Privacy Policy

Pursuant to California’s Shine the Light statute (Cal. Civ. Code Sec. 1798.83), you can control if we share information with third parties for their marketing purposes. To opt-out of us sharing your information with third parties for such promotional purposes, email us at privacy@clearcapital.com or write to us in the “Contact Us” section of this Policy and include “Marketing Opt-Out” in your request.

In addition, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain other rights concerning their personal information. To a large extent, the information we collect is regulated by GLBA or another law that exempts it from CCPA, but to the extent that Clear Capital is subject to CCPA, this section describes (1) the categories of personal information, collected and disclosed by us, subject to CCPA, (2) your privacy rights under CCPA, and (3) how to exercise your rights under CCPA.

When we use the term “personal information” in this section, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

a. Personal Information We Collect.
If you are a California consumer, please be aware that we collect, process, and maintain personal information to fulfill certain business purposes related to our Platform. We will not collect additional categories of personal information or use personal information collected for additional purposes without providing you notice. Within the preceding twelve (12) months we and our service providers have and may collect, and you may consent to provide, the categories of personal information set forth below. We disclose each of these categories of personal information with our service providers for our business purposes (to enable the service providers to provide their services) and as otherwise described in the “How We Disclose Personal Information” section above.

• Identifiers (for example, name, postal address, date of birth, email address, IP address, and online identifiers);
• Categories of personal information as defined by Cal. Civ. Code § 1798.80 (for example, name, signature, Taxpayer Identification Number, telephone number, passport number, driver’s license number, insurance policy number, account numbers);
• Protected classifications under California or federal law (for example, age, citizenship status, national origin or ancestry);
• Commercial information (for example, transaction history);
• Internet or other electronic network activity information, including information on your usage of our Sites;
• Geolocation data;
• [Professional or employment related information];
• [Educational information];
• Sensory data (for example, audio from call recordings); and
• Inferences drawn from any information identified above to create a profile

b. Your Privacy Rights.
In accordance with the CCPA, California consumers may exercise under certain conditions the following four (4) categories privacy rights with respect to their personal information. Please note: you will not be discriminated against in any way by virtue of your exercise of the rights listed below, which means we will not deny goods or services to you, provide a different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.

c. How to Exercise Your Rights.

If you would like to exercise your rights listed above, please send (or have your authorized agent send) an email to privacy@clearcapital.com or call us toll-free at: (866) 770-5710. You have a right not to receive discriminatory treatment by any business when you exercise your CCPA rights.

While we take measures to ensure that those responsible for receiving and responding to your request are informed of your rights and how to help you exercise those rights, when contacting us to exercise your rights, we ask you to please adhere to the following guidelines:

• Tell Us Which Right You Are Exercising: Specify which right you want to exercise and the personal information to which your request relates (if not to you). If you are acting on behalf of another consumer, please clearly indicate this fact and your authority to act on such consumer’s behalf;
• Help Us Verify Your Identity: Provide us enough information to verify your identity. For example, provide us (at a minimum) your full name, address, and phone number. Please note that if we cannot initially verify your identity, we may request additional information to complete the verification process. Any personal information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.
• Direct Our Response Delivery: Inform us of the delivery mechanism with which you prefer to receive our response. You may specify, for example, email, mail, or through your account (if you have one with us).

Please note that you don’t need to create an account with us in order to make a request to exercise your rights hereunder.

d. How We Respond to Your Requests.

In all cases, we will respond to your request within 45 days. However, where reasonably necessary, we may extend our response time by an additional 45 days, provided we send you notice of such extension first. We will provide the information to you via your preferred delivery mechanism. If the information is provided to you electronically, we will provide you the information in a portable format and, to the extent technically feasible, in a machine readable, readily useable format that allows you to freely transmit this information without hindrance.

Please note that we will not charge you for making a request, provided that you make no more than two (2) requests per year. If you make three (3) or more requests in any given twelve (12) month period, we may refuse to respond to such requests, if determined by us to be unfounded or excessive (e.g. repetitive in nature), or we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested. If we refuse to act on the request, we will provide you notice and the reason for our refusal to act.

10. Storage, Security and Retention of Information
We have taken reasonable steps to protect the information users share with us, including, but not limited to, setup of processes, equipment and software to avoid unauthorized access or disclosure of this information. No transmission of information via the Internet can be entirely secure, however, so please always use caution when submitting Personal Information. We will retain your Personal Information in compliance with the uses described in this Policy, as well as to comply with our legal, financial reporting, or compliance obligations.

11. Links to Third Parties and their Sites
Our Platform may include third party content and links to third party websites and services that collect Personal Information. We do not control these third parties and this Policy does not apply to their privacy practices. We are not responsible for the practices of these third parties or how they use information you provide to them. Please read the third parties’ privacy policies carefully.

12. Contacting Us

If you have any questions about this Policy, or our privacy practices, please email us at privacy@clearcapital.com or legal@clearcapital.com or write to us at:

ClearCapital.com, Inc.
Attn: General Counsel
300 E 2nd St, Ste 1405
Reno, NV 89501

13. Updates
Please note that this policy may be amended from time to time. Unless otherwise indicated, any changes to this Policy will apply immediately upon posting to the Platform so please check our site periodically for updates. You can see when this Policy was last updated by reviewing the “Last Updated” legend at the top of this page. We will provide notice of material changes by updating the Policy here, and communicating with you in the manner and format in which we typically communicate with you in our regular course of business, as required by applicable law.