PRIVACY POLICY

Last Updated: [ 1/27/2021]

If you are located in the European Economic Area (EEA), please visit our Privacy Policy for EEA Residents instead.

If you are located in the United States or any other country that is not a member of the EEA, this privacy policy (the “Policy”) applies to your visit to our websites at allclearid.com (the “Site”); your subscription to any of our services and the provision of the respective services (collectively, the “Services”); and any other means of communication between you and AllClear ID, Inc.

The Policy explains the categories of personal information that we collect, the sources we collect it from, the purposes we collect it for, and the third parties we share it with, as well as your rights to be informed and to request deletion. We also explain how we use cookies, and the security practices we use to keep your information safe.

Information Collected

We collect Personal Information through the Site when you access the Site and/or register for Services. “Personal Information” is information that can be used, whether alone or in combination with other information, to identify you as an individual.

If you are under the age of 13, you are not allowed to use the Site, or to use any of our Services (except insofar as your custodial parent or legal guardian has enrolled you in Services we have designed for minors, and accesses them on your behalf). We do not knowingly solicit any Personal Information from children under the age of 13. If we are made aware that we have collected Personal Information from a child under 13 years old in a manner that is inconsistent with the Children’s Online Privacy Protection Act of the United States, then we will delete this Personal Information as soon as practicable.

In order to improve the user experience of this Site and to deliver our Services, we have collected the following categories of Personal Information about consumers in the preceding 12 months, and may collect these categories of Personal Information about you and/or your family member going forward in accordance with this Policy:

Personal Information that you actively provide to us

For these categories of Personal Information, you always make an active choice whether or not to provide the information requested, every time it is transmitted to us. These categories of Personal Information are not collected in an automated way from your device or provided to us by a third party. However, if you choose not to provide Personal Information that we request in these categories, there may be certain features of the Services or Site that you may not be able to register for or use, or that we cannot provide without the requested Personal Information.

·Registration Information

You provide Registration Information when registering for our Services through the Site or on the phone. When registering for Services, the Personal Information you are requested to submit may include key identifying details such as your full name, residential address, Social Security number, gender, and date of birth; and contact details such as your telephone number and e-mail address. You may also be provided with or create a user name (account ID) for the Site that may be used to personally identify you when logging into the Site. If you are enrolling in monitoring of one or more payment cards, you may be asked to provide the payment account number(s) of the payment card(s) you wish to enroll.

·Minor Child’s Registration Information

You provide Minor Child’s Registration Information when enrolling your child in Services for minor children. For example, as a legal guardian, you may be requested to submit the child’s full name, Social Security number, gender, and date of birth in order to enroll that child in identity theft monitoring.

·Payment Information

When you register for Services that require enrollment and payment through the Site or on the phone, we may collect your credit card number or other payment account number, billing address, and other information related to the transaction (collectively, “Payment Information”) from you if our Services are being purchased by you and not by a Sponsor Company on your behalf. Our payment Service Provider(s) may also collect the Payment Information from you directly (through forms embedded in the Site that directly access the payment processor’s service) and store Payment Information for recurring billing where required for continued provision of our Services as requested by you.

·Investigative Background Information

You provide us investigative background information (“Investigative Background Information”) in order for us to provide investigative Services to you, including investigating fraud or identity theft claims on your behalf. Under certain circumstances (for example, if your health insurance provider has suffered a data breach) this may include information that may be considered Protected Health Information (PHI) under the US Health Insurance Portability and Accountability Act (HIPAA), such as medical record numbers or health plan beneficiary numbers. Other types of information requested as Investigative Background Information may include employment-related information, such as the name of your employer; and information about your financial transaction history, such as whether you authorized certain financial transactions conducted in your name. From time to time, we may request other types of Personal Information as Investigative Background Information if we reasonably believe that it is required in order to complete an investigation that you have requested. You always have the right to decline to provide Investigative Background Information that we request, without affecting your continued enrollment in our Services, but we may be unable to resolve an investigation that you have requested if you choose not to provide Investigative Background Information that we need to resolve an investigation.

