- The types of personal information we obtain
- How we may use personal information
- With whom we may share that information
- The choices available to you regarding our use of information
- The measures we take to safeguard your personal information, and
- How you can contact us about our privacy practices
Effective Date: January 11, 2022
1. INFORMATION WE OBTAIN
We may obtain personal information about you from various sources, including the CLEAR membership application. The types of personal information we may obtain include:
- Contact details (such as name, email and postal address and telephone number);
- Business contact information (such as employer’s name and address, job title and business email address and telephone number);
- Physical characteristics (such as gender and height);
- Government-issued identification information (such as Social Security number, passport number, Alien Registration number and driver’s license number, as well as copies of government-issued identification documents);
- Digital photographs (such as images from your mobile device camera);
- Biometric data (such as digital images of fingerprints, irises and face);
- Information about your use of the CLEAR service;
- Payment information (such as billing address and payment card details, including card number, expiration date and security code);
- Financial information (such as financial account information and details that a consumer report may contain);
- Demographic details (such as date and place of birth, citizenship, travel habits and preferences, income level, education level, family status and employment status);
- Location information (such as GPS data from your mobile device to enable a location-based service);
- Information about your health (such as for use with Health Pass, as described further in Section 15);
- Contact information for friends or others you would like us to contact;
- Information you submit in connection with a career opportunity at CLEAR (such as contact details, information in your resume and details about your current employment);
- Survey information; and
- Other information you may provide to us or authorize others to provide to us (such as shopping and language preferences).
We also may collect personal information typed into forms on our website, whether or not you submit the form.
Additionally, when users visit our website, we collect certain information by using tracking tools, such as cookies and web beacons. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. This allows us to collect information such as your device’s IP address, device type, browser type, operating system, referring URLs, actions taken on our site, and dates and times of website visits. Through these automated collection methods, we obtain “clickstream” data, which is a log of the content that a visitor clicks on while browsing a website. As the visitor clicks through the website, we may record and store those actions. Clickstream data also tells us the type of computer and browsing software you use, the address of the website from which you linked to our site, and the pages you visit on our site.
2. HOW WE MAY USE THE INFORMATION WE OBTAIN
A. BIOMETRIC DATA AND OTHER PERSONAL INFORMATION, INCLUDING HEALTH INFORMATION
We may use biometric data, health information and other personal information we obtain about you to:
- Facilitate and manage CLEAR’s application and enrollment processes
- Operate and administer the CLEAR programs, including CLEAR Health Pass (as described further in Section 15)
- Verify applicants’ and members’ identities, including authenticating users of the CLEAR services
With your express consent, we also may use information in other ways, such as when you choose to use a service or participate in a program we may offer jointly with another entity.
B. NON-BIOMETRIC AND NON-HEALTH PERSONAL INFORMATION
In addition to the uses described in 2.A. above, we also may use non-biometric and non-health personal information to:
- Provide services to our consumers (such as travel or airport-related amenities)
- Authenticate users of the CLEAR service, and conduct background checks and security threat assessments concerning CLEAR applicants and members
- Communicate with you and respond to your questions
- Create and manage online accounts that you establish on our website
- Send news and updates about CLEAR and other communications (such as communications about products and services offered by our marketing partners)
- Offer our consumers products or services we believe may be of interest to them
- Communicate with our consumers about, and administer participation in, special events, programs, surveys, and other offers and promotions
- Operate, evaluate and improve our business (including developing new products and services; analyzing our products and services; managing our communications; and performing accounting, auditing and other internal functions)
- Perform data analyses (including market and consumer research)
We do not collect personally identifiable information about a consumer’s online activities over time or across third-party Web sites or online services. Therefore, “do not track” signals from web browsers do not apply to our website. We do not alter any of our data collection or use practices upon receipt of “do not track” signal.
We also may use the information we obtain about you in other ways, when we provide specific notice at the time of collection.
C. HEALTH INFORMATION
In addition to the uses described in 2.A. above, we may use health information with our health-related services. This is described in greater detail in Section 15 below.
D. INTEREST-BASED ADVERTISING
You can choose whether or not to have this information collected through the use of browser settings and other third-party tools. To learn more about how to opt out, visit our Cookie Usage.
3. INFORMATION WE SHARE
We never sell or rent personal information about you.
A. BIOMETRIC DATA AND OTHER PERSONAL INFORMATION, INCLUDING HEALTH INFORMATION
We may share biometric data, health data, and other personal information we obtain about applicants to and members of the CLEAR program with:
- Service providers (such as order fulfillment and data analytics)
- Other government agencies, if required by law
- Other third parties with your express consent (such as when you choose to use a service or participate in a program that we may offer jointly with another entity)
B. NON-BIOMETRIC AND NON-HEALTH PERSONAL INFORMATION
C. HEALTH INFORMATION
D. SERVICE PROVIDERS
We contractually prohibit our service providers from using or disclosing our consumers’ personal information, other than to perform services for us or comply with legal requirements. We require these service providers to appropriately safeguard the privacy and security of the consumer personal information they collect, use, disclose or otherwise process for us.
