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Terms of Service & Privacy Policy

Last Updated: October 24, 2025

Terms of Service

Terms of Service for Willow Path Services

Willow Path Co. (Willow Path or we) offers a web application designed to assist individuals plan for their future and / or adjust to life moments (together, Willow Path Services). Willow Path Services subject to these Willow Path Terms of Service (Willow Path Terms).

PLEASE READ THESE TERMS CAREFULLY. THESE TERMS INCLUDE IMPORTANT INFORMATION ABOUT YOUR RELATIONSHIP WITH WILLOW PATH.

BY CLICKING A BUTTON OR CHECKING A BOX INDICATING ACCEPTANCE OF THESE TERMS OR OTHERWISE AFFIRMATIVELY ACTIVATING OR USING THE WILLOW PATH SERVICES, YOU AFFIRM TO WILLOW PATH THAT YOU UNDERSTAND AND AGREE TO THESE TERMS AND THE WILLOW PATH POLICY.

IF YOU DO NOT AGREE WITH THESE TERMS, YOU ARE NOT AUTHORIZED TO USE THE WILLOW PATH WEB APPLICATION.

1. Key Definitions

For your convenience, many of the capitalized terms that we use in these Willow Path Terms are defined in this Section 1:

Services Data means data that are generated by or derived from Users' use of the Willow Path Services.

Willow Path means businesses that offer products and services through the Willow Path Services.

Territory means the United States and its territories and possessions.

Partner Content means technology and services provided by a third party that interoperate with or otherwise support the Willow Path Services, such as security and hosting service providers.

User Data means data (including Personal Information, as defined in the Willow Path Privacy Policy) in any form or medium that is transmitted to or through the Willow Path Services or otherwise made available by a Customer and/or Users in connection with the Willow Path Services but excluding Services Data.

User or you means the person accessing and using the Willow Path Services to help with caregiving responsibilities pursuant to Willow Path's contract with a Customer.

2. How These Willow Path Terms Apply

These Terms apply to the Willow Path Services. After you initially accept these Willow Path Terms, you agree to the latest version of these Willow Path Terms when you access and use the Willow Path Services. Certain Willow Path Services may require that you agree to additional legal terms (Service Specific Terms). If any term of these Willow Path Terms conflicts with any of the Service Specific Terms, then the Service Specific Terms control with respect to the Willow Path Services to which they relate.

Willow Path may have agreements with Willow Path Partners that contain terms applicable to certain Willow Path Services or Users that are different from these Willow Path Terms. The Willow Path Partner's agreement applies instead of these Willow Path Terms only when expressly presented within the Willow Path Services and only to the extent of any conflict or inconsistency.

If you have a question about whether these Willow Path Terms apply to you, please contact support@willow-path.com.

3. Accessing the Willow Path Services

3.1 Access

Each User must provide their name and email to use the Willow Path Services.

Willow Path may, in its sole discretion, suspend or terminate access to the Willow Path Services if account information is inaccurate, out of date or incomplete (or if Willow Path reasonably believes it is). If you believe that your account is no longer secure, then you must immediately notify Willow Path at support@willow-path.com.

3.2 Right to Use Willow Path Services

Subject to your compliance with these Willow Path Terms and applicable Service Specific Terms, Willow Path and its licensors grant you the limited, non-exclusive, non-transferable, non-sub-licensable and revocable right to access and use the Willow Path Services in the Territory. Willow Path reserves all rights that are not expressly granted in these Willow Path Terms. Willow Path makes the Willow Path Services available in compliance with laws applicable to Willow Path and not necessarily in compliance with laws applicable to your specific use of the Willow Path Services.

The Willow Path Services may include software offered under an open-source license with use requirements that supplement these Willow Path Terms. The Willow Path Services may contain links to third-party websites and services for informational purposes. These websites and services are not under Willow Path's control and Willow Path is not responsible for their content.