·Other Personal Details

In addition to providing Registration Information, we may ask visitors to the Site to voluntarily input other Personal Information from time to time. For example, when you visit the Site, we may ask you to provide information about yourself for marketing purposes, such as your name, email address, employer, and country location. If as a Site visitor you provide elements of Personal Information for marketing purposes that are the same data you provide separately as Registration Information (for example, your name and email address), we will maintain records of these Other Personal Details separately from your Registration Information. You can request that we delete or stop using these Other Personal Details without affecting your Registration Information or use of our Services.

Personal Information that we receive about you from third parties

These categories of Personal Information include: details that we receive about you from third parties, in accordance with their own privacy policies and legal obligations, who wish to sponsor your use of our Services (“Sponsor Companies”); and details that we receive from third parties in order provide Services to you at your request.

·Monitoring Contact Details

When your use of our Services is sponsored by a Sponsor Company, they may provide us with your contact details and a unique identifier. We may use these contact details to deliver eligibility notifications to you, and to notify you of how you may access the relevant Services at the Sponsor Company’s expense.

·Identity Theft Monitoring Events and Alerts

If you enroll in our Services and opt into identity theft monitoring services for your or your child, we may obtain events and alerts related to the Registration Information or Minor Child’s Registration Information you provided, for the purpose of notifying you about related events and alerts. We receive this type of Personal Information from Service Providers who specialize in data breach and credit monitoring.

·Credit Monitoring and Fraud Alerts

If you enroll in our Services and opt in to credit monitoring, we may obtain events and alerts related to your credit file, or related to other Registration Information you provided, for the purpose of notifying you about them. We receive this type of Personal Information from Service Providers who specialize in credit monitoring.

·Third-Party Investigations Responses

When we provide Services to you, in the course of conducting investigations that you have authorized us to conduct into possible fraud or identity theft, at your request we may contact third parties, such as consumer reporting companies that provide credit reports. In these cases, we may receive Personal Information about you from these third parties in accordance with their own privacy policies and legal obligations. We will use such Personal Information only for the purposes of providing our Services to you.

Personal Information that we collect or assign automatically based on your device

These categories of Personal Information are collected through automated means when you visit the Site, including through the assignment of unique personal identifiers such as cookies and Pixel Tags. Most websites automatically collect these types of information. Pixel Tags also collect Personal Information relating to emails that we send you, such as whether an email we sent to your email address was opened.

·IP Addresses

Your Internet Protocol (IP) address is a number that is automatically assigned by your Internet Service Provider (ISP) to the device that you are using. This number is identified and logged automatically in our server log files whenever you visit the Site.

·Browsing Activity

We collect information about which pages you visit on the Site and the activities you undertake while visiting these pages. This information is automatically collected in our server log files, in association with your IP address and Device Fingerprint, whenever you visit the Site.

·Device Fingerprint

We collect information about the device you use to access the Site, such as model and manufacturer, type and version of operating system, screen resolution, type of Internet browser, and Internet browser version. This information is automatically collected in our server log files, in association with your IP address and browsing activity, whenever you visit the Site.

·Cookies and Similar Technologies

We use cookies or similar technologies on the Site to recognize you, your browsers, and/or your device(s). Please visit the Cookie Notice section below for additional details, including information about how you can set preferences governing our collection of Personal Information using cookies and similar technologies.

·Pixel Tags

We may also use so-called pixel tags, web beacons, clear GIFs, or similar means (collectively, “Pixel Tags”) in connection with some Site pages and HTML-formatted email messages to, for example, compile aggregate statistics about Site usage and response rates. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver branded Services, to provide online advertising, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can tell the sender whether and when the email has been opened.

Please note that, for the categories of Personal Information in this section (that is, Personal Information that we collect automatically), only the Cookies and Similar Technologies category can be affected by preferences that you set. We always collect the categories of Personal Information in this section for our business purposes, including preventing malicious misuse of the Site, whenever a user visits the Site. If you do not want us to collect these categories of Personal Information, please do not use the Site.

Cookie Notice

Cookies are small files placed onto a device that can facilitate your ongoing access to and use of a particular service, for example by holding your access token to the secure areas of a service. In addition, we use cookies to collect statistics about your visits to our Site and for performance, analytics, and research purposes. Our Site also uses cookies from third parties (such as Google Analytics and Salesforce) that may be used to personalize content and target advertisements or marketing material to you or your preferences, to provide social media features, and to analyze our website traffic. (Please note that within the subdomain my.allclearid.com, which is our portal that subscribers enrolled in the Services may log in to with their assigned credentials, we do not use cookies for advertisement personalization or targeting. This means that your activity within the consumer portal my.allclearid.com will not affect what advertisements you see, or expose Personal Information about you to us or to third parties that may be used for marketing and advertising purposes.)

