Website: www.cpfinancial.net

Effective Date: January 1, 2026

ClearPath Financial and Insurance Solutions, LLC also known as ClearPath Financial(“Company,” “we,” “our,” or “us”) is committed to protecting your privacy and safeguarding your personal information.
This Privacy Policy explains how we collect, use, store, and protect information obtained through our website.

This Privacy Policy applies solely to website interactions and does not replace any client privacy notice provided pursuant to SEC Regulation S-P.

1. Information We Collect

A. Information You Voluntarily Provide
We may collect personal information when you:
- Complete contact forms
- Download materials (including Navigating Your Retirement)
- Register for events or webinars
- Subscribe to newsletters
- Schedule consultations

Information collected may include:
- Name
- Email address
- Phone number
- Mailing address
- Information submitted in message fields

We do not request Social Security numbers, brokerage account numbers, or sensitive financial account credentials through this website.

B. Automatically Collected Information
We may automatically collect:
- IP address
- Device type
- Browser type
- Pages visited
- Time on site
- Referral sources
- General geographic location (non-precise)

This data is used for analytics and website optimization.

2. How We Use Your Information

We may use collected information to:
- Respond to inquiries
- Deliver requested downloads
- Schedule appointments
- Send newsletters or educational materials
- Provide event invitations
- Improve website functionality
- Comply with regulatory obligations

We do not sell, rent, or trade personal information.

3. Marketing Communications & Email

If you opt into communications:
- You may receive newsletters, market commentary, event invitations, or firm updates.
- You may unsubscribe at any time using the link provided in each email.

Receiving communications does not establish an advisory relationship.

4. SMS/Text Messaging Disclosure

If you provide your phone number and opt in to receive text communications:
- You may receive appointment reminders, event notifications, or firm updates.
- Message frequency may vary.
- Message and data rates may apply.
- You may opt out at any time by replying STOP.
- For assistance, reply HELP or contact us directly.

We do not sell or share mobile information with third parties for marketing purposes.

5. Cookies & Tracking Technologies

We may use cookies, analytics tools (such as Google Analytics), and tracking pixels to understand website traffic and improve user experience.
You may disable cookies in your browser settings.

6. Do Not Track (DNT)

Our website does not currently respond to Do Not Track signals, as there is no uniform industry standard for compliance.

7. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information.
However, no system is completely secure, and transmission of information via the internet carries inherent risks.

8. Data Retention

We retain personal information only as long as necessary to fulfill the purposes described in this policy, as required by regulatory and legal obligations,
or for legitimate business purposes. When no longer required, data is securely deleted or anonymized.

9. Sharing of Information

We may share personal information only:
- With service providers who assist in website hosting, analytics, email communications, or scheduling platforms
- As required by law or regulatory authority
- In connection with regulatory compliance obligations

Affiliated Advisory Firm Disclosure

ClearPath Financial operates through its affiliation with Abraham & Co., Inc., a Registered Investment Advisor located in the State of Washington.

Information submitted through this website may be shared with Abraham & Co., Inc. for purposes including:
- Regulatory compliance
- Supervisory oversight
- Client onboarding
- Advisory service evaluation
- Operational and administrative support

Information may be reviewed by supervisory personnel, compliance officers, or affiliated advisory representatives as required under applicable securities laws and regulations.

Any such sharing is conducted in accordance with federal and state privacy regulations, including SEC Regulation S-P.

We do not sell personal information to third parties.

10. Breach Notification

In the event of a data breach affecting personal information, we will comply with applicable federal and state notification requirements and notify affected individuals as required by law.

11. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you may have the right to:
- Request access to personal information we collect
- Request correction of inaccurate information
- Request deletion of personal information
- Know categories of information collected
- Know whether personal information is shared
- Opt out of the sale of personal information (we do not sell personal data)

We will not discriminate against you for exercising your privacy rights.

12. Children’s Privacy

This website is not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors.

13. Third-Party Links

This website may contain links to third-party websites. We are not responsible for the privacy practices or content of external websites.

14. Regulation S-P Notice

As an affiliated representative of a Registered Investment Advisor, separate privacy notices are provided to advisory clients pursuant to SEC Regulation S-P.
This Privacy Policy applies only to website visitors and prospective clients.

15. Changes to This Policy

We reserve the right to modify this Privacy Policy at any time. Changes will be reflected by updating the Effective Date above.
Continued use of the Site constitutes acceptance of any updates.

16. Contact Information

ClearPath Financial and Insurance Solutions, LLC
Matthew Sherman
Website: www.cpfinancial.net
Email: matt@cpfinancial.net
Phone: 951-256-4466