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CLEAR Privacy Policy

Effective Date: October 7, 2011

CLEAR Privacy Policy

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 governs the personal information we obtain about consumers, including those (1) who submitted their information at www.clearme.com or at a CLEAR authorized enrollment location after May 3, 2010, or (2) who were applicants to or members of the former CLEAR program as of June 22, 2009, and who subsequently chose to participate in the new CLEAR program. This policy does not apply to the personal information of individuals who were applicants to or members of the former CLEAR program and who subsequently chose not to participate in the new CLEAR program. That information is governed by the former program's Privacy Policy.

This Privacy Policy describes the types of consumer personal information we obtain, how we use the information, with whom we share it, and the choices we offer regarding our use of the information. We also describe the measures we take to protect the security of the information and how to contact us about our privacy practices.

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1. Information We Obtain

We may obtain personal information about consumers from various sources, including the CLEAR membership application. The types of personal information we may obtain include:

  • Contact details (such as name, postal address, telephone number and email address)
  • 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)
  • Tracking information about use of the CLEAR card
  • Payment card and 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)
  • Survey information
  • Location information
  • Contact information for friends or others you would like us to contact
  • Other information you may provide to us (such as shopping and language preferences)

We also may collect personal information typed into forms on clearme.com, whether or not the form is submitted.

In addition, when users visit our website, we collect certain information by automated means, such as cookies and web beacons. The information we collect in this manner includes IP address, browser type, operating system, referring URLs, information on 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

We may use biometric data and other personal information we obtain about consumers to:

  • Facilitate the CLEAR application and enrollment process
  • Administer the CLEAR program
  • Verify applicants' and members' identities, including authenticating users of the CLEAR card, and conducting background checks and security threat assessments concerning CLEAR applicants and members
  • Comply with applicable legal requirements and our policies, and enforce our Website Terms of Use and the CLEARmembership 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 Personal Information

We also may use personal information other than biometric data to:

  • Provide services to our consumers (such as travel or airport-related amenities)
  • 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 also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

i. Internet-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 our consumers. 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

We may share biometric 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. We also may disclose biometric data and other personal information for the purposes described in Section 2.A of this Privacy Policy to airport authorities, the U.S. Transportation Security Administration and other government agencies. 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 Personal Information

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

C. 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.

D. Disclosures for Legal Compliance Purposes

We may disclose information we obtain about consumers if we are required to do so by law or pursuant to legal process.

E. Disclosures in the Event of a Sale, Transfer or Contract Termination

We reserve the right to transfer personal information we have about consumers 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.

In some circumstances, we may be required by contract to transfer personal information we maintain about a particular consumer to the consumer's relevant airport authority. This may occur, for example, if the airport authority and CLEAR terminate their contract. In these circumstances, the airport authority to which we transfer the information will be responsible for the privacy and security of the information following the transfer.

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 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

Individuals may obtain a copy of certain personal information we maintain about them or update or correct inaccuracies in that information by using an online account they establish on the CLEAR website at clearme.com. To help protect privacy and maintain security, we will take steps to verify a consumer's identity before granting access to the information. In addition, if a consumer believes that the personal information we maintain about him or her is inaccurate, the consumer 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 the individual 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 consumers may require us to (1) reevaluate eligibility for participation in the CLEAR program and (2) obtain new copies of government-issued identification documents.

6. How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect consumer 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.

7. Data Retention

When a consumer terminates his or her CLEARmembership, the consumer may request that we remove from our databases any personal information we maintain about the consumer. If a consumer applies for CLEARmembership and subsequently decides not to complete the application, the consumer may request that we remove his or her personal information from our databases. An individual may request removal of his or her 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 these requests, except that we may retain limited information so we can comply with a consumer's intent not to be contacted in the future.

8. 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 prominent notice for consumers at the top of this Privacy Policy of any significant changes to this Privacy Policy for at least 90 days after the effective date of the changes. We will indicate at the top of the Privacy Policy when the policy was most recently updated.

9. How to Contact Us

If you have any questions or comments about this Privacy Policy, or if you 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
595 Madison Avenue
39th Floor
New York, New York 10022

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