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Clair Inc and its affiliate(s) (together "Company" or “We" or “Clair”) facilitate the provision of financial services to hourly workers, including wage advances. Clair respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy explains and governs how the Clair collects, uses, discloses, and otherwise processes personal information or personal data when you download, access, or use the Clair Website or Mobile Application (“Clair Website and Mobile App”) to access Clair’s products and services (collectively, the “Services”).
Personal information or personal data refers to any data or information which relates to an identified or identifiable natural person, and are subject to applicable data protection laws, including the EU General Data Protection Regulation 2016/679 (“GDPR”) or the California Consumer Privacy Act (Assembly Bill 375), as amended (“CCPA”).
Clair is a data processor (under GDPR) or service provider (under CCPA) and users of the Clair Website and Mobile App are the data controllers (under GDPR) or businesses (under CCPA) for such personal data or personal information. Additionally, Clair may act as an independent controller or business of personal information or personal data with respect to its own processing activities. In certain instances, Clair uses third-party processors and sub-processors on the Clair Website and Mobile App to provide its Services, for example using Freshworks for customer support.
Residents of California are afforded certain rights regarding their personal information or personal data. Under the CCPA, personal information or personal data refers to “information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device.”
Clair’s processing of personal information for the Services using the Clair Website and Mobile App is governed by this Privacy Policy. Clair may act as an independent controller or business of personal information or personal data with respect to its own processing activities.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Clair Website and Mobile App.
As a user of the Clair Website and Mobile App, you will be asked to provide us with the following categories of information:
We obtain the categories of personal information listed above from the following categories of sources:
Clair uses or discloses the personal information we collect for the following purposes:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We may share the information or data we collect, or you provide as described in this Privacy Policy:
Clair retains personal information or personal data for as long as necessary to (a) provide the Services; (b) comply with legal obligations; and (c) resolve disputes. Clair uses appropriate, commercially reasonable physical, electronic, and procedural safeguards to protect personal information and data from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction in accordance with applicable law. We cannot, however, guarantee that any safeguards or security measures will be sufficient to prevent a security problem. We recommend that our customers take steps to protect against unauthorized access to any devices, networks and applications connected to the Services.
You can review and change your personal information by logging into the Clair Mobile App and visiting your account profile page.
You may also send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
In compliance with the Children’s Online Privacy Protection (“COPPA”), the Clair Website and Mobile App is not intended for persons under 18 years of age. No one under age 18 may provide any information to or on the Clair Website and Mobile App. We do not knowingly collect personal information or data from persons under 18. If you are under 18, do not use or provide any information or data on the Clair Website and Mobile App. If we learn we have collected or received personal information or data from a person under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us at:
P.O. Box 1791
New York, NY 10159
[email protected]
+1 (833) 462-5247
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.
Clair provides its Services primarily from the United States, where we are headquartered. To provide the Services, Clair or its sub-processors may transfer personal information or personal data about its end users outside of the country in which end users are located, including to the United States or to other jurisdictions that may not be subject to equivalent data protection laws.
When transferring personal information or personal data across borders we take steps reasonably necessary to ensure that the information or data is subject to appropriate safeguards, is treated securely and is transferred under an approved data transfer mechanism pursuant to applicable data protection laws.
Clair’s legal bases for our processing of personal information is based on one or more of the following:
Clair will not collect, retain, share or use personal information except as necessary to provide the Services. We do not sell, as defined under CCPA, personal information. As the data controller, Clair is responsible for responding to your request to exercise any right afforded you under applicable data protection law, including the GDPR and the CCPA.
Clair may change this Privacy Policy from time to time by publishing a revised Privacy Policy on the Clair Website and Mobile App. Your continued use of the Clair Website and Mobile App after we make changes is deemed to be acceptance of those changes.
If you have any questions or comments about this Privacy Policy, please do not hesitate to contact us at:
P.O. Box 1791
New York, NY 10159
[email protected]
+1 (833) 462-5247
We'd love to talk. Submit your contact information below, and we'll reach out to show you how Clair can help your business offer on-demand pay.