4. Your Responsibilities

You are solely responsible for:

  • Compliance with these Willow Path Terms, including use of the Willow Path Services and decisions and actions based on use of the Willow Path Services;
  • The lawfulness of User Data and Feedback (defined below);
  • The products and services made available by Willow Path Partners that you choose to use and associated fees;
  • Your compliance with all applicable laws and regulations related to your use of the Willow Path Services;
  • The security and use of your Access Credentials and all activities that occur through those Account Credentials. (Please immediately notify Willow Path at support@willow-path.com if you detect or suspect unauthorized activity.);
  • Use of reasonable and appropriate administrative, physical and technical safeguards to protect against unauthorized access to or use of the Willow Path Services;
  • Reasonably cooperating with Willow Path when Willow Path believes your use of the Willow Path Services violates law or any other part of these Willow Path Terms; and
  • The hardware and other equipment and internet connection through which you access and use the Willow Path Services (including operation, maintenance and management) and all access to and use of the Willow Path Services directly or indirectly through that equipment and internet connection.

You are responsible for your use of the Willow Path Services, and you will defend and indemnify Willow Path and its officers, directors, employees, consultants, licensors, affiliates, subsidiaries and agents (together, the Willow Path Entities) from and against every claim brought by a third party, and any related liability, damage, loss and expense, including reasonable attorneys' fees and costs, arising out of or connected with: (a) your unauthorized use or misuse of the Willow Path Services; (b) your violation of these Willow Path Terms or applicable law; (c) any dispute or issue between you and any Willow Path Partner or other third party; and (d) violation of any third-party intellectual property, publicity, confidentiality, privacy or other legal property right. Willow Path reserves the right, at our own expense, to assume the exclusive defense and control of any matter subject to indemnification (without limiting your indemnification obligations with respect to that matter) and you agree to cooperate with Willow Path's defense of those claims.

5. Conditions of Use

5.1 Acceptable Use

You understand and agree that you will not (and will use best efforts not to enable a third party to):

  • copy, modify, frame, mirror or create derivative works or improvements of the Willow Path Services;
  • rent, lease, lend, sell, sublicense, assign, distribute, publish, transfer or otherwise make available any of the Willow Path Services to any third party, including on or in connection with the internet or any time-sharing, service bureau, software as a service, cloud or other technology or service;
  • reverse engineer, disassemble, decompile, decode, adapt or otherwise attempt to derive or gain access to the source code of the Willow Path Services, in whole or in part;
  • bypass or breach any security device or protection used for the Willow Path Services or access or use the Willow Path Services other than with your own valid Access Credentials;
  • input, upload, transmit or otherwise provide to or through the Willow Path Services any User Data or other information or materials that are unlawful or injurious to Willow Path or any third party or contain, transmit or activate any virus, worm, malware or other malicious computer code;
  • damage, destroy, disrupt, disable, impair or otherwise impede or harm in any manner the Willow Path Services or Willow Path's provision of the Willow Path Services, in whole or in part;
  • remove, delete, alter or obscure any copyright, trademark, patent or other intellectual property or proprietary rights notice from any of the Willow Path Services;
  • access or use the Willow Path Services in any manner or for any purpose that infringes, misappropriates or otherwise violates any right of any third party (including by any unauthorized access to, misappropriation, use, alteration, destruction or disclosure of the data of any other customer) or that violates any applicable law;
  • access or use the Willow Path Services for purposes of competitive analysis of the Willow Path Services, the development, provision or use of a competing product or service or any other purpose that is to Willow Path's detriment or commercial disadvantage; or
  • otherwise access or use the Willow Path Services beyond the scope of the authorization expressly granted under these Willow Path Terms.

The Willow Path Services are not targeted for use by minors.

5.2 Disclosure of User Data

Customer and Users agree that Willow Path may disclose User Data if (i) Willow Path believes that disclosure is reasonably necessary to comply with any law or a request from a government regulator or communications service provider that Willow Path believes in good faith is lawful, (ii) to enforce our agreements and policies, (iii) to protect the security or integrity of the Willow Path Services, (iv) to protect ourselves, our other customers or the public from harm or illegal activities, or (v) to respond to an emergency that Willow Path believes in good faith requires us to disclose User Data.

5.3 Monitoring

Willow Path does not control how Users use the Willow Path Services or data that Users submit to or transmit through the Willow Path Services. You understand that, when using the Willow Path Services, you may be exposed to content from a variety of sources and acknowledge that the content may be inaccurate, offensive, indecent or objectionable.

