#### 1. Introduction At CLEAR, we are committed to protecting the privacy and security of your Personal Data. Our Members trust us to provide frictionless experiences, to keep their data safe and to protect their privacy, and we’re obsessed with delivering on that promise. Importantly, CLEAR does not sell your biometric or sensitive Personal Data. We are transparent about the information we have, how we protect and use it, and how Members engage with CLEAR from the very beginning—starting with our Privacy Policy below. #### 2. Policy This Privacy Policy describes how Clear Secure, Inc., and its corporate subsidiaries and affiliates (collectively, “CLEAR”, “we”, and “us”) use your Personal Data when you access or use any of our products and services, directly or through our partners, including identity verification, faster access to partner services and fraud prevention (collectively, “CLEAR Services” or “Services”), visit our Member websites, or communicate with us. This Privacy Policy does not apply to Personal Data we collect or process when you are a CLEAR employee or contractor or when you apply for employment at CLEAR. Additionally, this Privacy Policy does not apply to activities that CLEAR undertakes as a service provider or processor to a third party, including a CLEAR partner. #### 3. What Personal Data Do We Have? Personal Data is any information that identifies you or that CLEAR can use to identify you. Personal Data does not include information that is anonymous or that has been de-identified so that it cannot identify you. When you interact with and use CLEAR Services, we may use, collect or process the following kinds of Personal Data, including information derived from this Personal Data, depending on the Services you use, your jurisdiction, and what is permitted or required by the laws that apply: - **Account and Membership information**: including your name, Membership and service level, renewal information, account credentials, and account settings; - **Contact information**: including your name, address, email address, phone number, and information about individuals you may ask us to contact; - **Business information**: including your job title, email address and phone number, professional or employment information, and your employer’s name, address, and contact information; - **Government-issued ID information**: including passport or national ID number, social security number, copies of your government-issued identification documents; - **Identifiers**: including internet protocol (IP) address, and identifiers for the devices you use to access our products, services, or websites; - **Demographic and physical information**: including information from your government-issued ID, such as your age, date and place of birth, connected travelers including family Members, citizenship, employment and education status, gender, height, and weight; - **Biometric data**: including faceprints, fingerprints, iris scans, and digital images and video of your fingers, eyes, and face; - **Payment and financial information**: including your payment card details, billing address, and financial account information; - **Transaction and background data**: including information about past transactions with CLEAR or our partners, failure to pay or return status with prior merchants; - **Travel information**: including flight details and itineraries, travel preferences, CLEAR lane wait times, frequent flyer and other customer loyalty numbers; - **Communications with CLEAR**: including customer support interactions, chatbot conversations, any correspondence that you send us by postal mail, email, telephone, or webform; - **Health insurance and appointment information**: including information about health partners and information about your insurance provider and coverage; - **Location information**: including precise geolocation as derived from your IP address and GPS information from your device; - **Usage and Device information**: including information about how and when you interact with our Services and Member websites, language preference, and internet or similar network activity on the devices you use. #### 4. How Do We Receive Your Personal Data? CLEAR may receive Personal Data from the following sources: - **Directly from you**: including when you create an account, upload Personal Data to our Services, communicate with us; - **Automatically through our Services**: including from your device when you use or interact with our Services or visit our Member websites; - **From our partners or other third parties**: including partners you use CLEAR with, and others who help us provide our verification and fraud prevention services; - **From our service providers**: including when we engage them to enable certain technology and when they collect, use or process your Personal Data on our behalf. #### 5. Why Do We Ask for Personal Data? Depending on what Services you use or access, we may use your Personal Data for the following purposes: - **To provide our Services**: including to create your account, manage our application and enrollment process, operate our Services; - **To provide customer support**: including by communicating with you about and addressing support issues; - **To evaluate, improve and update our Services**: including by analyzing how our Services are used; - **For advertising and marketing purposes**: including understanding which of our Services are relevant to you; - **To detect and prevent fraud and malicious activity**: ensuring that you are who you say you are; - **To protect our systems**: including detecting, preventing, and responding to security threats; - **To communicate with you**: including in response to your communications; - **To enforce our rights and policies**: including ensuring compliance with our Member Terms; - **For legal compliance purposes**: including to investigate or respond to government inquiries. #### 6. Who Do We Share Personal Data With? CLEAR does not sell your biometrics or sensitive Personal Data. Depending on how you interact with CLEAR or our Services, we may securely share your Personal Data as explained below: - **With Your Consent**: including when you choose to use a Service or participate in a program we offer; - **TSA**: when using our paid airport service CLEAR+; - **Federal research and standards organization**: to support product evaluation and alignment with applicable technical benchmarks; - **To our Partners**: to verify your identity, detect and prevent fraud; - **To our Service Providers**: to help power our technologies or perform services on our behalf; - **Safety or Financial Loss**: to prevent physical harm or financial loss; - **As Legally Required**: including to governmental or regulatory bodies; - **Corporate Restructuring**: as part of our assets during a merger or acquisition. #### 7. Transferring Personal Data Internationally CLEAR may store, process, and transfer your Personal Data in a country other than that where you live, including the United States. We engage in international transfers only as permitted by applicable law and enter into appropriate data protection terms designed to ensure an adequate level of protection. #### 8. How We Protect Personal Data We use appropriate technical, organizational, and physical controls to protect your Personal Data from unauthorized access, modification, disclosure, or destruction. You can help keep your Personal Data secure by taking precautions. #### 9. Retention of Personal Data We retain your Personal Data for as long as is required to provide you with our Services and to fulfill the purposes described in this Privacy Policy. We carefully consider several factors when determining how long to retain your Personal Data, including legal obligations and contractual commitments. #### 10. Children’s Personal Data CLEAR does not direct its products, services, or websites at children under the age of majority. If we learn that we have collected Personal Data from a child under the age of majority without permission, we will delete it. #### 11. Your Privacy Rights and Choices At CLEAR, we respect your privacy rights and offer you the ability to exercise your privacy rights. Depending on where you live, you or your authorized agent may exercise the following rights: - **Right to Access / Know**: Access your Personal Data and receive confirmation whether we process your Personal Data and the categories of Personal Data we process. - **Right to Portability**: Receive your Personal Data in a portable format. - **Correction / Rectification**: Correct inaccurate Personal Data about you. - **Deletion / Erasure:** Request that we delete your Personal Data. - **Withdraw Consent**: Withdraw consent at any time. - **Object / Restrict / Opt-Out**: Opt-out or restrict processing of your Personal Data. - **Non-Discrimination**: We will not discriminate against you for exercising any of your privacy rights. #### 12. Privacy Policy Updates We may update this Privacy Policy from time to time to account for changes in how we collect, use, process, or share your Personal Data. We will indicate the date of our latest update. #### 13. How to Contact Us If you have any questions about this Privacy Policy, please contact us through our data protection officer at [privacy@clearme.com](mailto:privacy@clearme.com). #### 14. Notice to Users in Canada CLEAR and our third-party service providers may maintain and process your Personal Data outside your jurisdiction of residence, including outside the Province of Quebec. Personal information transferred to the U.S. will be subject to U.S. laws.