Effective Date: July 18, 2020
We may obtain personal information about you from various sources, including the CLEAR membership application. The types of personal information we may obtain include:
We also may collect personal information typed into forms on our website, whether or not the form is submitted.
In addition, when users visit our website, we collect certain information by using cookies, web beacons and other tracking tools to collect certain information including 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. 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. Through these automated collection methods, we obtain “clickstream data, which is a log of content on which a visitor clicks while browsing a website. As the visitor clicks through the website, a record of the action may be collected and stored. Clickstream data also can tell us the type of computer and browsing software a visitor uses, the address of the website from which the visitor linked to our site, and the pages she visits on our site.
We may use biometric data, health information and other personal information we obtain about you to:
We also may use the information in other ways with your express consent, such as when you choose to use a service or participate in a program we may offer jointly with another entity.
In addition to the uses described in 2.A. above, we also may use non-biometric and non-health personal information to:
We do not collect personally identifiable information about a consumer’s online activities over time and across third-party Web sites or online services. Therefore, “do not track” signals transmitted from web browsers do not apply to our website, and we do not alter any of our data collection and use practices upon receipt of such a signal.
We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
In addition to the uses described in 2.A. above, we may use health information as described in greater detail below in Section 15.
We offer you certain choices in connection with the personal information we maintain about you. At any time, you may tell us not to use your personal information for marketing purposes. In addition, you may ask us to refrain from sharing the personal information we maintain about you with third parties for the third parties’ own marketing purposes.
Our website may provide links to other online services for your convenience and information, and 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 relevant third parties, including details on the information they may collect about you, is subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by us, CLEAR is not responsible for these third parties’ information practices.
We maintain administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, 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 call centers that provide routine customer service do not have access to biometric data or government-issued identification information regarding CLEARmembers.
In addition, the following are examples of security measures that are used to safeguard all types of personal information we maintain about our consumers:
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.
Attention: Chief Privacy Officer
65 East 55th Street, 17th Floor
New York, New York 10022
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
The information provided in this section applies only to California residents.
We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide an explanation of the rights and choices we offer California residents regarding our handling of their personal information, along with 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, used and shared and used your personal information during the past 12 months.
· Access. You can request a copy of the personal information that we maintain about you.
· Deletion. You can ask us to delete the personal information that we collected or maintain about you.
Please note that 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:
· Identity verification. CCPA requires us to verify the identity of the individual submitting a request for their personal information before providing a substantive response to the request. Because we take the privacy and security of your personal information seriously, we will verify your identity by asking you to both (a) provide certain information about yourself, and then (b) provide us with a notarized affidavit. Once your identity is verified, we will work to provide you with 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 THAT WE COLLECT, USE AND SHARE
CLEAR will never sell or rent your personal information.
|CCPA Categories (Definitions are available here)||Collected|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||Yes|
|Protected classification characteristics under California or federal law||Yes (age)|
|Internet or other similar network activity||Yes|
|Professional or employment-related information||Yes|
|Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||No|
|Inferences drawn from other personal information||Yes|
We describe the sources through which we collect Personal Information in Section 1, Information We Obtain, above. We describe the purposes for which we use and share this information in Section 2, How We Use the Information We Obtain, above, and Section 3, Information We Share.
The CLEAR Health Pass is a program that enables members to use and share their health data or information derived from this data to indicate eligibility for access or facilitate access at locations that use the CLEAR Health Pass for these purposes. The 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, and/or diagnostic test results. We may receive such health information from you directly or from third parties (such as health care providers or labs) that are permitted to share this information with us.
If you use the CLEAR Health Pass service, we may use your health information or information derived from this data to operate and administer the CLEAR Health Pass, evaluate and improve our service, as well as the purposes set forth above in Section 2A. Additionally we may share health information we obtain about you or information based on this information with locations that use the CLEAR Health Pass program. 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.