You are solely responsible for your User Data and the consequences of providing User Data via the Willow Path Services. Willow Path disclaims all liability that arises in connection with User Data. You hereby waive any legal or equitable right or remedy you may have against Willow Path with respect to User Data.

You understand that Willow Path may, at any time and without prior notice, screen, remove, edit or block any User Data that in Willow Path's sole judgment violates these Willow Path Terms or is otherwise objectionable. You acknowledge and agree that Willow Path reserves the right to, and may from time to time, monitor data transmitted or received through the Willow Path Services for operational and other lawful purposes. If at any time Willow Path chooses to monitor the Willow Path Services, Willow Path assumes no additional responsibility or liability to you or any third party.

6. Intellectual Property Rights

6.1 Ownership of User Data

You are and will remain the sole and exclusive owner of all right, title and interest in and to your User Data, including all intellectual property rights relating thereto. You hereby irrevocably grant to Willow Path all rights and permissions in or relating to User Data that Willow Path determines necessary or useful to perform the Willow Path Services, enforce these Willow Path Terms or otherwise exercise Willow Path's rights and perform Willow Path's obligations. By providing your User Data to or through the Willow Path Services to other users of the Willow Path Services, you grant those users a non-exclusive license to access and use your User Data as permitted by these Willow Path Terms and the functionality of the Willow Path Services.

You expressly acknowledge that User Data excludes Services Data. In furtherance of the foregoing, you hereby unconditionally and irrevocably grant to Willow Path all right, title and interest you may have in and to Services Data.

6.2 Ownership of Willow Path Services

The Willow Path Services are owned and operated by Willow Path. The visual interfaces, graphics, design, compilation, information, data, computer code (including source code or object code), products, software, services, and all other elements of the Willow Path Services provided by Willow Path (Willow Path Content) are protected by intellectual property and other laws. All Willow Path Content included in the Willow Path Services are the property of Willow Path or its third-party licensors. Except as expressly authorized by these Willow Path Terms or otherwise by Willow Path, you may not use the Willow Path Content. Willow Path reserves all rights to the Willow Path Content not granted expressly in these Willow Path Terms.

6.3 Ownership of Partner Content

With respect to content provided by Willow Path Partners (Partner Content), the Willow Path Partner and/or its licensors own all right, title and interest, including all intellectual property rights, in and to Partner Content. You have no right, license or authorization with respect to Partner Content except as expressly set forth in the applicable third-party license. All other rights in and to the Partner Content are expressly reserved by the applicable third-party licensor.

6.4 Feedback

If you choose to provide input and suggestions regarding problems with or proposed modifications or improvements to the Willow Path Services (Feedback), then you grant Willow Path and its transferees a fully paid, royalty-free, perpetual, irrevocable, worldwide, non-exclusive and fully sub-licensable right and license to use, reproduce, perform, display, distribute, adapt, modify, re-format, create derivative works of and otherwise exploit in any manner all Feedback. You also acknowledge and agree that Willow Path may publish your Feedback on its website and attribute that Feedback to you.

7. Changes to Willow Path Services and These Willow Path Terms

7.1 Updates

We are always looking to innovate and make the Willow Path Services better. As a result, Willow Path may from time to time update the Willow Path Services, including enhancements, modifications, upgrades and other changes to the existing features and operability of the Willow Path Services (collectively, Updates). These Updates may occur for various reasons, such as adding or removing functionality, fixing bugs, and addressing issues relating to security or performance. Whenever possible, Willow Path will provide you with reasonable, advance notice (which may include notice by way of posting in the Willow Path Services) of material Updates to enable you to prepare for the Updates. You acknowledge and agree that Updates made to comply with applicable law may not allow Willow Path to provide advance notice of Updates.

You acknowledge, understand and agree that the Willow Path Services and Updates may (i) cause your mobile telephone, computer and/or network equipment to automatically communicate with Willow Path's (or one of its third-party service provider's) servers to deliver the functionality described in these Willow Path Terms and to record User Data and Services Data, (ii) affect preferences or data stored in your device, and (iii) collect personal information and other information, as described in the Willow Path Privacy Policy.

