Privacy Policy

Status: Provisional bounded-launch policy — pending exact attorney sign-off. Last updated: July 31, 2026

This policy is limited to Camino's bounded individual-pay launch. It is not final attorney approval and does not authorize customer-scale, institutional, sponsored, or research activity.

Camino Institute, LLC (a Texas limited liability company) ("Camino Institute," "we," "our") operates the Camino Institute website at camino.to and the Camino application under camino.to/app (collectively, the "Platform"). This Privacy Policy explains what information we collect, how we use it, and your rights regarding your data.

By using the Platform, you agree to the practices described in this policy. If you do not agree, do not use the Platform.

1. Information We Collect

Account information. When you create an account, we collect your email address, the password hash (we do not store your password in plaintext), and any profile information you provide.

Payment information. Payments are processed by Stripe. We do not store your credit card number, banking information, or any other payment instrument. We retain a Stripe Customer ID linking your account to your Stripe records. Stripe's privacy policy governs the processing of your payment data.

Program content.

• Camino Lumen™ — when you participate in the 13-reflection program, we collect your responses to reflection prompts, the content of your AI-guided conversations, your optional journal entries, and any revisions you make to your prior responses.
• Lexica™ — when you participate in the 21-day program, we collect your daily reflection content, your conversation history with the AI, your vocabulary adoption record, your Camino Pacing System trajectory, and your participation pattern over the 21 days.
• These program contents are encrypted at rest (AES-256) and in transit (TLS 1.2+).
• This is the primary data the platform uses to generate your Personal Insight Snapshot™ (Lumen) and your Close Document (Lexica).

Assessment responses. When you complete the Three-Dimensional Coherence Self-Assessment (TDCSA) at the end of Camino Lumen™ and at Day 21 of Lexica™, we collect your item-level responses. We compute and store your Identity, Worldview, and Relationship subscale scores and your TDCI composite. These are stored at the item level — we do not aggregate and discard your raw responses.

Memory records. The Camino AI maintains six categories of memory records derived from your reflections. These records are encrypted, scoped to your account, and used only to deliver continuity across your reflections and to generate your program outputs.

Coaching session records. If you purchase coaching sessions with a Camino Coach, we record your purchases, scheduling, completion, and any notes the coach records about the session. All Camino Coaches are licensed providers; coaching itself is not a separate regulated credential. Coaching session notes are visible only to authorized Camino clinical personnel — they do not appear on any participant-facing surface and are encrypted at rest.

Layer 1 program-safety events. If Camino's automated safety-boundary checks flag content that may need support outside Camino (a "Layer 1 flag" - see Section 8), the platform creates a record of the event, pauses your session, sends an internal email notification for asynchronous program review, and provides you with crisis resources in the app. The flag record contains a category indicator (e.g., suicidal_ideation, self_harm, psychiatric_crisis), a timestamp, and a link to your participant context - but it does not include the specific phrase that triggered it.

If you are in imminent danger, call emergency services, call 911 in the United States, or go to the nearest emergency room. In the United States, you can always call or text 988 (Suicide and Crisis Lifeline) regardless of whether the platform has flagged your session.

Usage data. We use PostHog for anonymous, route-level page-view measurement across the public site and authenticated application. The measurement can include a sanitized route template (for example, /app/reflections/:reflection), device and browser type, and standard request metadata such as IP address. It does not include your account ID, email address, dynamic route identifiers, query strings, referrers, reflection content, AI prompts or responses, assessment responses or scores, vocabulary records, coaching notes, clinical flags, or form values. Autocapture, session replay, heatmaps, surveys, error capture, performance capture, person profiles, and persistent analytics cookies or browser storage are disabled. Unknown authenticated routes are reported only as /app/other.

Communications. If you contact us by email or through the contact form, we retain that correspondence in the Camino-controlled support@camino.to support mailbox. Privacy and data requests route through that same support intake. Any reserved alternate address is an internal alias into the same support mailbox and is not separately publicized for this release.

2. How We Use Your Information

We use the information we collect to:

• Deliver Camino Lumen™ and Lexica™ programs.
• Generate your Personal Insight Snapshot™ (after Camino Lumen™) and your Close Document (after Lexica™).
• Manage your account, your enrollments, and any coaching session purchases.
• Send transactional email related to your account: verification, reflection-availability notices, Snapshot or Close Document delivery, payment receipts, re-entry messages if you lapse from Lexica™ for 2+ days, coaching session confirmations and reminders.
• Apply our Camino Pacing System to calibrate AI engagement intensity per your trajectory.
• Track your vocabulary adoption rate during Lexica™ as a measure of program engagement.
• Improve the Platform and the quality of AI-generated content.
• Keep research features dormant while the activation gate described in Section 7 remains on HOLD.
• Respond to your inquiries.
• Comply with legal obligations.

