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PRIVACY POLICY


TABLE OF CONTENTS

 1.  Information We Obtain
 2.  How We May Use the Information We Obtain
 3.  Information We Share
 4.  Your Choices
 5.  Access and Correction
 6.  Other Online Services and Third-party Features
 7.  How We Protect Personal Information
 8.  Retention of Personal Information
 9.  Children’s Personal Information
 10. Updates to Our Privacy Policy
 11. How to Contact Us
 12. Former Clear Members
 13. Biometric Data Retention for Illinois Enrollees
 14. Notice to California Users
 15. Clear Health Pass and Digital Vaccine Card
 16. Notice to European Residents



Securing data and protecting privacy is job #1 for us at Clear Secure, Inc.
(collectively, with our subsidiaries and corporate affiliates, “CLEAR”).  Our
members 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 members, how we protect that
information, and how members engage with CLEAR from the very beginning --
starting with our Privacy Policy below.

Our Privacy Policy describes:

 * 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

In January 2022, we updated our Privacy Policy to explain certain rights
available to members who are residents of the United Kingdom and European Union.
 We also made some changes to ensure our Privacy Policy remains easy to
understand.

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
 * 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 Usage.

3. INFORMATION WE SHARE

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.

4. YOUR CHOICES

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.

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.

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.

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.

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.

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

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.

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 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

12. FORMER CLEAR MEMBERS

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.

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:

 1. You may begin the process by clicking here
 2. Call 1-855-253-2763
 3. 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).

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

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 ProcessedPurpose for Processing Legal Bases for
ProcessingBiometric 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.

‍




FROM CLEAR USERS

If y’all don’t have @Clear yet and are traveling… Do it! It saved me so much
time this morning with PreCheck at MSP. I was through security in under 10
minutes.

@matthewwdavid

I swear @Clear is the only reason I make my flights on time

@siatrini

Security clearance at @miamiairports 90 seconds. Get @Clear it’s sooo worth it!
😊

‍

@ECronin2
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