7.2 Other Modifications to Willow Path Services

Willow Path reserves the right to modify, limit or discontinue the Willow Path Services at any time (including by limiting or discontinuing certain features of the Willow Path Services), temporarily or permanently, without notice to you.

Willow Path may elect to deprecate certain functionality or features within the Willow Path Services upon notice posted through the Willow Path Services. Whenever possible, Willow Path will provide at least ninety (90) days' advance notice of deprecation of any material function (and any related support) within the Willow Path Services. You acknowledge and agree that deprecations made to comply with applicable law may not allow Willow Path to provide advance notice.

To the fullest extent permitted by law, Willow Path will have no liability to you or any third party for any change to the Willow Path Services or any suspension or termination of your access to or use of the Willow Path Services made in accordance with these Willow Path Terms.

7.3 Changes to Terms

You acknowledge and agree that Willow Path has the right to modify these Willow Path Terms from time to time to reflect changes to the Willow Path Services, industry requirements or applicable law. Willow Path will notify you at least thirty (30) business days in advance of the material modifications to these Willow Path Terms. Willow Path will send notifications of material modifications by email using the email address(es) associated with your Account Credentials and/or through a notice posted in the Willow Path Services. You agree that Willow Path may notify you by posting a notice in the Willow Path Services for non-material changes to the Willow Path Services. You acknowledge and agree that changes to applicable law may prevent Willow Path from providing advance notification. Continued use of the Willow Path Services after the end of the notice period specified in the notification is deemed conclusive acceptance of these Willow Path Terms as modified.

8. Availability of Willow Path Services

You acknowledge that the Willow Path Services are not error-free or 100% reliable or available. Proper functioning of the Willow Path Services relies and is dependent on, among other things, broadband internet access used to transmit data through the Wi-Fi network and the wireless device used. The Willow Path Services may be interrupted, delayed, refused or otherwise limited for a variety of reasons, such as insufficient coverage, power outages, termination of service, environmental conditions, interference, non-payment of applicable fees, system capacity, repairs, relocations and priority access by emergency responders in the event of a disaster or emergency (Service Interruptions). You understand that Service Interruptions may make the Willow Path Services unreliable or unavailable for the duration of the Service Interruption. Although Willow Path uses commercially reasonable efforts to notify you of Service Interruptions, Willow Path cannot and does not guarantee that you will receive these notifications. YOU AGREE THAT YOU WILL NOT RELY ON THE WILLOW PATH SERVICES FOR ANY LIFE SAFETY OR CRITICAL PURPOSES. You agree that you will not be entitled to any refund or rebate for service interruptions or suspensions. Willow Path does not offer any specific uptime guarantee for the Willow Path Services.

The Willow Path Services are available only in the U.S. Territory. Willow Path makes no representation that the Willow Path Services, or any feature or part thereof, are appropriate or available for use in any other location. To the extent you choose to access and use the Willow Path Services outside the Territory, you do so at your own initiative and are responsible for compliance with applicable laws.

9. Disclaimers; No Warranties

9.1 Waiver and Disclaimers

THE WILLOW PATH SERVICES AND OTHER CONTENT AVAILABLE THROUGH THE WILLOW PATH SERVICES ARE PROVIDED "AS IS" AND ON AN "AS AVAILABLE" BASIS.

THE WILLOW PATH ENTITIES DISCLAIM ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, RELATING TO THE WILLOW PATH SERVICES AND ALL MATERIALS AND CONTENT AVAILABLE THROUGH THE WILLOW PATH SERVICES, INCLUDING: (A) ANY IMPLIED WARRANTY OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, QUIET ENJOYMENT OR NON-INFRINGEMENT; AND (B) ANY WARRANTY ARISING OUT OF COURSE OF DEALING, USAGE OR TRADE. WILLOW PATH DOES NOT WARRANT THAT THE WILLOW PATH SERVICES OR CONTENT OFFERED THROUGH THE WILLOW PATH SERVICES WILL BE UNINTERRUPTED, SECURE OR FREE OF ERRORS, VIRUSES OR OTHER HARMFUL COMPONENTS OR THAT WILLOW PATH WILL CORRECT ERRORS.