We do not sell your personal information. We do not use your personal information for advertising. We do not run ads on the Platform.

3. AI-Generated Content

The Camino platform uses artificial intelligence to engage with your reflection responses, to generate your Personal Insight Snapshot™ and Close Document, to calibrate your Camino Pacing System level, to track your vocabulary adoption, and to identify content that may require outward crisis or emergency resources.

Your reflection content is processed by a single AI system designed by Walter Calvo, LCSW, DBA, with program-specific configuration. This system operates under a strict Socratic constraint — the AI asks questions to surface your insight; it does not prescribe, diagnose, advise, or instruct.

AI-generated content is not a clinical assessment, diagnosis, or treatment. It is a structured reflection tool. If you are experiencing a mental health crisis or symptoms requiring clinical attention, please contact a licensed mental health professional or a crisis service. In the United States, you can call or text 988 to reach the Suicide and Crisis Lifeline.

We use OpenAI as the primary AI infrastructure. OpenAI processes our conversation requests to generate AI responses; the data handling practices of OpenAI apply to that processing. We do not transmit your real name, your participant ID linked to identifying information, or your Stripe data to the AI provider — only the conversation content needed to generate the next AI response.

4. Data Retention

Camino applies a data-class-specific retention schedule. The Platform does not automatically delete participant records after 90 days or any other inactivity threshold.

• While your account is active — account, program, reflective, assessment, memory, coaching, billing, and safety-boundary records are retained to operate the Platform.
• After program completion or inactivity — program-participation records are retained for billing, legal compliance, program continuity, and re-enrollment tracking. Reflective content follows the current three-year review schedule measured from the last program completion, but deletion requires manual review and written confirmation before execution.
• Deletion requests — you may request deletion through your authenticated account or by contacting support@camino.to. Requests are authenticated, classified, manually reviewed, and logged before any deletion or anonymization occurs. Camino provides a plain-language summary of what is proposed for deletion, retention, or anonymization and obtains the required operator and, where applicable, Walter/counsel/privacy approval for the exact disposition.
• Preserved records — billing, payment, safety-boundary, coaching/professional, audit, dispute, legal-hold, and security records may be retained or anonymized when required by law, recordkeeping duties, dispute preservation, or documented operational need. Reflective content is not included in payment or dispute evidence.
• Layer 1 program-safety records — category, timestamp, disposition, and audit evidence may be retained for at least seven years after account or program termination, or longer where a legal or professional-recordkeeping duty applies. Camino does not retain the triggering phrase in the Layer 1 notification record.
• Research records — research activation remains on HOLD. Camino does not collect, query, analyze, export, or publish a research corpus under this bounded launch.

Encrypted database backups are stored in a private Cloudflare R2 bucket for disaster recovery. The operational schedule retains 7 daily, 4 weekly, and 6 monthly backups. Approved deletions age out of ordinary backups through that rotation unless an applicable legal hold or verified recovery need requires a separately controlled record.

5. Third-Party Service Providers

We work with third-party service providers to operate the Platform. These providers process data on our behalf and are bound by data processing agreements where applicable:

• Stripe — payment processing (Lumen $97, Lexica $197, coaching session $197/session, package deal $294).
• Resend — transactional email delivery, including Layer 1 program-safety email notifications to Walter Calvo.
• OpenAI — AI conversation infrastructure.
• PostHog — anonymous route-level page-view measurement across camino.to and /app. Camino disables persistent browser identity, user identification, autocapture, replay, heatmaps, surveys, error and performance capture, and participant-content collection.
• Hostinger — Platform hosting (web application VPS and managed Postgres database). All Platform infrastructure runs on Hostinger.
• Cloudflare R2 — private encrypted backup storage for the Postgres database.
• GlitchTip — self-hosted error tracking. Run on Camino Institute infrastructure, not a third-party SaaS. Error payloads are scrubbed of participant content before being recorded.

We do not share your personal data with third parties for their own marketing purposes.