The Site does not respond to “do not track” signals from browsers. Thus, your selection of the “do not track” option provided by your browser may not prevent our collection of cookie information.

The following button will take you to our cookie preference center, where you can obtain additional information on the different types of cookies used by the Site, as well as edit and save your preferences for their use:

Information Use

Please note that we do not and will not ever sell your Personal Information.

We may use Personal Information we collect for the following purposes:

·Fulfillment of Your Requests

We may use Personal Information collected about you to provide you with Services or information that you request. We may use Personal Information, including Payment Information, in order to fulfill your purchase. In order to serve you better, we may contact you by email and/or telephone to provide identity theft monitoring alerts, to respond to your inquiries, to authenticate requests, or to otherwise deliver Services that you have registered to receive from us.

·Identity Theft Monitoring Notifications

We may use Personal Information provided by you, or about you by third parties, in order to notify you of data breaches or similar security events that may have affected the security of your Personal Information.

·Credit Monitoring and Fraud Alerts

We may use Personal Information provided by you, or about you by third parties, in order to notify you of events and alerts related to changes on credit file(s) with consumer reporting agencies.

·Sponsor Company Offers

At no charge to you, we may use Personal Information provided to us about you by Sponsor Companies in order to offer you our Services paid for by a Sponsor Company.

·Administrative Communications

From time to time we may use Personal Information to communicate with you about important information regarding your account, our Services, the Site, or changes to our terms, conditions, and policies. These communications may include a series of welcome, verification, and informational emails that are part of the activation process and that help to inform new users about features of our Services. Please be aware that, as long as you are a subscriber to an AllClear ID Service, you will receive certain emails related to the proper functioning of your account. We may use your Registration Information to communicate with you regarding the status and administration of your account, and other important information.

·Site Administration

We use IP Addresses, as well as Browsing Activity and Device Fingerprint information, for purposes such as calculating Site usage levels, helping diagnose problems with the Site’s servers, administering the Site, enhancing and optimizing your Site experience, and preventing malicious misuse of the Site.

·Marketing and Advertising

We use Personal Information to learn about the characteristics of people who use our Site and our Services, to measure the effectiveness of our electronic communications on the Site and via emails, and to personalize content and target advertisements based on relevant user characteristics. We may send you marketing information about our Services, during and after any term for which you are subscribed for one of our Services. If you would prefer that we not send such email messages to you, please follow the instructions in the email to unsubscribe, or request deletion of your data in accordance with the Your Data, Your Rights section of this Policy. We will not send you marketing information about products or services of other companies.

·Fulfillment of Legal Obligations

We will disclose Personal Information in an appropriate, proportional manner to third parties in order to comply with legal processes of competent jurisdictions, and to respond to valid requests by government entities exercising their statutory authorities. In the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including, without limitation, in connection with any bankruptcy or similar proceedings), transfer of Personal Information to a third party may be required in order to fulfill our legal obligations.

·Remedies and Damage Limitation

We will disclose Personal Information in an appropriate, proportional manner to third parties when reasonably necessary to protect our, your, or other persons’ rights, privacy, safety, or property; to permit us to pursue available legal remedies or limit damages that we may sustain; or to enforce our Terms of Use.

Information Sharing

AllClear ID takes the privacy of our users very seriously and may disclose Personal Information that we collect about you only for the purposes described in this Policy. We do not and will never sell or rent your Personal Information to any third parties, or otherwise allow third parties to use your Personal Information for their marketing purposes.

