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.

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
• Comply with and enforce applicable legal requirements and policies, including this Privacy Policy, our Terms of Use and the CLEAR Membership Terms and Conditions

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 learn how to best tailor our website to our visitors by collecting information through cookies, web beacons and other automated tracking tools on our website. We may use cookies to customize visits to our site and deliver content. 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 and gather demographic information about visitors to our site. 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 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

We collect data about your visit to our website to provide advertising about products and services tailored to your individual interests. Therefore, you may see certain ads on other websites because we participate in advertising networks run by third-party vendors. Those networks track your online activities through automated means, including the use of cookies and web beacons. The networks use this information to show advertisements tailored to your interests. Our ad network vendors receive information about your visit to our website, such as the pages you have viewed. This information also helps us track the effectiveness of our marketing efforts. 

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 Notice.

We never sell or rent personal information about you.

We do not share or disclose personal 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 (such as order fulfillment and data analytics) 
• The U.S. Transportation Security Administration, pursuant to the purposes described in Section 2.A of this Privacy Policy
• 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

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 Section 3.A above, if you use the CLEAR Health Pass product we also may share health information we obtain about you or information based on this information with private and public entities that use CLEAR Health Pass, for the purposes described in Section 2.A and Section 15 of this Privacy Policy.

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 reserve the right to transfer information we have about you if we sell or transfer all or part 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 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.

We offer you certain choices about your personal information. At any time, you may request that we not use your personal information for marketing purposes. You may also request we not share your personal information with third parties for their own marketing purposes. You can tell us your preferences by contacting us as indicated in Section 11 of this Privacy Policy.

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 privacy@clearme.com with the word “unsubscribe” in the subject line and your name in the body of the email.

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.

If you believe the personal information we maintain about you is inaccurate, you may request that we edit the information by contacting us as indicated in Section 11 of this Privacy Policy. Please note that changes to your personal information may require us to reevaluate your eligibility for participation in the CLEAR program and/or obtain new copies of government-issued identification documents.

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.

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.

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. 

To request removal of your personal information as described above, you may contact us as indicated in Section 11 of this Privacy Policy. 

We will honor your requests, except that we may retain limited information to comply with your request not to be contacted in the future.

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.

We may update this Privacy Policy periodically to reflect new CLEAR program features or changes in our personal information practices. We will post a notice at the top of this Privacy Policy of any significant changes to this Privacy Policy. We will also state there when this Privacy Policy was most recently updated. We will provide other notice to you as required by law.

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 with:

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:

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

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

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.

 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: privacy@clearme.com 

·          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. 

As described above in this Privacy Policy, we use cookies and other tracking tools on our website to analyze website traffic and facilitate advertising.  We may share personal information with third parties based on your consent if you accept certain of these cookies. 

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.   

The CCPA requires companies disclose their collection and use of specific categories of Personal Information listed in CCPA. Below is a table of those categories and a notification indicating 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 and other information from your government-issued identification)
 
 
 
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). 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).

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.

We provide the notice in this Section to users of CLEAR who reside in Europe. 

A. CONTROLLER, REPRESENTATIVE, AND DATA PROTECTION OFFICER 

CLEAR is the controller of your personal information covered by this Privacy Policy. 

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
Cork T23AT2P
Ireland

And if you are a UK resident, you may write to VeraSafe at:

37 Albert Embankment
London SE1 7TL
United Kingdom

In addition, CLEAR has appointed a Data Protection Officer, whom you can contact at privacy@clearme.com.

B. LEGAL BASES FOR PROCESSING

Information Being Processed
Purpose for Processing 
Legal Bases for Processing
Biometric Data and Health Personal Information
Facilitate and manage CLEAR's application and enrollment processes.
Operate and administer CLEAR programs, including Health Pass.
Verify applicants' and members' identities, including authenticating users of CLEAR services.
Comply with and enforce applicable legal requirements and policies, including this Privacy Policy.
Enforce our Website Terms of Use and the CLEAR Membership Terms and Conditions.
Your consent.
Where necessary to perform a task carried out in the public interest.
Non-Biometric and Non-Health Personal Information
Facilitate and manage CLEAR's application and enrollment processes. 
Operate and administer CLEAR programs, including Health Pass.
Verify applicants' and members' identities, including authenticating users of CLEAR services.
Comply with and enforce applicable legal requirements and policies, including this Privacy Policy.
Enforce our Website Terms of Use and the CLEAR Membership Terms and Conditions.
Provide services to our consumers.
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).
Comply with and enforce applicable legal requirements and policies.
Where necessary to perform a task carried out in the public interest.
Our legitimate interests in providing the services you access and request.

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 privacy@clearme.com, 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 

To provide our services and to comply with the requirements our business customers and government organizations impose on our services, we will process your personal information in the United States for the purposes we have set out in this Privacy Policy.  If such processing involves the transfer of personal information to the United States in a manner governed by European data protection law, the transfer will be performed pursuant to the applicable requirements of the law, such as standard contractual clauses, the individual’s consent, or in other circumstances permitted by European data protection law.