HealthPath Solutions Website Privacy Policy

HealthPath Solutions LLC ("HealthPath Solutions," "HealthPath," "we," "us," or "our") respects your privacy. This Website Privacy Policy explains how we collect, use, disclose, retain, and protect information when you visit or interact with our public website, https://healthpathsolutions.us (the "Website").

HealthPath Solutions is a healthcare systems design, strategic consulting, and administrative services company headquartered in Tampa, Florida, with national operations. This Policy applies to information collected through the Website and does not necessarily apply to information collected through separate client engagements, employment processes, contracts, or other HealthPath systems that may be governed by additional notices or agreements.

By using the Website, you acknowledge the practices described in this Policy. If you do not agree with this Policy, please do not use the Website.

1. Important Health Information and HIPAA Notice

The Website is a public informational and business website. It is not intended to collect, transmit, store, or process protected health information ("PHI") and is not a substitute for a secure client portal, patient portal, electronic health record, or other approved healthcare information system.

Do not submit PHI or other sensitive health information through the Website, including through contact forms, newsletter forms, comments, email links, downloads, or other interactive features. Do not submit patient names, diagnoses, treatment information, medical records, insurance information, account numbers, dates of birth, Social Security numbers, or similar information.

HealthPath Solutions does not intend to create a business associate relationship through ordinary use of the Website. The Website hosting provider is not intended to exchange medical information with HealthPath Solutions, and HealthPath Solutions does not currently require a business associate agreement with the Website hosting provider for the public Website.

If you voluntarily submit PHI or other sensitive information through the Website, we may take reasonable steps to delete it, restrict access to it, or handle it as necessary to protect privacy, security, and legal interests. However, transmission through a public website or ordinary email may not be secure, and HealthPath Solutions cannot guarantee that such information will be treated as PHI under HIPAA.

2. Information We Collect

The categories of information we collect depend on how you interact with the Website.

2.1 Information You Provide Directly

You may provide information when you:

• Submit a contact or inquiry form;
• Request information about our services;
• Subscribe to a newsletter or other email communications;
• Download a report, guide, or other resource;
• Submit a question, comment, or other communication;
• Apply for an opportunity, if an application feature is made available;
• Contact us by email or telephone using information displayed on the Website; or
• Otherwise communicate or interact with HealthPath Solutions.

Information may include:

• Name;
• Practice or organization;
• Work email address;
• Telephone number;
• Role/title (optional);
• State (optional); and
• Information requested (optional, such as a message or details about your inquiry).

Please provide only information reasonably necessary for your inquiry. Do not include PHI, financial account numbers, government identification numbers, passwords, or other highly sensitive information in a form or message unless HealthPath Solutions expressly directs you to use an approved secure method.

2.2 Information Collected Automatically

When you visit the Website, certain information may be collected automatically, including:

• Internet Protocol ("IP") address;
• Approximate geographic location derived from IP address;
• Browser type and version;
• Device type, operating system, and language;
• Screen resolution and other device characteristics;
• Referring website or search terms;
• Pages viewed and links clicked;
• Date, time, duration, and frequency of Website visits;
• Website navigation and interaction data;
• Error logs and diagnostic information;
• Campaign, referral, and attribution information; and
• Information about how you interact with emails or other communications, where applicable.

This information may be collected through cookies, pixels, tags, log files, software development kits, and similar technologies.

2.3 Cookies and Similar Technologies

The Website uses, or may use, cookies and similar technologies to operate the Website, remember preferences, understand Website usage, improve functionality, measure performance, and support communications and marketing activities.

Cookies may include:

• Strictly necessary cookies: Required for basic Website operation, security, form functionality, or consent-management features;
• Functional cookies: Used to remember preferences and improve Website functionality;
• Analytics cookies: Used to measure traffic, engagement, navigation, and Website performance;
• Advertising or marketing cookies: Used only if enabled to support advertising, campaign measurement, or cross-context behavioral advertising; and
• Preference or consent cookies: Used to remember cookie choices.

The Website may use Google Analytics, including Google Analytics 4 ("GA4"), for Website analytics.

Optional analytics cookies will run only after you provide consent through the cookie banner or preference center (where required or appropriate).

