers — as described in our Cookie Policy.
3.3 Information from third parties
- Advertising platforms — aggregate campaign performance and, where you arrived via a paid ad, non-identifying click and conversion signals.
- Business data providers — publicly available firmographic details used to verify a business enquiry.
- Partners — where an advertiser or publisher shares campaign data with us under a written agreement.
We do not knowingly collect special category data, financial account information from website visitors, or personal information about individuals in a non-business capacity through this site.
4. How we use information
| Purpose | What this involves |
|---|---|
| Responding to enquiries | Replying to your message, assessing fit, and arranging follow-up conversations |
| Providing our services | Managing offers, matching, campaign delivery, reporting and payouts under a partner agreement or insertion order |
| Compliance oversight | Reviewing offers, creative and placements; investigating compliance reports; maintaining records of approvals |
| Business operations | Invoicing, accounting, contract administration and dispute resolution |
| Website improvement | Understanding how the site is used so we can improve content, structure and performance |
| Marketing | Sending business communications about our services where permitted, always with an opt-out |
| Security and fraud prevention | Protecting our systems, detecting invalid traffic, and preventing abuse of offers |
| Legal obligations | Meeting tax, accounting, regulatory and law-enforcement requirements |
We do not sell personal information, and we do not share personal information with third parties for their own independent marketing purposes.
5. Legal bases for processing
Where data protection law requires us to identify a legal basis, we rely on:
- Legitimate interests — running and improving a B2B business, responding to enquiries, securing our systems and maintaining compliance records, balanced against your rights;
- Performance of a contract — delivering services under a partner agreement or insertion order;
- Consent — for non-essential cookies and for marketing communications where consent is required, withdrawable at any time; and
- Legal obligation — where we must retain or disclose information by law.
6. Cookies and tracking
We use a small number of cookies and similar technologies for essential site function, analytics and advertising measurement. Because we run paid campaigns on search, social and native platforms, some of those platforms may set measurement identifiers when you arrive from one of their placements. Full detail, including how to control them, is in our Cookie Policy.
7. Advertising and campaign data
In the course of providing our services we process campaign data on behalf of advertisers and publishers. In most of these arrangements we act as a processor or service provider, handling data under the instructions of the advertiser or publisher who is the controller.
Campaign data typically includes click and impression identifiers, conversion events, timestamps, source and placement identifiers, and — where an offer involves a form submission — the business contact details the user chose to provide. The offer documentation for each campaign states what is collected, who receives it, and what the user is told at the point of capture.
If you submitted your details through an offer and want them corrected or deleted, the fastest route is to contact the advertiser named on the page where you submitted them, since they hold the record. If you are unsure who that was, email us at contact@clearpath-advertising.com with the date and the site you saw it on and we will help you identify them.
8. How we share information
We share personal information only where necessary, and only with:
- Advertisers and publishers — to the extent required to deliver, verify and pay for a campaign under a written agreement;
- Service providers — hosting, email, analytics, tracking, accounting and payment providers acting on our instructions under contract;
- Professional advisers — lawyers, accountants and auditors bound by confidentiality;
- Authorities — where required by law, regulation, court order or to protect our legal rights; and
- A successor entity — in connection with a merger, acquisition or sale of assets, subject to this policy continuing to apply.
9. International transfers
We are based in the United States and our service providers may process information in the United States and other countries. Where we receive personal information from individuals in the United Kingdom, the European Economic Area or another jurisdiction with transfer restrictions, we put appropriate safeguards in place — typically standard contractual clauses or an equivalent recognised mechanism — before that information is transferred.
10. How long we keep information
| Category | Typical retention |
|---|---|
| Website enquiries that do not proceed | Up to 24 months from last contact |
| Partner and client records | Duration of the relationship plus 7 years, for tax and contractual purposes |
| Campaign and compliance records | Up to 7 years, so placements and approvals remain auditable |
| Marketing contact records | Until you opt out, then a suppression record kept indefinitely to honour that opt-out |
| Website analytics | Generally 14 to 26 months depending on the tool |
Where a longer period is required by law or by an unresolved dispute, we keep the relevant records until that requirement ends.
11. How we protect information
We apply administrative, technical and physical safeguards proportionate to the sensitivity of the information we hold: encryption in transit, access controls on a need-to-know basis, vendor due diligence, and contractual confidentiality obligations on staff and contractors. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a breach affecting your personal information occurs, we will notify you and the relevant authorities where the law requires it.
12. Your rights and choices
Depending on where you are located, you may have the right to:
- access the personal information we hold about you;
- have inaccurate information corrected;
- have information deleted in certain circumstances;
- object to or restrict certain processing, including direct marketing;
- receive a portable copy of information you provided to us;
- withdraw consent where we relied on it; and
- lodge a complaint with your supervisory authority.
To exercise any of these, email contact@clearpath-advertising.com. We will respond within the period required by applicable law — generally within 30 to 45 days — and may need to verify your identity first. Exercising these rights is free, and we will not treat you differently for doing so.
You can opt out of our marketing emails at any time using the unsubscribe link in any message, or by emailing us. Opting out of marketing does not stop operational messages about an active campaign or account.
13. US state privacy rights
Residents of states with comprehensive privacy legislation — including California, Colorado, Connecticut, Virginia, Utah and others as those laws take effect — have rights to know, access, correct, delete and port personal information, to opt out of targeted advertising and of any sale or sharing of personal information, and to be free from discrimination for exercising those rights.
We do not sell personal information, and we do not share personal information for cross-context behavioural advertising as those terms are defined under the California Consumer Privacy Act. We have not done so in the preceding twelve months.
To submit a request, email contact@clearpath-advertising.com with “Privacy request” in the subject line and tell us which right you are exercising and the state you reside in. An authorised agent may submit a request on your behalf with written proof of authorisation. If we decline a request you may appeal by replying to our decision, and we will respond to the appeal within the period your state’s law allows.
14. Children’s privacy
Our services are directed exclusively at businesses and business professionals. We do not knowingly collect personal information from anyone under 18. If you believe a child has provided us with personal information, contact us and we will delete it.
15. Third-party sites
This site and the campaigns we manage link to third-party websites, including advertiser landing pages and publisher properties. We are not responsible for the content or privacy practices of those sites, and we encourage you to read their privacy notices before providing information to them.
16. Changes to this policy
We may update this policy to reflect changes to our practices, technology or legal obligations. The “last updated” date at the top of this page shows when it last changed. Where changes are material, we will take reasonable steps to notify partners and contacts directly. Continued use of the site after an update constitutes acceptance of the revised policy.
17. How to contact us
- EntityClear Path Consulting LLC, trading as Clear Path Advertising
- Postal address3089 Kellogg Creek Rd, Acworth, GA, 30102, USA
- Emailcontact@clearpath-advertising.com