Messaging Privacy Policy

01Purpose of This Policy

This Messaging Privacy Policy explains how ClearPath Investments ("Clear Path Investments," "we," "us," or "our") collects, uses, stores, and protects information related to our SMS and other messaging programs. It supplements our general Privacy Policy and SMS Terms & Conditions.

By opting in to receive messages from Clear Path Investments, you acknowledge and consent to the practices described below.

02Information Collected Through Messaging

When you opt in to receive messages or communicate with us via SMS or messaging platforms, we may collect:

• Phone Number: The mobile number associated with your opt-in.
• Opt-In Records: Date, time, IP address (if collected via web form), method of opt-in, and the exact consent language displayed at the time.
• Message Content: The content of messages you send to us and our replies, including timestamps and delivery status.
• Engagement Data: Information about which messages you open, respond to, or opt out of, used internally for service improvement.
• Related Profile Data: Name, property address, and other details you provide in connection with a property inquiry or transaction.

03How We Use Messaging Information

Information collected through our messaging program is used to:

• Send and receive messages relating to your inquiry, property, transaction, or marketing preferences.
• Schedule appointments, provide notifications, and coordinate closing or follow-up activities.
• Respond to questions and provide customer support.
• Demonstrate compliance with applicable telecommunications laws and carrier requirements.
• Improve message quality, deliverability, and the overall communications experience.
• Detect and prevent fraud, abuse, and security threats.

04Mobile Information & Third-Party Sharing

Mobile information may be shared in a limited fashion only with:

• Subcontractors & Service Providers: Vetted vendors operating under contractual confidentiality obligations that help us deliver the messaging program, including our CRM, SMS platform provider, compliance auditors, and similar operational tools. These providers may not use mobile information for their own marketing or promotional purposes.
• Legal Compliance: When required by law, subpoena, regulatory request, or court order, or to enforce our rights and the terms of our agreements.
• Carriers: As necessary to route, deliver, and verify message delivery through wireless networks.

05Opt-Out & Data Deletion

You may opt out of receiving SMS messages from us at any time by replying STOP to any text message. After processing your opt-out, you may also request:

• Confirmation of your opt-out status.
• Deletion of your phone number from active messaging lists, subject to retention of consent records as required by law.
• A copy of the messaging-related information we hold about you.

To make a request, email us at [email protected] with the subject line "Messaging Data Request."

06Data Retention

We retain messaging records — including opt-in proof, message content, and engagement data — for the period required to:

• Demonstrate compliance with the Telephone Consumer Protection Act (TCPA), CTIA Messaging Principles, A2P 10DLC requirements, and other applicable regulations.
• Resolve disputes and enforce agreements.
• Meet our legal, accounting, and operational obligations.

Once retention periods expire, we securely delete or anonymize the relevant data.

07Security Safeguards

We use reasonable administrative, technical, and physical safeguards designed to protect messaging-related information against unauthorized access, alteration, disclosure, or destruction. These include encryption in transit where supported, access controls, audit logging, and vendor risk reviews. However, no system is 100% secure and we cannot guarantee absolute security.

08Children & Age Requirement

The messaging program is not directed to anyone under 18. You confirm you are at least 18 years old (or the age of majority in your jurisdiction, whichever is higher) when you opt in. If we learn we have collected mobile information from someone under 18, we will delete it promptly.

09International Users

The messaging program is intended for use within the United States. If you opt in from outside the U.S., you understand and consent that your information may be processed and stored in the United States, which may have data protection laws different from your jurisdiction.

10Changes to This Policy

We may update this Messaging Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Updates will be posted on this page with a revised effective date.

11Contact Us

For privacy-related questions about our messaging program, contact us: