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.
This Privacy Policy describes how we handle the personal information that we obtain in the course of providing services to consumers who accept our Member Terms to become CLEAR members. This Privacy Policy describes:
In January 2024, we updated this Privacy Policy in order to (1) comply with the principles of the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the U.K. Extension to the EU-U.S. DPF and the Swiss-U.S. Data Privacy Framework and (2) include certain disclosures related to fraud prevention.
In April 2023, we updated Section 1 of this Privacy Policy to include that we may collect videos from our users, and Section 3 to provide more information about how our service providers process personal information.
In June 2023, we updated the Privacy Policy to provide more information about privacy rights for our users in Canada and Mexico.
Effective Date: January 31, 2024
At CLEAR, we strive to collect only the personal information about you that we need to provide the products and services that you choose. We may obtain personal information about you from various sources, including the CLEAR membership application. The types of personal information we may obtain include:
Additionally, when users visit our website, we may 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 may 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. To learn more, visit our Cookie Usage page.
As described further below, CLEAR uses your personal information to provide you services, to process your transactions, to communicate with you, for security and fraud prevention, and to comply with law. We may also use personal information for other purposes with your consent.
A. BIOMETRIC DATA AND OTHER PERSONAL INFORMATION, INCLUDING HEALTH INFORMATION
We may use biometric information, health information and other personal information we obtain about you to:
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 Section 2.A. above, we also may use non-biometric and non-health personal information to:
We learn how to best tailor our website to our visitors by collecting information through cookies, web beacons and other analytics tools on our website. We may use website analytics to determine how much time visitors spend on each web page of our website, how visitors navigate through the site, and how we may change our site to better meet the needs of our visitors. We may also use cookies to customize visits to our site and deliver content. See our Cookie Usage page for more information. 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 do not collect personally identifiable information about a consumer’s online activities over time or across third-party Web sites or online services.
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 Section 2.A. above, we may use health information with our health-related services such as CLEAR Health Pass and Digital Vaccine Card.
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, pixels 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.
Where applicable, we limit how our third-party advertising partners use data collected via cookies and other tracking. You can also choose whether to have this information collected through the use of the cookie preferences center (by clicking on the green cookie in the bottom, left-hand corner of your browser screen), browser settings and other third-party tools, and by implementing Global Privacy Control on your browser. To learn more, visit our Cookie Usage page.
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 users of CLEAR with:
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 CLEAR Health Pass 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 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, prevent fraud 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. We permit service providers to retain such personal information only for as long as is necessary to provide the services to CLEAR, and we always limit service providers’ data retention terms to comply with applicable law and this Privacy Policy.
E. DISCLOSURES FOR OTHER PURPOSES
We may disclose information we obtain about you:
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.
At CLEAR, we respect your ability to know, access, correct, restrict the processing of, and delete your personal information. We’ve honored these rights since CLEAR launched in 2010 for all our members, regardless of where they live. To exercise your privacy rights, you may:
CLEAR
Attention: Chief Privacy Officer
85 10th Avenue, 9th Floor
New York, New York 10011
To help protect the security of your personal information, your identity will be verified when we receive your request.
We may share non-sensitive identifiers and personal information pertaining to internet or other similar network activity with third parties for advertising purposes only with your opt-in consent by accepting targeting cookies on our cookie banner, which can be accessed by clicking on the green cookie in the bottom, left-hand corner of your browser screen. CLEAR also honors Global Privacy Control. Please review our Cookie Usage page for more details.
You can also direct us at any time not to send you marketing emails by:
There may be situations where we cannot grant certain types of these requests — for example, if you ask us to delete your personal information, but CLEAR is legally obligated to keep a record of that transaction to comply with law. We may also decline to grant a request where doing so would undermine our legitimate use of data for anti-fraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns.
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:
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.
Our website and other services 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 these third parties, including details on the information they may collect, are 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.
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 10 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. If we learn that we have collected personal information online from a child under the age of 13, we will delete it.
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 exercise your rights under this Privacy Policy, you may:
CLEAR
Attention: Chief Privacy Officer
85 10th Avenue, 9th Floor
New York, New York 10011
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 or
(b) three years following your last interaction with CLEAR.
The information provided in this section applies only to California residents.
A. PERSONAL INFORMATION WE COLLECT, USE AND SHARE
The California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”), requires companies to disclose their collection and use of specific categories of personal information. Below is a table of those categories that CLEAR collects, or has collected in the past 12 months. Please note that, while each 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 (Personal Information We Obtain). We also describe the sources through which we collect Personal Information in Section 1. We describe the purposes for which we use and share this information and the categories of third parties to whom we disclose personal information above in Section 2 (How We May Use the Personal Information We Obtain), and Section 3 (Personal Information We Share).
CLEAR will never sell or rent your personal information.
Under California law, the definition of “sharing” is narrower than the term’s common use, and how we use the term “share” in Section 3 of this Privacy Policy. Under California law, “sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged. California law defines “cross-context behavioral advertising” as the “targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s activity across businesses, distinctly-branded websites, applications, or services, other than the business, distinctly-branded website, application, or service with which the consumer intentionally interacts.”
