HOTPATH LLC — PRIVACY POLICY

Effective Date: August 1, 2026

1. INTRODUCTION

Hotpath LLC ("Hotpath," "we," "us") respects your privacy. This Privacy Policy describes how we collect, use, and protect personal information when you visit our website, communicate with us, or engage our services.

2. TWO ROLES: OUR CLIENTS' DATA VS. END-USER DATA

2.1 Data About Our Clients (We Are the Controller). When you engage us or contact us, we collect and control information about you and your business, as described in this Policy.

2.2 End-User Data Processed Through Deliverables (We Are a Processor). The interfaces we build for clients may process personal information belonging to our clients' own customers, leads, and end users ("End-User Data"). For End-User Data, our client is the controller and Hotpath acts solely as a processor/service provider, handling such data only under the client's instructions and the applicable agreement. A Data Processing Agreement (DPA) is available upon request for engagements involving End-User Data. End users should direct privacy inquiries to the business they interacted with.

3. INFORMATION WE COLLECT

Information you provide: name, email, phone, company, business details, project requirements, files and feedback, and billing information (payment card details are processed by our payment processors and are not stored by us).

Information collected automatically: IP address, browser and device type, pages visited, and service usage data such as error logs and performance metrics.

4. HOW WE USE INFORMATION

To deliver and improve our services; communicate about projects; process payments; secure our systems; and comply with legal obligations. We do not sell or rent personal information, and we do not share it with third parties for their own marketing.

5. SHARING AND SUBPROCESSORS

We share information only with service providers who help us operate, under confidentiality obligations, including: payment processing (e.g., Stripe), cloud hosting and infrastructure providers, and communication tools. We may also disclose information if required by law or to protect our legal rights. A current list of subprocessors relevant to your engagement is available upon request.

6. THIRD-PARTY PLATFORMS

Deliverables may integrate with third-party platforms (such as GoHighLevel). Data transmitted to those platforms is governed by their own privacy policies, which we encourage you to review. We are not responsible for third-party privacy practices.

7. DATA RETENTION

We retain client project data and communications for as long as needed to provide services and meet legal, tax, and accounting obligations — typically three (3) years after project completion — then delete or anonymize it. You may request earlier deletion, subject to legal retention requirements.

8. SECURITY

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information, consistent with applicable law, including Oregon's information security requirements. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a breach of security affects your personal information, we will notify you and applicable regulators as required by law.

9. YOUR RIGHTS

Depending on your jurisdiction, you may have the right to access, correct, or delete your personal information, or to withdraw consent to processing. To exercise any of these rights, contact us at [email protected]. We will respond within the timeframe required by applicable law.

10. COOKIES AND DO NOT TRACK

Our website may use cookies and similar technologies for functionality and analytics. You can disable cookies in your browser settings, though some features may not function. Our website does not currently respond to browser "Do Not Track" signals, as no uniform standard for such signals has been adopted.

11. CHILDREN'S PRIVACY

Our services are intended for businesses and are not directed to individuals under 18. We do not knowingly collect information from children; if we learn we have, we will delete it.

12. CHANGES TO THIS POLICY

We may update this Policy from time to time. For material changes, we will notify active clients by email at least thirty (30) days before the changes take effect. The "Effective Date" above reflects the latest revision.

13. CONTACT

Hotpath LLC
Email: [email protected]
Address: 4713 Milo Ave NE, Suite 1A, Salem, OR 97301