E. DISCLOSURES FOR OTHER PURPOSES
We may disclose information we obtain about you:
- If law or legal process requires us to do so (such as a court order or subpoena)
- In response to requests by government agencies (such as law enforcement authorities)
- To establish, exercise or defend our legal rights
- When we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss
- In connection with an investigation of suspected or actual illegal activity
- Otherwise with your consent or at your direction.
We also may share the information we obtain about you in other ways when we provide specific notice at the time of collection.
F. NOTICE FOR CANADA ENROLLEES
CLEAR, its corporate affiliates, and third-party service providers may maintain and process your personal information in the United States. Personal information transferred to the U.S. will be subject to U.S. laws. It may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws.
We or our service providers may also disclose information we obtain about you if we are required or permitted to do so by law or pursuant to legal process (such as court order or subpoena). This may include lawful access by Canadian or U.S. courts, law enforcement or other government authorities in those jurisdictions. If you have any questions about how we or our service providers treat your personal information, please contact us at the contact information in Section 11 below.
4. YOUR CHOICES
You can direct us at any time not to send you marketing emails by:
- Clicking on an unsubscribe link in marketing emails you receive from us
- Replying to marketing emails you receive from us with the word “unsubscribe” in the subject line
Emailing us at email@example.com with the word “unsubscribe” in the subject line and your name in the body of the email.
5. ACCESS AND CORRECTION
Click here to request a copy of personal information we maintain about you. To help protect your privacy and security, we will take steps to verify your identity before granting access. If we deny an access request, we will notify you of the reasons for the denial and offer an opportunity to challenge our decision.
6. OTHER ONLINE SERVICES AND THIRD-PARTY FEATURES
Our website may provide links to other online services for your convenience and information. This may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the these third parties, including details on the information they may collect, is subject to the privacy statements of these parties. We strongly suggest you review them. To the extent any linked online services or third-party features are not owned or controlled by us, CLEAR is not responsible for their information practices.
7. HOW WE PROTECT PERSONAL INFORMATION
We maintain administrative, technical and physical safeguards. These are designed to protect personal information against accidental, unlawful or unauthorized: destruction, alteration, access, disclosure or use.
To safeguard certain sensitive information (such as biometric data and government-issued identification information), we implement security measures such as encryption, firewalls, and intrusion detection and prevention systems. Our customer service call centers do not have access to biometric data.
In addition, some examples of security measures we use to safeguard personal information include:
- Procedures for identifying and classifying personal information
- Implementing safeguards appropriate to the sensitivity of the information
- Access control procedures to verify business need before access to personal information is granted
- Procedures for the periodic review of access permissions
- Procedures for terminating access to personal information when there is no longer a business need for access
- Personnel security controls designed to reduce the risk of human error, theft, fraud or misuse of facilities
- Physical and environmental security procedures designed to prevent unauthorized access, damage or interference to business premises and information.
In the event of a breach of CLEAR’s systems resulting in unauthorized access to your personal information, CLEAR will provide notice as required by law.
8. RETENTION OF PERSONAL INFORMATION
If you are terminating your CLEAR membership, you may request that we remove any personal information we maintain about you. If you apply for CLEAR membership, but do not complete your application, you may request that we remove any personal information we maintain about you.
We will honor your requests, except that we may retain limited information to comply with your request not to be contacted in the future.
9. CHILDREN’S PERSONAL INFORMATION
We recognize the importance of protecting children's online privacy. The CLEAR website is intended for a general audience and is not directed to children. We do not knowingly collect personal information online from children under the age of 13.
11. HOW TO CONTACT US
If you would like to terminate your membership and request deletion of all your information, please contact us per the above or click here.
You also may write to us at:
Attention: Chief Privacy Officer
65 East 55th Street, 17th Floor
New York, New York 10022
12. FORMER CLEAR MEMBERS
13. BIOMETRIC DATA RETENTION FOR ILLINOIS ENROLLEES
For Illinois enrollees, in accordance with Illinois state law, CLEAR will retain biometric data only until the occurrence of the first of the following:
(a) The initial purpose for collecting or obtaining such biometric data has been satisfied
(b) Three years following your last interaction with CLEAR
14. NOTICE TO CALIFORNIA USERS
The information provided in this section applies only to California residents.