As described above in this Privacy Policy, CLEAR uses cookies and other tracking tools on our website to facilitate advertising. With your opt-in consent via our cookie consent banner, we may “share” (as the term is defined under California law) non-sensitive identifiers and personal information pertaining to internet or other similar network activity with third parties for advertising purposes.
B. YOUR RIGHTS UNDER CALIFORNIA LAW
California consumers have the following rights:
C. HOW TO SUBMIT A REQUEST
CLEAR does not sell the personal information of California consumers and does not discriminate in response to privacy rights requests. CLEAR uses sensitive personal information only to provide services to our users, as described in greater detail in this Privacy Policy and our Member Terms. To exercise your other rights under California law, you may:
CLEAR
Attention: Chief Privacy Officer
85 10th Avenue, 9th Floor
New York, New York 10011
D. OTHER NOTES REGARDING CALIFORNIA PRIVACY LAW
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 accordance with the laws of those jurisdictions. If you have any questions about how we or our service providers treat your personal information, please contact our Privacy Officer at the contact information in Section 10.
To verify your identity, we collect a selfie as well as a photo of your government-issued ID. We extract information about your facial features from the photos and use this to match your selfie with the photo on your ID card. CLEAR will retain biometric data and other personal information only until the occurrence of the first of the following: (a) the initial purpose for collecting or obtaining such data has been satisfied or (b) three years following your last interaction with CLEAR (unless you request to close your account earlier).
In addition to the rights described in section 4 above, you may contact us using the contact information in section 4 to request to access, correct, or delete your personal information at any time, subject to legal and contractual restrictions.
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
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:
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 10 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. COMPLIANCE WITH THE DATA PRIVACY FRAMEWORK PRINCIPLES
CLEAR’s U.S.-based entities listed: Here (the “CLEAR Certifying Entities”) comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. The CLEAR Certifying Entities have certified to the U.S. Department of Commerce that they adhere to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. The CLEAR Certifying Entities have certified to the U.S. Department of Commerce that they adhere to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy
Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
CLEAR
Attention: Chief Privacy Officer
85 10th Avenue, 9th Floor New York, New York 10011
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, the CLEAR Certifying Entities commit to refer unresolved complaints concerning handling of personal data received in reliance on those frameworks to VeraSafe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.verasafe.com/privacy-services/dispute-resolution/submit- dispute/ for more information or to file a complaint. The services of VeraSafe are provided at no cost to you. Individuals have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms.
The CLEAR Certifying Entities are responsible for the processing of personal data they receive under the DPF and subsequently transfer to a third party acting as an agent on its behalf. CLEAR complies with the DPF Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions.
The Federal Trade Commission has jurisdiction over the CLEAR Certifying Entities’ compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). We may be required in certain circumstances to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
E. 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, unless we specify otherwise. 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.
We provide the following notice for services provided to consumers within Mexico to comply with the Federal Law on Protection of Personal Data Held by Private Parties (“LFPDPPP”), its Regulations and the Privacy Notice Guidelines (the “Mexican data protection legislation”).
This addendum is an integral part of the CLEAR Privacy Policy. If there is any conflict, this addendum shall prevail over the CLEAR Privacy Policy for services provided to consumers within Mexico, to the extent that the Mexican data protection legislation applies.
Identity and address of the Controller
Clear Secure, Inc. is the Controller of your data covered by this Privacy Policy, with an address as set forth in Section 10.
Personal Information We Obtain
In connection with the list of personal data collected by CLEAR set forth in Section 1, “Personal Information We Obtain”, please be informed that biometric data (such as digital images of fingerprints, irises, and face) and information about your health (such as vaccination records for CLEAR Health Pass) are considered sensitive personal data under the Mexican data protection legislation.
How We May Use the Personal Information We Obtain
We use your data for the purposes set forth in Section 2, “How We May Use the Personal Information We Obtain.” From those purposes only the following would be considered as secondary:
You can direct us at any time not to send you marketing communications like these by:
Personal Information We Share
For personal data sharing described in Section 3.A, “Biometric Data and Other Personal Information, Including Health Information,” and Section 3.C, “Health Information,” CLEAR may transfer your personal data to our commercial partners with your express consent when you choose to use a service or participate in a program we offer jointly.
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, unless we specify otherwise.
You can opt out of CLEAR processing or sharing your personal data at any time using the mechanisms established in Section 4 or through the appropriate mechanism implemented when we ask for your consent.
Your Privacy Rights With CLEAR
You can exercise the rights established in Section 4, “Your Privacy Rights with CLEAR.” In addition, consumers using our services in Mexico have these additional data protection rights:
You may exercise these rights using the same procedures outlined in Section 4, including by opting out of marketing communications via the procedures as set forth above.
Children’s Personal Information
As established in Section 8, “Children’s Personal Information,” CLEAR is intended for a general audience and is not directed at children. We will collect personal data from a child under the age of 18 only if we have the proper authorization of the parents or legal guardians of the child. If we learn that we have collected personal data from a child under 18 without authorization from the child’s parents or guardians, we will delete it.