Cookies and local storage may include the consent preference itself and related consent records.

2.4 Information from Third Parties

We may receive information from third parties, such as:

• Analytics providers (for example, Google Analytics/GA4);
• Email or newsletter providers;
• Website hosting, security, and form-processing providers;
• Social media platforms;
• Search engines; and
• Service providers assisting with Website operations.

3. Cookie Consent and Your Choices

The Website will display a cookie consent banner or preference center where required or appropriate. Through the banner or preference center, you may be able to:

• Accept all cookies;
• Reject or disable non-essential cookies;
• Select categories of cookies;
• Change or withdraw consent;
• Review cookie purposes; and
• Access this Privacy Policy and related privacy information.

Strictly necessary cookies may remain active because the Website may not function properly without them.

Your browser may also allow you to block, delete, or restrict cookies. Disabling cookies may affect Website functionality, form submission, analytics accuracy, or your ability to save preferences.

If the Website uses advertising, targeted advertising, or cross-context behavioral advertising, the Website will provide applicable opt-out tools, including a "Your Privacy Choices" or "Do Not Sell or Share My Personal Information" link where required.

4. How We Use Information

We may use information for the following business and operational purposes:

• Responding to inquiries and requests;
• Communicating about HealthPath Solutions, our services, reports, events, or resources;
• Delivering newsletters and other requested communications;
• Managing subscriptions and communication preferences;
• Providing, maintaining, securing, and improving the Website;
• Measuring Website traffic, engagement, and performance;
• Understanding how visitors use the Website;
• Diagnosing errors and preventing fraud, abuse, and security incidents;
• Managing downloads, registrations, and other Website interactions;
• Personalizing Website content or preferences, where permitted;
• Evaluating and improving marketing campaigns;
• Maintaining records and enforcing our agreements and policies;
• Complying with applicable legal, regulatory, and contractual requirements;
• Protecting the rights, property, safety, and security of HealthPath Solutions, Website users, and others; and
• Supporting legitimate business operations, including corporate transactions.

We may also use information for other purposes disclosed at the time of collection or otherwise permitted by applicable law.

We do not use information collected through the public Website to provide medical diagnosis or treatment. We do not accept PHI through ordinary Website features.

5. Legal Bases and Business Purposes

Depending on the circumstances and applicable law, HealthPath Solutions may process personal information because:

• You have requested information or services;
• Processing is necessary to respond to your inquiry;
• Processing is necessary to perform or prepare for a contract;
• Processing supports our legitimate business interests;
• You have provided consent, such as consent to optional cookies or marketing communications;
• Processing is necessary to comply with a legal obligation; or
• Processing is necessary to protect rights, safety, security, or property.

Where consent is required, you may withdraw it at any time. Withdrawal does not affect processing that occurred before withdrawal.

6. Email and Newsletter Communications

If you subscribe to a newsletter or other marketing communication, we may use your email address and subscription preferences to send the requested communications.

You may unsubscribe by:

• Selecting the unsubscribe link in an email;
• Using the communication preference tool, if provided; or
• Contacting us using the information in Section 19.

Even if you opt out of marketing communications, we may continue to send non-promotional administrative or transactional communications when reasonably necessary.

7. How We Share Information

We may disclose personal information to the following categories of recipients:

7.1 Service Providers and Processors

We may share information with vendors and service providers that perform services for us, including:

• Website hosting and infrastructure providers;
• Website security and monitoring providers;
• Form and submission-processing providers;
• Analytics providers (including Google Analytics/GA4);
• Email and newsletter providers;
• Customer relationship management or inquiry-management providers;
• Cloud storage and business systems providers;
• Website maintenance and development providers;
• Professional advisers;
• Information technology and support providers; and
• Legal, accounting, and compliance service providers.

These providers may process information only as reasonably necessary to provide services to HealthPath Solutions, subject to applicable agreements and legal requirements.

7.2 Business Transfers

Information may be disclosed as part of an actual or contemplated merger, acquisition, financing, reorganization, sale of assets, bankruptcy, dissolution, or other corporate transaction.

