Privacy Policy
This privacy policy (this “Privacy Policy”) governs the collection, storage, and use of information and data collected by Clear, Inc. or any of our affiliates (collectively, “Clear,” “we”, “us”, or “our”), via our website at www.clearinc.com and its subdomains, by our mobile application, or by telephone, facsimile, email, or other means (collectively, and together with our website, “Clear Services”).
We have prepared this Privacy Policy to explain how we collect, use, protect, and disclose information and data when you use our website or any other Clear Services.
Please read this Privacy Policy carefully. By accessing and using this website or any other Clear Services, you confirm that you have read and understand this Privacy Policy in its entirety. You understand and acknowledge that we reserve the right to change or amend this Privacy Policy at any time, which will be reflected by the “effective” date above. Please check this webpage regularly to stay informed of updates to this Privacy Policy. If any material changes are made to this Privacy Policy, advance notice of the changes will be posted in the first section of this webpage as required by applicable law. You understand that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.
1.What information do we collect from you?
A.Information provided by you directly or by your agent
Clear collects information when you use Clear Services and supplied by you or your designated agent during the application process, including but not limited to, the following information (as applicable):
| Individual and Business names
Mailing address |
| Business address |
| Phone and e-mail details, including passwords |
| Bank account information |
| Date of birth |
| Social security number, drivers’ license, or other government IDs |
| Income, assets, debt, and other personal and business data |
| Other information provided in correspondence with us, including by email, post facsimile, and telephone |
B.Cookies and tracking technologies
When you use Clear Services, we and our third-party service providers may utilize cookies and other similar technologies (such as web beacons or pixel tags) to capture and remember certain information (collectively, “Technologies”). These Technologies help us to improve your website experience, provide you with better tools, and operate our business in other ways described under the heading “Why do we collect this information” below. You have the ability to disable cookies in your browser settings; however, doing so may affect the functionality of certain features of our website.
Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services, to provide tailored advertising, and to evaluate our marketing efforts. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. We do not process “do not track” (DNT) signals.
You may stop or restrict the placement of tracking technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings menu to exercise this choice.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
C.Device specific information and tracking technologies
When you use Clear Services, we and our third-party service providers may collect device specific information. This information, including but not limited to your internet protocol address, geographical location, browser type, operating system, MAC address, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, length of visit, and pages viewed, is saved automatically in log files. We use the information in these files to improve the functionality of our services and in other ways described under the heading “Why do we collect this information” below.
D.Information obtained from third parties
Information from Other Sources. We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email, profile picture, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
Information from financial partners to process your loan. In addition to collecting personal information supplied by you or your designated agent, we use unaffiliated third parties to gather data on borrowers and prospective borrowers, from financial institutions, consumer reporting agencies, and other information service providers for purposes described under the heading “Why do we collect this information” below. This information includes the categories of information described above, and also includes:
- Government IDs
- Criminal records
- Household records
- Employment information, such as visa permit number
By using Clear Services and applying for a loan, you acknowledge that our unaffiliated, third-party providers will have the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution or consumer reporting agency, according to the terms of such third-party provider’s privacy policy.
2.Why do we collect this information?
Clear may use information we collect about you to:
- determine your eligibility for a loan;
- obtain, upon your authorization, a credit report, references, and other information from credit bureaus or other third parties in connection with your loan application;
- verify your identity;
- detect and guard against potential fraud and identity theft;
- manage and monitor your Clear account and update your records;
- develop, maintain and improve our website, products, and services;
- detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity;
- improve customer acquisition through the use of advertising campaigns and other means, such as targeted marketing;
- enforce our agreements;
- carry out statistical analysis and market research and testing;
- comply with our legal and regulatory obligations, and carry out regulatory checks;
- make our website available to you and identify products and services you may be interested in; and/or
- send or facilitate communications with you.
3.How and when is your information shared with other parties?
