Legal

Privacy Policy

Securing data and protecting privacy is job #1 for us at CLEAR.  Our customers trust us to provide frictionless experiences, to keep your data safe and to protect your privacy and we’re obsessed with delivering on that promise. Importantly, we will never sell or rent your personal information. We are transparent about what we know about our customers, how we protect that information, and how customers engage with CLEAR from the very beginning -- starting with the privacy policy below. 

We launched the CLEAR Health Pass in June 2020 in response to the COVID pandemic. CLEAR Health Pass enables participating members to link their identity to certain health characteristics to facilitate access to venues that use the CLEAR Health Pass. Our June 2020 Privacy Policy Update includes information specific to this new feature of the CLEAR service.

Effective Date: June 2, 2020

We at CLEAR, along with our subsidiaries and affiliates (collectively, “CLEAR”), respect your concerns about privacy and value our relationship with you. This Privacy Policy describes the types of personal information we obtain about consumers and others identified below, how we may use the information, with whom we may share it, and the choices available regarding our use of the information. The Privacy Policy also describes the measures we take to safeguard your personal information and how you can contact us about our privacy practices.

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;
  • Biometric data (such as digital images of fingerprints and irises);
  • 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 may be contained in a consumer report);
  • 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;
  • Information about your health, 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 to be provided to us (such as shopping and language preferences).

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.

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 the CLEAR Health Pass described further in Section 15
  • Verify applicants’ and members’ identities, including authenticating users of the CLEAR services
  • Comply with and enforce applicable legal requirements and policies, including this Privacy Policy and enforce our Website Terms of Use and the CLEAR Membership Terms and Conditions

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.

B. NON-BIOMETRIC AND NON-HEALTHPERSONAL 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
  • Respond to and communicate with our consumers about their questions and comments
  • Create and manage online accounts that consumers 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)

In addition, by collecting information through cookies, web beacons and other automated means on our website, we learn how to best tailor our website to our visitors. We may use cookies to customize visits to our site and deliver content consistent with our visitors’ interests and the manner in which our visitors browse the site. We may use IP addresses to help diagnose problems with our server and to administer our website. We also may use IP addresses to help identify visitors to our site for the duration of a session and to gather demographic information about our visitors. We may use clickstream data to determine how much time visitors spend on each web page of our website, how visitors navigate through the site, and how we may tailor our site to better meet the needs of our visitors.

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.

C. HEALTH INFORMATION

In addition to the uses described in 2.A. above, we may use health information as described in greater detail below in Section 15.

D. INTEREST-BASED ADVERTISING

Data about your visit to our website is being collected for use in providing advertising about products and services tailored to your individual interests. You can choose whether or not to have your information collected for that purpose. This section of the Privacy Policy provides details and explains how to exercise that choice.

You may see certain ads on other websites because we participate in advertising networks administered by third-party vendors. These networks track your online activities over time by collecting information through automated means, including through the use of cookies and web beacons. The networks use this information to show you advertisements that are tailored to your individual interests. The information our ad network vendors collect includes information about your visit to our website, such as the pages you have viewed. This process also helps us track the effectiveness of our marketing efforts. To learn more about how to opt out of ad network interest-based advertising, click here.

3. INFORMATION WE SHARE

We never sell or rent personal information about you.

In addition, we do not share or otherwise disclose such information except as described in this Privacy Policy.

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 we have retained to perform services on our behalf (such as order fulfillment and data analytics). We also may disclose biometric data and other personal information for the purposes described in Section 2.A of this Privacy Policy to the U.S. Transportation Security Administration and other government agencies if required by law. In addition, we may disclose the information to 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

In addition to the disclosures described in Section 3.A above, we also may share non-biometric and non-health personal information (except for government-issued identification numbers and payment card and financial account numbers) we obtain about you with our affiliates for the purposes described in Section 2.B of this Privacy Policy.

C. HEALTH INFORMATION

In addition to the disclosures described in Sections 3.A above, if you use the CLEAR Health Pass we also may share health information we obtain about you or information based on this information with locations that use the CLEAR Health Pass program, for the purposes described in Section 2.A and Section 15 of this Privacy Policy.

D. SERVICE PROVIDERS

We contractually prohibit our service providers who access our consumers’ personal information from using or disclosing the information other than to perform services on our behalf or comply with legal requirements. We require these service providers by contract to appropriately safeguard the privacy and security of the consumer personal information they collect, use, disclose or otherwise process on our behalf.