WILLOW PATH MAKES NO WARRANTY, REPRESENTATION OR CONDITION THAT THE WILLOW PATH SERVICES WILL MEET YOUR REQUIREMENTS OR WILL BE ACCURATE OR RELIABLE OR THAT WILLOW PATH WILL CONTINUE TO OFFER THE WILLOW PATH SERVICES IN WHOLE OR IN PART.

NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED BY YOU FROM THE WILLOW PATH ENTITIES OR ANY MATERIALS OR CONTENT AVAILABLE THROUGH THE WILLOW PATH SERVICES, WILL CREATE ANY WARRANTY THAT IS NOT EXPRESSLY STATED IN THESE WILLOW PATH TERMS. WILLOW PATH IS NOT RESPONSIBLE FOR ANY DAMAGE THAT MAY RESULT FROM THE WILLOW PATH SERVICES AND YOUR DEALING WITH ANY OTHER USER OR WILLOW PATH PARTNERS. YOU UNDERSTAND AND AGREE THAT YOU USE THE WILLOW PATH SERVICES AT YOUR OWN DISCRETION AND RISK, AND THAT WE ARE NOT RESPONSIBLE FOR ANY DAMAGE TO YOUR PROPERTY (INCLUDING YOUR COMPUTER SYSTEM OR MOBILE DEVICE USED IN CONNECTION WITH THE WILLOW PATH SERVICES) OR ANY LOSS OF DATA.

Willow Path is not responsible for loss or damages arising from unauthorized use of Account Credentials unless such loss or damage arises directly from Willow Path's gross negligence or willful misconduct.

THE LIMITATIONS, EXCLUSIONS AND DISCLAIMERS IN THIS SECTION APPLY TO THE MAXIMUM EXTENT PERMITTED BY LAW. Willow Path does not disclaim any warranty or other right that Willow Path is prohibited from disclaiming under applicable law. TO THE EXTENT ANY OF THE LIMITATIONS, EXCLUSIONS AND DISCLAIMERS CONFLICTS WITH APPLICABLE LAW, THE SCOPE AND DURATION OF THE WARRANTIES APPLICABLE TO THE WILLOW PATH SERVICES WILL BE THE MINIMUM PERMITTED UNDER THAT LAW.

10. Limitation of Liability

THE LIMITATIONS AND EXCLUSIONS IN THIS SECTION APPLY TO THE MAXIMUM EXTENT PERMITTED BY LAW. WILLOW PATH DOES NOT LIMIT OR EXCLUDE ANY LIABILITY THAT IS PROHIBITED FROM BEING LIMITED OR EXCLUDED UNDER APPLICABLE LAW. TO THE EXTENT ANY LIMITATION OR EXCLUSION CONFLICTS WITH APPLICABLE LAW, WILLOW PATH'S LIABILITY WILL BE THE MINIMUM PERMITTED UNDER THAT LAW.

IN NO EVENT WILL THE WILLOW PATH ENTITIES BE LIABLE TO YOU OR THIRD PARTY ACCESSING OR USING THE WILLOW PATH SERVICES PURSUANT TO YOUR ACCOUNT FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR PUNITIVE DAMAGES (INCLUDING DAMAGES FOR LOSS OF PROFITS, GOODWILL, OR ANY OTHER INTANGIBLE LOSS) ARISING OUT OF OR RELATING TO ACCESS TO OR USE OF, OR INABILITY TO ACCESS OR USE, THE WILLOW PATH SERVICES OR ANY CONTENT ON THE WILLOW PATH SERVICES, WHETHER BASED ON WARRANTY, CONTRACT, TORT (INCLUDING NEGLIGENCE), STATUTE, OR ANY OTHER LEGAL THEORY, AND WHETHER OR NOT ANY WILLOW PATH ENTITY HAS BEEN INFORMED OF THE POSSIBILITY OF DAMAGE. WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, Willow Path is not responsible for loss or damages arising from unauthorized use of Account Credentials unless such loss or damage arises directly from Willow Path's gross negligence or willful misconduct.

TO THE FULLEST EXTENT PERMITTED BY LAW, THE AGGREGATE LIABILITY OF THE WILLOW PATH ENTITIES TO YOU OR ANY THIRD PARTY FOR ACCESSING OR USING THE WILLOW PATH SERVICES PURSUANT TO YOUR ACCOUNT WITH WILLOW PATH, FOR CLAIMS ARISING OUT OF OR RELATED TO THE USE OF OR ANY INABILITY TO USE THE WILLOW PATH SERVICES OR OTHERWISE UNDER THESE WILLOW PATH TERMS, WHETHER IN CONTRACT, TORT OR OTHERWISE, IS LIMITED TO THE GREATER OF: (A) THE AMOUNT YOU PAID TO WILLOW PATH FOR ACCESS TO AND USE OF THE WILLOW PATH SERVICES IN THE 12 MONTHS PRIOR TO THE EVENT OR CIRCUMSTANCE GIVING RISE TO THE CLAIM (BUT NOT INCLUDING THE PURCHASE PRICE FOR ANY WILLOW PATH PRODUCTS) AND (B) $1,000.

EACH PROVISION OF THESE WILLOW PATH TERMS THAT PROVIDES FOR A LIMITATION OF LIABILITY, DISCLAIMER OF WARRANTIES, OR EXCLUSION OF DAMAGES IS INTENDED TO AND DOES ALLOCATE THE RISKS BETWEEN WILLOW PATH AND CUSTOMER AND USERS UNDER THESE WILLOW PATH TERMS. THIS ALLOCATION IS AN ESSENTIAL ELEMENT OF THE BASIS OF THE BARGAIN BETWEEN WILLOW PATH AND YOU. EACH OF THESE PROVISIONS IS SEVERABLE AND INDEPENDENT OF ALL OTHER PROVISIONS OF THESE WILLOW PATH TERMS. THE LIMITATIONS IN THIS SECTION 10 WILL APPLY EVEN IF ANY LIMITED REMEDY FAILS OF ITS ESSENTIAL PURPOSE.

11. Dispute Resolution

11.1 Governing Law

These Willow Path Terms and your use of the Willow Path Services are governed by the laws of the State of Delaware, without regard to its choice of law provisions. You and Willow Path submit to the personal and exclusive jurisdiction of the state courts and federal courts located within Delaware for resolution of any lawsuit or court proceeding permitted under these Willow Path Terms.

[Note: Insert applicable state jurisdiction here if desired.]

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, YOU AGREE THAT ANY CAUSE OF ACTION ARISING OUT OF OR RELATED TO THE SERVICES MUST COMMENCE WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES; OTHERWISE, THE CAUSE OF ACTION IS PERMANENTLY BARRED.

11.2 No Class Actions

YOU AND WILLOW PATH AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.

12. General Terms

12.1 Electronic Communications

The communications between you and Willow Path may use electronic means. Except as prohibited by applicable law, you (a) consent to receive communications from Willow Path in an electronic form; and (b) agree that all terms and conditions, agreements, notices, disclosures, and other communications that Willow Path electronically provides to you satisfy any legal requirement that such communications would satisfy if it were to be in writing.

12.2 US Government Rights

The Willow Path Services are a "commercial item" as defined at 48 C.F.R. 2.101, consisting of "commercial computer software" and "commercial computer software documentation" as such terms are used in 48 C.F.R. 12.212. Accordingly, if Customer is an agency of the US Government or any contractor therefor, Customer only receives those rights with respect to the Willow Path Services as are granted to all other customers and users under license, in accordance with (i) 48 C.F.R. §227.7201 through 48 C.F.R. §227.7204, with respect to the Department of Defense and their contractors, or (ii) 48 C.F.R. §12.212, with respect to all other US Government licensees and their contractors.

12.3 Force Majeure

No failure, delay or default in performance of any obligation of a party shall constitute an event of default or breach of these Willow Path Terms to the extent that such failure to perform, delay or default arises out of a cause, existing or future, that is beyond the control and without negligence of such party, including action or inaction of governmental, civil or military authority; fire; strike, lockout or other labor dispute; flood, terrorist act; war; riot; theft; earthquake and other natural disaster. The party affected by such cause shall take all reasonable actions to minimize the consequences of any such cause.