We do not “sell” your personal information as the term is defined under the California Consumer Privacy Act (CCPA), nor have we ever sold personal information. Your information, as collected by or provided to us, may be shared by us (currently and in the preceding 12 months) with the following categories of third parties:
| Category | Examples | Category of Third Parties Information is Disclosed to |
| Identifiers | A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. |
|
|
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, bank account information, |
|
|
Protected classification characteristics under California or federal law |
Age (40 years or older). |
|
| Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
|
|
Internet or other electronic network activity |
Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement. |
|
|
Professional or employment-related information |
Current or past job history or performance evaluations. |
|
|
Inferences drawn from other personal information to create a profile about a consumer |
Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
|
For more information on this sharing, see below:
- Sharing with Service Providers. In order to provide, operate, and improve Clear Services, we may share your information with service providers who assist us in operating our website, providing market research and marketing our products and services, so long as the service provider contractually agrees to only use the data on our behalf.
- Service providers may also include your representative(s), to the extent such a representative assists or assisted with the investor eligibility process. Information shared with your representative may include, among others, information about your loan performance.
- Sharing with Loan partners. In order to enable Clear to carry out our services and conduct our businesses, including, but not limited to:
- With credit bureaus, consumer reporting agencies, financial institutions, collections agencies, and fraud prevention agencies
- With business credit bureaus to report loan performance.
In addition to the sharing outlined above, we may share any information we maintain about you with the following parties:
- With our company affiliates;
- With any third party who acquires some or all of our business and/or assets in connection with an acquisition or merger, as permitted under applicable law;
- When required by applicable law, including, but not limited to:
- With law enforcement or other government bodies, such as to comply with subpoenas, bankruptcy proceedings, or similar legal processes or for the purposes of limiting fraud.
- When we believe in good faith that sharing such information is necessary to enforce our site policies or any loan agreement, protect our or other’s rights, property, or safety, and/or to comply with a judicial proceeding, court order, or legal process.; and
- With other third parties in de-identified or aggregated form, for marketing, advertising, research, or other business purposes.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
4.Storage and security
While we take appropriate physical, technical and organizational measures to safeguard the personal information that you provide to us, unfortunately no system is 100% secure. To the fullest extent permitted by applicable law, we accept no liability if communications are unintentionally disclosed, intercepted by third parties, incorrectly delivered, or fail to deliver.
The personally identifiable information that you provide and that we collect will be stored and maintained by Clear for so long as we, in our sole discretion, believe is necessary or appropriate (a) to carry out the purpose(s) for which such information was collected, in accordance with this Investor Privacy Policy, or (b) to comply with applicable laws, contracts or other rules or regulations.
5.Your rights
In accordance with applicable law, you may have the right, subject to verification of your identity:
- To update and correct any out-of-date or incorrect personal information that we hold about you free of charge; and
- To opt out of any marketing communications that we or any service provider to whom we have disclosed your personal information may send you.
- To request deletion of your personal information, subject to certain exceptions prescribed by law.
- To request restriction of or object to processing of your personal information, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law.
If you wish to exercise any of the above rights, please contact us using the details specified under the heading “Contacting us” below. Note that we will require you to take steps to verify your identity before you may exercise the rights listed above, such as by requesting you provide us with your account information, or asking you to answer questions regarding your activities on our Services. Once you have verified your identity, you may also designate an authorized agent to exercise your rights on your behalf by providing the agent’s contact information to out customer support staff, as required by applicable law.
You may have a right not to receive discriminatory treatment as a result of your exercise of these rights.
Please note that the Fair Credit Report Act (FCRA) requires each of the nationwide credit reporting agencies — Equifax, Experian, and TransUnion — to provide you with a free copy of your credit report, at your request, once every 12 months. For more information, visit: https://www.ftc.gov
6.Links to other sites
Our websites may offer links to sites of other companies and associations. While we monitor the quality of content provided on these sites, these external sites are not subject to this Privacy Policy and we have no control over their content. Please carefully review the policies of these sites before providing any personal information
7.Contacting us
If you have any questions regarding this Privacy Policy, you may contact us using the information below.
Clear, Inc.
c/o Legal Dept.
125 Park Ave., 25th floor
NY, NY 10017
(800)223-2793
legal@clearinc.com