6. Security

We implement reasonable technical and organizational measures to protect your data:

• Encryption at rest. Reflective content, assessment responses, vocabulary records, memory records, coaching session notes, Personal Insight Snapshot content, Close Document content, and re-entry messages are encrypted at rest using AES-256-GCM with application-layer envelope encryption.
• Encryption in transit. All connections use TLS 1.2 or higher.
• Authentication. Passwords are hashed with bcrypt; we never store passwords in plaintext. Session tokens are httpOnly, secure, and SameSite-strict.
• Access controls. Reflection content and assessment responses are accessible only to your authenticated account. Walter Calvo's clinical console is gated by a clinician role and is not accessible to participants.
• Logging hygiene. We do not log reflection content, assessment responses, vocabulary records, or AI prompt content. Application logs and error reports are scrubbed of participant content before being recorded.
• Backups. Daily encrypted backups to a private Cloudflare R2 bucket with quarterly restore drills.
• Webhooks. All payment webhook signatures are verified before processing.

No system is perfectly secure. If you have reason to believe your account has been compromised, contact us immediately at support@camino.to.

7. Research Activity Is Inactive

Research activation remains on HOLD. The bounded launch does not offer a research enrollment option, accept research authorization, create a research corpus, run research queries or analyses, export research data, publish research findings, activate the Camino Transformation Index, or expand reassessment for research purposes.

Program access is not conditioned on research participation. A separate accepted activation record, approved protocol, approved participant authorization, and required Walter/counsel/privacy review must exist before any research activity can begin.

8. Program Safety Boundaries and Crisis Resources

Walter Calvo, LCSW, DBA, is the Co-Founder and Clinical Director of Camino Institute. He provides program oversight to the Platform - meaning he reviews AI behavioral specifications, sets safety-boundary standards for the product, and sets the standards for Camino Coaches, all of whom are licensed providers, who deliver add-on sessions.

This oversight is not clinical treatment, crisis care, emergency response, or real-time monitoring. Walter is not your clinician. The platform is not a clinical service. Camino does not promise that Walter or any Camino representative will monitor your reflections in real time, intervene in an emergency, contact you in time, or keep you safe.

If Camino's automated safety-boundary checks flag content that may need support outside Camino - including indicators of suicidal ideation, self-harm, active trauma activation, safety disclosure (such as domestic violence or threats), psychiatric crisis (such as reality-testing failure), or persistent distress over multiple sessions - the system will:

1. Pause your reflection session.
2. Create an internal Layer 1 program-safety review record.
3. Provide you with crisis and emergency resources in the application.

The Layer 1 record is reviewed asynchronously for program oversight and documentation. That review is not emergency response or clinical care. If you are in immediate danger or may harm yourself or someone else, call 911 or local emergency services, or go to the nearest emergency room. In the United States, you can call or text 988 (Suicide and Crisis Lifeline) regardless of whether the platform has flagged your session.

9. Your Rights

You have the right to:

• Access the personal data we hold about you.
• Correct inaccurate data.
• Request deletion of your data (subject to the safety-boundary and professional-record retention requirements described in Section 4).
• Receive a plain-language summary of how an authenticated deletion request will affect each data class before execution.
• Opt out of marketing communications at any time via the unsubscribe link in any email.

To exercise any of these rights, use the authenticated account request flow or contact us at support@camino.to. Camino acknowledges and processes authenticated requests through the manual review described in Section 4; the exact disposition depends on the data class and applicable legal or recordkeeping constraints.

10. Children

The Platform is not directed at children under the age of 18. We do not knowingly collect data from anyone under 18. If you believe a minor has created an account, contact us at support@camino.to so Camino can authenticate and review the request under Section 4.

11. International Users

The Platform operates from the United States. If you access the Platform from outside the United States, you understand and consent to the transfer and processing of your data in the United States, subject to U.S. law. We do not currently maintain a separate GDPR or other regional compliance program; if regulatory scope changes, we will update this policy.

12. Changes to This Policy

We may update this policy from time to time. When we do, we will update the status and last-updated date above and notify active users by email if the changes are material. Continued use of the Platform after notification constitutes acceptance of the updated policy.

13. Contact

Camino Institute, LLC San Antonio, Texas

support@camino.to

© 2026 Camino Institute™. All rights reserved. The CAMINO Method™, Three-Dimensional Coherence™, Complete Coherence™, Grounded Generosity™, Camino Lumen™, Lexica™, Coherence Profile™, and Beyond Coaching™ are trademarks of Camino Institute, LLC.