12.4 Notice to California Residents

If you are a California resident, under California Civil Code Section 1789.3, you may contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs in writing at 1625 N. Market Blvd., Suite S-202, Sacramento, California 95834, or by telephone at (800) 952-5210 in order to resolve a complaint regarding the Willow Path Services or to receive further information regarding use of the Willow Path Services.

12.5 Other General Terms

These Terms, together with the Willow Path Privacy Policy and any other agreements expressly incorporated by reference into these Willow Path Terms, are the entire and exclusive understanding and agreement between you and Willow Path regarding your use of the Willow Path Services. You may not assign or transfer these Willow Path Terms or your rights under these Willow Path Terms, in whole or in part, by operation of law or otherwise, without our prior written consent. Willow Path may assign these Willow Path Terms at any time without notice or consent. The failure to require performance of any provision will not affect our right to require performance at any other time after that, nor will a waiver by us of any breach or default of these Willow Path Terms, or any provision of these Willow Path Terms, be a waiver of any subsequent breach or default or a waiver of the provision itself. If any part of these Willow Path Terms is held to be invalid or unenforceable, the unenforceable part will be given effect to the greatest extent possible, and the remaining parts will remain in full force and effect. You and Willow Path are independent contractors in the performance of every part of these Willow Path Terms. Nothing in these Willow Path Terms is intended to create or shall be construed as creating an employer-employee relationship or a partnership, agency, joint venture, or franchise. You and Willow Path are and will be solely responsible for your/its respective employees and agents and respective labor costs and expenses arising in connection with those employees and agents. Use of section headers in these Willow Path Terms is for convenience only and will not have any impact on the interpretation of any provision.

Privacy Policy

Willow Path Co. Privacy Policy

Willow Path Co. and its subsidiaries and affiliates (collectively, "WILLOW PATH," "we," or "us") offer web and mobile services and related offerings that facilitate caregiving planning by employees and care team members for care recipients ("WILLOW PATH Services"). This Privacy Policy explains the personal information we process, how we use it, and your rights.

This Privacy Policy also serves as our Notice at Collection for purposes of U.S. Privacy Laws.

1. Key Definitions

Business Purposes means performing the WILLOW PATH Services; managing and processing interactions and transactions with Users; securing and debugging; advertising and marketing (including email marketing communications and survey follow-up outreach); quality assurance; research and development; and other purposes as defined by U.S. Privacy Laws.

User (or "you") means the person accessing and using WILLOW PATH Services.

Personal Information means information that identifies or can reasonably be used to identify an individual.

Processing means any operation performed on personal information, such as collecting, storing, combining, or sharing.

Sale or Selling means selling, renting, releasing, disclosing, disseminating, making available, or otherwise communicating a User's personal information for monetary or other valuable consideration.

Share or Sharing means sharing personal information for cross-context behavioral advertising.

WILLOW PATH Partners means businesses that offer products and services through WILLOW PATH Services.

Vendors means service providers that process personal information on behalf of WILLOW PATH.

U.S. Privacy Laws means the California Consumer Privacy Act (as amended by the CPRA), Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, and Virginia Consumer Data Protection Act, as amended or replaced from time to time.

2. When and Where This Privacy Policy Applies

This Privacy Policy covers the twelve (12) months prior to the Last Updated date and is updated at least once per year. If our processing materially changes between updates, we will provide a supplemental notice when or before the changes apply.

This Privacy Policy applies to individuals who reside in the United States.

3. Collection of Personal Information

WILLOW PATH collects personal information:

  • Directly from you (e.g., account registration, surveys, email subscriptions)
  • From your devices (e.g., browser information, IP addresses)
  • From our affiliates and service providers
  • From public sources
  • From other businesses or individuals

We generally process personal information to provide and improve WILLOW PATH Services, operate our business, and for the Business Purposes described above.

Email Collection for Marketing and Survey Follow-Up

Beginning in 2025, we collect email addresses from Users for two primary purposes:

  1. 1. Marketing Communications – With your consent, we use your email to send newsletters, promotional offers, service updates, and other marketing content related to WILLOW PATH Services.
  2. 2. Survey & Interaction Follow-Up – When you complete a survey or interact with our platform, we may collect your email address to follow up with clarifying questions, request feedback, or provide additional information related to your responses or experience.

