Effective Date: March 31, 2024

This notice supplements our Privacy Policy and applies to personal data defined as “consumer health data” subject to the Washington State My Health My Data Act.

1. Consumer Health Data We Obtain 

As described in the Personal Information We Obtain and How We May Use the Personal Information We Obtain sections of our Privacy Policy, at CLEAR, we strive to collect only the personal information about you that we need to provide the products and services that you choose. The data we collect depends on the context of your interactions with CLEAR and the choices you make, the products and features you use, your location, and applicable law. Because consumer health data is defined very broadly, many of the categories of data we collect could also be considered consumer health data, particularly if you choose to use a service or participate in a program we may offer jointly with a healthcare entity.

Examples of consumer health data may include:

• Contact details (such as name, email and postal 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 images and videos (such as images from your mobile device camera);
• Biometric data (such as digital images of fingerprints, irises and face);
• Travel information (such as flight details and itineraries), frequent flyer and other customer loyalty numbers; 
• Information about the devices you use to access the CLEAR service and CLEAR websites (such as IP address);
• Information about your use of the CLEAR service and CLEAR websites, including personal information typed into forms on our website, whether or not you submit the form;
• 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);
• Location information (such as GPS data from your mobile device to enable a location-based service);
• Information about your health (such as vaccination records for CLEAR Health Pass). 

2. Sources of Consumer Health Data

As described further in the Personal Information We Obtain section of our Privacy Policy we may obtain personal information about you from various sources, including the CLEAR Membership application.

3. Why We Collect and How We May Use Consumer Health Data

We collect and use consumer health data for the purposes described in the How We May Use The Personal Information We Obtain section of our Privacy Policy. 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 use consumer health data we obtain about you to: 

• Facilitate and manage CLEAR’s application and enrollment processes;
• Operate and administer the CLEAR programs and services;
• Verify applicants’ and users’ 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 Member Terms.
• Provide services to our consumers (such as travel or airport-related amenities);
• Authenticate CLEAR users, and conduct background checks and security threat assessments concerning CLEAR applicants and users;
• Communicate with consumers and respond to their questions;
• Create and manage online accounts that users 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); or
• Perform data analyses (including market and consumer research).

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.

See the Your Privacy Rights With CLEAR section of our Privacy Policy and the “How to Exercise Your Rights” section below for more details on the controls and choices you may have.

4. Consumer Health Data We Share

We may share each of the categories of consumer health data described above for the purposes described in the Personal Information We Share section of our Privacy Policy. In particular, we may share personal data, including consumer health data, with 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).

5. Third Parties With Which We Share Consumer Health Data

As necessary for the purposes described above and as described in the Personal Information We Share section of our Privacy Policy, we share consumer health data with the following categories of third parties:

• Service providers (such as order fulfillment and data analytics providers, liveness analysis providers such as  iProov , and cloud service providers such as Amazon Web Services). As described in Section 3.D of our Privacy Policy, whenever CLEAR discloses personal information to its service providers, we contractually prohibit them from using or disclosing that information other than to perform services for us or to comply with legal requirements. We also require our service providers to appropriately safeguard the privacy and security of the personal information we disclose to them, and we impose limits on how long they can retain such information.
• The U.S. Transportation Security Administration and airport authorities, pursuant to the purposes described in Section 2.A of our 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).  

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; or
• Otherwise with your consent or at your direction.or participate in a program that we may offer jointly with another entity). 

6. How to Exercise Your Rights

Washington law provides certain rights with respect to consumer health data, including rights to access, delete, or withdraw consent relating to such data, subject to certain exceptions. You can request to exercise such rights as described in the Your Privacy Rights with CLEAR section of our Privacy Policy and as set forth below. 

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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:

1. Contact us at: privacy@clearme.com
2. Call 1-855-253-2763
3. Submit a request here (for access and deletion requests only); or
4. Write to us at:

CLEAR

Attention: Chief Privacy Officer

85 10th Avenue, 9th Floor

New York, New York 10011

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To help protect the security of your personal information, your identity will be verified when we receive your request.

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