E. DISCLOSURES FOR OTHER PURPOSES

We may disclose information we obtain about you if we are required to do so by law or pursuant to legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent or at your direction.

We reserve the right to transfer information we have about you in the event we sell or transfer all or a portion of our business or assets, as permitted or required by law. Should such a transfer occur, we will use reasonable efforts to direct the transferee to use the personal information in a manner that is consistent with this Privacy Policy.

We also may share the information we obtain about you in other ways for which we provide specific notice at the time of collection.

4. YOUR CHOICES

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.

You can direct us at any time not to send you marketing emails by (1) clicking on an unsubscribe link in marketing emails you may receive from us, (2) replying to marketing emails you receive from us and including the word “unsubscribe” in the subject line, or (3) emailing us at privacy@clearme.com and including the word “unsubscribe” in the subject line and your name in the body of the email. In addition, you can tell us your preference by contacting us as specified in the “How to Contact Us” section of this Privacy Policy.

5. ACCESS AND CORRECTION

You may obtain a copy of certain personal information we maintain about you or update or correct inaccuracies in that information by using an online account you establish on the CLEAR website at clearme.com . To help protect your privacy and maintain security, we will take steps to verify a consumer’s identity before granting access to the information. In addition, if you believe that the personal information we maintain about you is inaccurate, you may request that we erase, rectify, complete or amend the information by contacting us as indicated in the “How to Contact Us” section of this Privacy Policy. If we deny an access request, we will notify you of the reasons for the denial and offer an opportunity to challenge our decision. Please note that certain changes to the personal information we maintain about you may require us to (1) reevaluate eligibility for participation in the CLEAR program and (2) obtain new copies of government-issued identification documents.

6. OTHER ONLINE SERVICES AND THIRD-PARTY FEATURES

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.

7. HOW WE PROTECT PERSONAL INFORMATION

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:

  • Procedures for the identification and classification of personal information and implementation of safeguards appropriate to the sensitivity of the information;
  • access control procedures designed to verify a business need before access to personal information is granted, and procedures for the periodic review of access permissions;
  • procedures for termination of access to personal information designed to curtail access to the information by terminated personnel or 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; and
  • physical and environmental security procedures designed to prevent unauthorized access, damage or interference to business premises and information.

8. RETENTION OF PERSONAL INFORMATION

When you terminate your CLEAR membership, you may request that we remove from our databases any personal information we maintain about you. If you apply for CLEAR membership and subsequently decide not to complete the application, you may request that we remove your personal information from our databases. You may request removal of your personal information as described in this paragraph by contacting us as specified in the “How to Contact Us” section of this Privacy Policy, and we will honor your request, except that we may retain limited information so we can 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.

10. UPDATES TO OUR PRIVACY POLICY

This Privacy Policy may be updated periodically to reflect new CLEAR program features or changes in our personal information practices. We will post a notice for consumers at the top of this Privacy Policy of any significant changes to this Privacy Policy. We will indicate at the top of the Privacy Policy when the policy was most recently updated.

11. HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy, any privacy related complaints, or would like us to update information we have about you or your preferences, please contact us by email at privacy@clearme.com. You also may write to us at:

CLEAR
Attention: Chief Privacy Officer
65 East 55th Street, 17th Floor
New York, New York 10022

12. FORMER CLEAR MEMBERS

For members of the former CLEAR program prior to 2010 who subsequently chose not to participate in the new CLEAR program, your information is governed by the former program’s Privacy Policy, available HERE.

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.

 

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:

  • You may begin the process by clicking here
  • Call 1-855- 253-2763
  • Send an email to us at: privacy@clearme.com

·          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. 

As described above in this Privacy Policy, we do use cookies and other tracking tools on our website to analyze website traffic and facilitate advertising. In addition, by using the CLEAR Health Pass service at a specific facility, you direct us to disclose certain information about your health to that facility.   

The CCPA requires that companies disclose their collection and use of specific categories of Personal Information enumerated in CCPA. Below is a table of those categories and a notification as to whether CLEAR collects each. Please note that, while each “CCPA category” may cover many types of personal information, CLEAR collects, uses and shares only the personal information described in Section 1 of this Privacy Policy.

CCPA Categories (Definitions are available here) Collected
Identifiers Yes
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)
Commercial information No
Biometric information Yes
Internet or other similar network activity Yes
Geolocation data Yes
Sensory data No
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.

15. CLEAR HEALTH PASS

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 is powered by your health information. We may receive 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.