7.3 Legal, Safety, and Security Disclosures

We may disclose information when reasonably necessary to:

• Comply with law, regulation, legal process, subpoena, or governmental request;
• Protect the rights, property, safety, or security of HealthPath Solutions or others;
• Detect, investigate, prevent, or respond to fraud, abuse, security incidents, or unlawful conduct;
• Enforce Website terms, policies, or agreements; or
• Establish, exercise, or defend legal claims.

7.4 With Your Direction or Consent

We may disclose information when you direct us to do so or otherwise consent.

8. Sale and Sharing of Personal Information

HealthPath Solutions does not sell personal information for monetary consideration.

If applicable law treats certain disclosures to analytics providers as "sharing" for cross-context behavioral advertising, California residents and other consumers with applicable legal rights may opt out through the Website's "Your Privacy Choices" or "Do Not Sell or Share My Personal Information" mechanism, if present.

Where legally required, HealthPath Solutions will process recognized opt-out preference signals, including Global Privacy Control, in accordance with applicable law and technical capability.

9. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including to:

• Provide requested communications or services;
• Maintain business and transaction records;
• Resolve disputes;
• Enforce agreements;
• Prevent fraud and abuse;
• Protect Website and information security;
• Comply with legal, tax, accounting, regulatory, or contractual obligations; and
• Establish, exercise, or defend legal claims.

Retention periods vary depending on the type of information, the purpose of collection, the sensitivity of the information, legal requirements, and operational needs. When information is no longer reasonably necessary, we may delete, anonymize, aggregate, or securely dispose of it.

In general, we retain:

• Contact form submissions for as long as reasonably necessary to respond to your inquiry, maintain business records, and administer our relationships;
• Newsletter or insights-list signup records until you unsubscribe or we no longer maintain the list, subject to legal/operational requirements;
• Analytics data and related identifiers for a limited period consistent with our analytics configuration and business needs;
• Cookie-consent records and preference data for as long as reasonably necessary to demonstrate and honor your choices; and
• Server, security, and access logs for a limited period reasonably necessary for security, troubleshooting, fraud prevention, and compliance.

10. Security

HealthPath Solutions maintains administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, disclosure, or destruction. Safeguards may include access controls, authentication, encryption where appropriate, secure service-provider configurations, monitoring, backup practices, workforce policies, and incident-response procedures.

No method of transmission or storage is completely secure. We cannot guarantee the absolute security of information transmitted to or stored by HealthPath Solutions or its service providers.

Because the Website is public and is not designed to receive PHI, do not submit PHI or other highly sensitive information through Website forms, comments, email links, or other public features.

11. Data Privacy Governance

HealthPath Solutions maintains privacy and security practices informed by its Data Privacy Impact Assessment process, HIPAA and confidentiality practices, applicable law, contractual commitments, and reasonable risk-based safeguards.

We may conduct reviews of new Website features, data uses, third-party tools, cookies, analytics, forms, and other processing activities to identify and address privacy and security risks.

12. Your Privacy Rights and Choices

Depending on your location and applicable law, you may have the following rights regarding personal information:

• Right to know or access: Request information about the categories and specific pieces of personal information we collect, use, disclose, or otherwise process;
• Right to correct: Request correction of inaccurate personal information;
• Right to delete: Request deletion of personal information, subject to legal and operational exceptions;
• Right to data portability: Request a copy of certain personal information in a portable and usable format;
• Right to opt out: Opt out of the sale of personal information, sharing for cross-context behavioral advertising, targeted advertising, or certain profiling activities, where applicable;
• Right to limit: Request limits on the use or disclosure of sensitive personal information where applicable;
• Right to withdraw consent: Withdraw consent for processing based on consent;
• Right to object or restrict: Object to or request restriction of certain processing activities where provided by applicable law;
• Right to appeal: Appeal a decision regarding a privacy-rights request where required by applicable law; and
• Right to nondiscrimination: Receive equal treatment and not be discriminated against for exercising applicable privacy rights.

These rights are subject to exceptions, limitations, verification requirements, and other conditions under applicable law. For example, HealthPath Solutions may retain information necessary to comply with law, complete a transaction, detect security incidents, resolve disputes, or protect legal rights.