AllClear ID may disclose Personal Information about you to the following categories of recipients:

·Service Providers

We work with companies that have contractual agreements with us to provide us services (collectively, “Service Providers”), including without limitation, CSIdentity Corporation (aka Experian Partner Solutions) and ConsumerInfo.com, Inc. (aka Experian Consumer Services) and its respective affiliates (collectively, “Experian”) subject to legal obligations to protect any Personal Information disclosed to them to, at a minimum, the same standards that we agree with you in this Policy. We may disclose Personal Information to Service Providers, including Experian, for the purpose of enabling them to provide services to us and, by extension, you, and making offers for, and otherwise fulfilling, opportunities from AllClear ID and Experian to purchase additional services, or move or upgrade to a new identity repair and protection service from AllClear ID and Experian (such additional purchased services, collectively, “Continuation Services”). For clarity, any extension of the subscription term for sponsored services shall not be deemed Continuation Services hereunder. Services provided to us by these Service Providers include, but are not limited to, email list management services, certain product functionalities, customer support, web hosting, customer data management and enhancement, fulfillment services (e.g., companies that fill product orders or coordinate mailings), research and surveys, data analysis, email service, and making offers for, and otherwise fulfilling, any Continuation Service(s), including (i) opportunities to enroll in any Continuation Service(s) sent via email by Experian, either on its own behalf or on behalf of AllClear ID or (ii) fulfilling your enrollment in any Continuation Service(s) offered by AllClear ID and/or Experian. You may opt out of receiving email offers for Continuation Services at any time by selecting “unsubscribe” within any such email. If we collect Payment Information from you, we may share it with our payment Service Provider(s) for processing of charges, and they may in turn share your Payment Information with card networks and your card issuer in order to execute processes related to those charges (such as authorization and settlement).

·Investigative Contacts

We may provide non-affiliated third parties – such as insurance companies, creditors, healthcare providers, or law enforcement personnel – with Personal Information that you disclose to us (in some cases, including Protected Health Information) to the extent necessary for Fulfillment of Your Requests, including for the purpose of investigating identity theft, fraud, or incorrect usage of your name, identity, or other data. We will not provide more Personal Information to Investigative Contacts than is necessary to fulfill your requests for Services.

·Obligatory Recipients

We will disclose Personal Information in an appropriate, proportional manner to third parties in order to comply with legal processes of competent jurisdiction, and to respond to valid requests by government entities exercising their statutory authorities.

·Recipients of Limited Disclosures

We will disclose Personal Information in an appropriate, limited, proportional manner to third parties when reasonably necessary to protect our, your, or other persons’ rights, privacy, safety, or property; to permit us to pursue available legal remedies or limit damages that we may sustain; or to enforce our Terms of Use.

·Successors and Assigns

We reserve the right to transfer Personal Information to a third-party successor entity or assignee in furtherance of the Fulfillment of Legal Obligations in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including, without limitation, in connection with any bankruptcy or similar proceedings).

Your Data, Your Rights

Right to Know

You have the right to request that we inform you what Personal Information of yours we collect, use, and disclose, including whether we sell your Personal Information. (We never sell Personal Information to anyone.)

You can request a copy of specific pieces of Personal Information we have collected about you, as well as any or all of the following:

-Categories of Personal Information that we have collected about you

-Categories of sources from which we have collected your Personal Information

-Categories of your Personal Information that we have sold or disclosed for a business purpose

-Categories of third parties to whom we have sold or disclosed your Personal Information

-The business or commercial purposes for collecting or selling your Personal Information.

Please see the Contacting Us and Submitting Requests section below for details on how to make a Right to Know request.

Right to Request Deletion

You have the right to request that we delete Personal Information of yours that we collect or maintain.

Please see the Contacting Us and Submitting Requests section below for details on how to make a deletion request.

Once we have received a deletion request, we must verify that the request is actually authorized by you before we can fulfill your request. (See the Contacting Us and Submitting Requests section for more details).

Please note that sometimes legal obligations prevent us from deleting Personal Information in response to authenticated requests. Should this occur, we will honor your request to the extent that we are legally able, and explain to you what deletions we cannot undertake and why.

When deleted, Personal Information will be destroyed using one or more of the following methods, depending on which media has been used to store the data:

-Shredding of paper copies or physical media

-Degaussing of magnetic physical media

-Overwriting, block erasing, and/or or cryptographically erasing data on electronic media

-Overwriting or otherwise permanently rendering inaccessible records stored in electronic databases.

Accessing and Changing Personal Information on Your Account

If you have enrolled in our Services, you can log in at any time to review your Registration Information and, unless otherwise indicated, edit it; or change the settings for your AllClear ID account. You can do so by logging into your account on the Site and editing the information on your Profile page.