The California Consumer Privacy Act of 2018 (“CCPA”) requires us to:
- Explain the rights and choices we offer California residents regarding our handling of their personal information
- Provide information regarding the categories of personal information we collect, use and share
A. CALIFORNIA RESIDENTS’ PRIVACY RIGHTS
The CCPA grants California residents the following rights:
· Information. You can request information about how we have collected, shared and used your personal information during the past 12 months.
· Access. You can request a copy of the personal information we maintain about you.
· Deletion. You can ask us to delete the personal information we maintain about you.
Please note, the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you. You are entitled to exercise the rights described above free from discrimination.
B. HOW TO SUBMIT A REQUEST
To request access to or deletion of personal information from our databases:
- You may begin the process by clicking here
- Call 1-855-253-2763
- Send an email to us at: firstname.lastname@example.org
· Identity verification. CCPA requires us to verify your identity before providing a substantive response to your request for your personal information. We take the privacy and security of your personal information seriously. Therefore, we will verify your identity by asking you to provide certain information about yourself. Once your identity is verified, we will provide your requested information in a timely manner.
· Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. To protect your privacy we will require the authorized agent to have a written authorization confirming that authority.
C. PERSONAL INFORMATION WE COLLECT, USE AND SHARE
CLEAR will never sell or rent your personal information.
In addition, by using the CLEAR Health Pass service, you may direct us to disclose certain information about your health to access or facilitate access to locations or services that use CLEAR Health Pass.
We describe the sources through which we collect Personal Information in Section 1 (Information We Obtain). We describe the purposes for which we use and share this information above in Section 2 (How We Use the Information We Obtain), and Section 3 (Information We Share).
15. CLEAR HEALTH PASS AND DIGITAL VACCINE CARD
CLEAR Health Pass enables members to use and share their health data (or information derived from this data) to show eligibility for access, or to facilitate access, to locations that use CLEAR Health Pass. CLEAR Health Pass may collect, use or share personal health information, such as responses to a health symptom and exposure questionnaire, the results of a body temperature check, diagnostic test results, and/or vaccine records. We may receive such health information from you directly or from third parties (such as health care providers or labs) permitted to share this information with us. We may also collect information about your location to provide location-based services related to Health Pass, such as to help you locate nearby COVID-19 testing centers.
If you use CLEAR Health Pass, we may use your health information (or information derived from this data) to:
- Operate and administer CLEAR Health Pass
- Evaluate and improve our services
- For the purposes set forth above in Section 2.A
- Share your health information (or information based on this information) with private and public entities that use the CLEAR Health Pass program or as otherwise required by law.
We may also share de-identified information with public interest organizations, health care organizations and researchers. We will prohibit these organizations from attempting to re-identify the information we share with them.
CLEAR Digital Vaccine Card provides CLEAR members with the ability to generate a standalone digital card to demonstrate their COVID-19 vaccination status. If you generate a Digital Vaccine Card, CLEAR may store, use and share your vaccine information to validate your vaccination status, as well as for the purposes set forth above in Section 2.A.
16. NOTICE TO EUROPEAN RESIDENTS
We provide the notice in this Section to users of CLEAR who reside in Europe.
A. CONTROLLER, REPRESENTATIVE, AND DATA PROTECTION OFFICER
We have appointed VeraSafe as our representative in Europe for data protection matters, pursuant to Article 27 of the General Data Protection Regulations of the European Union and United Kingdom. To contact VeraSafe, please visit https://www.verasafe.com/public-resources/contact-data-protection-representative.
Alternatively, if you are an EU resident, you may write to VeraSafe at:
Unit 3D North Point House
North Point Business Park
New Mallow Road
And if you are a UK resident, you may write to VeraSafe at:
37 Albert Embankment
London SE1 7TL
In addition, CLEAR has appointed a Data Protection Officer, whom you can contact at email@example.com
B. LEGAL BASES FOR PROCESSING
C. EUROPEAN RESIDENTS’ DATA PRIVACY RIGHTS
European data protection laws provide European residents with certain privacy rights. If you are located within Europe, you may ask us to take the following actions in relation to your personal information we hold:
- Access. Provide you information about our processing of your personal information and give you access to your personal information.
- Rectification. Update or correct inaccuracies in your personal information.
- Erasure. Delete your personal information.
- Data Portability. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restriction. Restrict the processing of your personal information.
- Objection. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by email to firstname.lastname@example.org, by clicking here, by contacting VeraSafe as set forth above, or by postal mail at the address provided in Section 11 above. We may request information from you to help us confirm your identity and process your request. Please note, these rights are not absolute, and exercising them may require us to cancel your membership. Upon receipt, we will evaluate your request and determine whether an exemption applies. If we deny your request, we will communicate our decision to you.
If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
D. PROCESSING OF PERSONAL INFORMATION IN THE UNITED STATES