You may opt out of marketing emails at any time by clicking "unsubscribe" in any email or by contacting us at support@willow-path.com.

Opting out of marketing communications does not affect our ability to contact you for essential follow-up questions related to surveys or direct interactions with WILLOW PATH Services, provided such follow-up is reasonably necessary to complete or support the interaction.

We may use trusted Vendors (e.g., email campaign providers, survey management providers) to help deliver both marketing and follow-up communications, subject to strict confidentiality and data protection obligations.

4. Disclosure of Personal Information

WILLOW PATH discloses personal information:

  • To Vendors providing services on our behalf (e.g., data analytics, cloud storage, survey and email marketing providers)
  • To WILLOW PATH Partners
  • To government entities or law enforcement, when required
  • In connection with corporate transactions (e.g., mergers, acquisitions)
  • With your consent or at your direction

We do not sell your personal information for monetary value. However, we may share personal information as described above for cross-context behavioral advertising.

5. Retention

We retain personal information for as long as reasonably necessary to carry out the purposes described in this Privacy Policy, including legal compliance, dispute resolution, and enforcement of agreements.

Email addresses collected for marketing are retained until you opt out, request deletion, or until we no longer need them for marketing purposes.

Email addresses collected for survey follow-up are retained only as long as necessary to complete the follow-up process or for related business purposes, unless you request deletion sooner.

6. Your Privacy Rights

Subject to verification, you may exercise the following rights:

  • Right to Know/Access – Request information about the categories and specific pieces of personal information collected, disclosed, or shared.
  • Right to Delete – Request deletion of your personal information, subject to legal exceptions.
  • Right to Correct – Request correction of inaccurate personal information.
  • Do Not Sell/Share/Target – Opt out of the sale, sharing, or use of your personal information for targeted advertising, including email addresses used for direct marketing.
  • Right to Limit Sensitive Personal Information Processing – Request limitations on the use of sensitive personal information.

You may exercise your rights by emailing support@willow-path.com.

We will verify your identity before fulfilling certain requests. You may also designate an authorized agent, subject to additional verification requirements.

7. Notice of Financial Incentives

We may offer discounts, promotional offers, or other incentives to Users who subscribe to our marketing communications. Participation is voluntary, and you may withdraw at any time.

We value the personal information collected for such programs based on the benefits provided (e.g., discounts) and the type of information collected (e.g., email address).

8. Non-Discrimination

We will not discriminate against you for exercising your privacy rights. However, we may offer different prices, rates, or levels of service if reasonably related to the value of personal information provided.

9. Shine the Light Law (California)

California residents may request information about our disclosure of personal information to third parties for their direct marketing purposes by emailing support@willow-path.com with the subject line "Shine the Light Request."

10. Contact Us

If you have questions or concerns about this Privacy Policy or our practices, contact us:

Email: support@willow-path.com

Willow Path Co. does not knowingly collect or process personal information from children under 13. If we learn that we have done so, we will delete the information promptly.

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction.

In the event of a data breach, Willow Path Co. will notify affected individuals in accordance with applicable law.

If you are dissatisfied with our response to a privacy rights request, you may appeal by contacting support@willow-path.com.

This Privacy Policy is effective as of October 24, 2025, and replaces prior versions.

Additional Notes

Any disputes arising under these Terms will be resolved through binding arbitration administered by the American Arbitration Association (AAA), except where prohibited by law. Both parties waive the right to a jury trial.

The Willow Path Services are not directed to children under 13. By using the Services, you represent that you are at least 13 years old.

The Willow Path Privacy Policy is incorporated by reference into these Terms of Service.

Willow Path Co. maintains reasonable administrative, physical, and technical safeguards designed to protect the integrity and confidentiality of data processed through the Services.

How to Contact Willow Path

Willow Path understands that these Terms and Privacy Policy contain a lot of information to read and understand. If you have questions about our Terms of Service, Privacy Policy, or any other aspects of our services, please feel free to reach out to us.

Contact us: support@willow-path.com