13. California Privacy Rights

This section applies to California residents to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), applies to HealthPath Solutions' processing activities.

California residents may have the right to:

• Know and access categories and specific pieces of personal information;
• Know the categories of sources, purposes, and recipients associated with personal information;
• Correct inaccurate personal information;
• Request deletion of personal information, subject to exceptions;
• Opt out of the sale or sharing of personal information;
• Limit the use or disclosure of sensitive personal information in circumstances covered by law;
• Opt out of certain targeted or cross-context behavioral advertising activities;
• Receive equal treatment for exercising privacy rights; and
• Use an authorized agent to submit a request, subject to verification and authorization requirements.

HealthPath Solutions does not knowingly sell personal information for monetary consideration. If any Website technology is determined to constitute "sharing" under the CCPA/CPRA, California residents may use the Website's applicable opt-out mechanism or contact us using the information in Section 19.

13.1 Submitting a California Request

A California resident may submit a request by:

• Email: info@healthpathsolutions.us.

We may need to verify your identity before completing an access, correction, or deletion request. Verification measures will be reasonably proportionate to the nature and sensitivity of the request. We will not request unnecessary sensitive information solely for verification.

Authorized agents may submit requests on your behalf where permitted by law. We may require evidence of authorization and may verify the identity of both the requester and the individual on whose behalf the request is submitted.

HealthPath Solutions processes verified requests in accordance with applicable law and explains any permitted extension when necessary.

14. Other State Privacy Rights

Residents of other states may have privacy rights under applicable state privacy laws, including rights to access, correct, delete, obtain, or port personal information, opt out of targeted advertising, opt out of the sale of personal information, opt out of certain profiling, or appeal a privacy-request decision.

The availability and scope of these rights depend on the applicable law, the consumer's location, the nature of the information, and whether HealthPath Solutions is subject to the relevant law. HealthPath Solutions will process qualifying requests in accordance with applicable legal requirements.

To exercise a privacy right, contact us using Section 19. If we deny a request and applicable law provides an appeal right, you may appeal by contacting us at info@healthpathsolutions.us.

15. Do-Not-Track and Global Privacy Control

Some browsers and devices offer "Do Not Track" settings. Because there is not a uniform industry standard for responding to Do Not Track signals, the Website may not respond to all such signals.

Where required by applicable law and supported by the Website's technical configuration, HealthPath Solutions will recognize and process recognized opt-out preference signals, including Global Privacy Control, as a request to opt out of applicable sale, sharing, targeted advertising, or similar activities.

16. Children's Privacy

The Website is intended for a general audience and is not directed to children under 16. HealthPath Solutions does not knowingly collect personal information from children under 13 through the Website.

We request that children under 16 not submit personal information through the Website. If we learn that we have collected personal information from a child in violation of applicable law, we will take reasonable steps to delete it.

If you believe a child has submitted personal information to us, contact us using Section 19.

17. Third-Party Websites and Services

The Website may contain links to third-party websites, services, social media platforms, publications, vendors, or other resources. These third parties may collect information under their own privacy policies and terms.

HealthPath Solutions does not control and is not responsible for the privacy, security, availability, content, or practices of third-party websites or services. A link does not necessarily constitute an endorsement, sponsorship, or recommendation.

Please review the privacy policies of third parties before providing them with information.

18. Accessibility

HealthPath Solutions seeks to make the Website accessible and usable for visitors with disabilities and works toward alignment with applicable accessibility expectations, including WCAG-aligned practices and HealthPath Solutions' accessibility policies.

If you experience difficulty accessing any Website content or feature, please contact us at info@healthpathsolutions.us so we can assist you.

19. Contact Information

For questions about this Privacy Policy, Website privacy practices, or privacy-rights requests, contact:

20. Changes to This Privacy Policy

HealthPath Solutions may update this Privacy Policy from time to time to reflect changes in Website features, data practices, technology, service providers, legal requirements, or business operations.

When we make material changes, we may provide notice through the Website, update the "Last Updated" date, or use another legally appropriate method. Your continued use of the Website after an updated Policy becomes effective means that you acknowledge the revised Policy, to the extent permitted by law.

We encourage you to review this Policy periodically.

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