Contacting Us and Submitting Requests

You can contact us through the following methods:

E-mail

support@allclearid.com

Phone

1-855-434-8077

Mail

AllClear ID, Inc., 816 Congress Avenue, Suite 1800, Austin, Texas 78701, Attn. Legal Department

Submitting Right to Know or Deletion Requests

To submit a Right to Know or a deletion request, please use one of the methods described above.

Once we have received such a request, we will use information we have on file for you to verify that the request has actually been authorized by you. Depending on the nature of your request and the information in question, you may need to provide additional information to authenticate the request before we will be able fulfill your request by releasing the relevant records to you or deleting them, as applicable. In particular:

·For requests submitted by phone, we will ask you for Personal Information that you previously provided to us or we previously received from third parties about you, commensurate with the sensitivity of your request.

·For requests sent by e-mail or by letter mail, we will attempt to contact you at the phone number(s) you have previously provided to us and then proceed as above to verify your identity.

·For requests that can be serviced through your online account with us, a successful login into the account will serve as verification of your identity.

·For requests that are limited to Other Personal Details, such as for deletion of your e-mail address used for Marketing and Advertising, we may instead rely on a confirmation that you are in control of the e-mail account that the request pertains to.

For your security, we will at no time disclose your Social Security number, driver’s license number or other government-identified identification number, financial account numbers, any health insurance or medical identification number, account passwords, or security questions and answer to you in response to a Right to Know request. We may also withhold other pieces of Personal Information if we determine that the disclosure would create a substantial, articulable, and unreasonable risk to the security of that information, your account with us, or the security of our systems or networks.

Security

We use a wide range of advanced technologies for Internet and secure interactive voice security, including multi-band, multi-factor authentication; encryption of data transmitted via public networks; and encryption of stored data.

When you attempt to access secure areas of the Site or sign into the Services, we will authenticate your identity.

We protect your information over the Internet by using a secure web server, which allows your browser to interact with our web server via an encrypted session.

For access to the Site, we use a Transport Layer Security (TLS) connection that provides an encrypted connection between your computer and our server. The encrypted connection scrambles ordinary text or data into ciphertext to safeguard your information as it is transmitted over the Internet. The information is decrypted, or put back into a readable format, when it reaches its intended destination.

Certain Personal Information we collect is stored encrypted. In addition, the Site and the Services are hosted in an environment that employs firewall and other advanced technology designed to prevent interference or access from outside intruders, as well as unauthorized insiders.

Notwithstanding the foregoing, there is always some element of risk involved in sending Personal Information online. You acknowledge that, in connection with the Site and our Services, information is being transmitted over local exchange, interexchange, and Internet backbone carrier lines and through routers, switches, and other devices owned, maintained, and serviced by third-party local exchange and long-distance carriers, utilities, ISPs, and others, all of which are beyond our control and jurisdiction. Accordingly, we assume no liability for or relating to the delay, failure, interruption, or corruption of any data or other information transmitted in connection with the Site and our Services. We further make no warranty and assume no liability regarding the availability, reliability, or suitability of any ISP or digital subscriber line services.

We make no warranties as to the security of users’ data communications, or that third parties will not gain unauthorized access to or monitor users’ computer(s) or online communications. You agree that we will not be liable for any such unauthorized access.

We are not responsible for the content or privacy practices on any website not operated by AllClear ID. Certain businesses not affiliated with us may display the AllClear ID logo and offer access to our Services. You should not construe such use, in any respect, as our endorsement or guarantee of the security practices of those businesses.

Linking

The Site may contain links to third-party websites. These linked websites are not under our control and we are not responsible for the privacy practices or the contents of any such linked website, or any link contained in any linked website. We provide links only as a convenience, and the inclusion of a link on the Site does not imply endorsement by us of the linked website. If you provide any Personal Information through a third-party website, your transaction will occur on the third party’s website (not the Site) and the Personal Information you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any third parties.

Non-US Individuals

If you are visiting this Site from a region outside the US or EEA with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information you consent to any transfer and processing in accordance with this Privacy Policy.

Updates to the Privacy Policy

This Policy supersedes any earlier version. We may change this Privacy Policy and, when we do, will post the Last Updated date so that you will always be aware of what information we collect, use, and disclose.

We encourage you to review this Privacy Policy from time to time. If, after reviewing this policy, you have any questions or concerns, please contact us.