Website Privacy Policy

Introduction

     Clair Inc. ("Company" or “We" or “Clair”) is a company providing financial services to hourly workers including wage advances for free. Clair respects your privacy and is committed to protecting it through our compliance with this policy. This Website Privacy Policy, together with our Terms of Service, explains how the Clair Website (“Website”) collects, uses, discloses, and otherwise processes personal information or personal data when you download, access, or use the Website in connection with our products and services (collectively, the “Services”).

Scope

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, such as the EU General Data Protection Regulation 2016/679 (“GDPR”) or the California Consumer Privacy Act (Assembly Bill 375), as amended (“CCPA”). 

Clair is the data processor (under GDPR) or service provider (under CCPA) and users of the Clair Website are the data controllers (under GDPR) or businesses (under CCPA) with respect to 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-procsesors on its Website to assist in providing its Services, for example through the use of Zendesk Chat. Please visit our Processors/Sub-Processors of Customer Data page for more information.

Please note that residents of California are afforded certain rights regarding their personal information or personal data. In compliance with the CCPA, personal information or personal data differs from the definition above and 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 in connection with the Services is governed by this Website Privacy Policy and our agreements with each customer (in each case, a “Customer Agreement”). In the event of any conflict between this Website Privacy Policy and the corresponding Customer Agreement, the Customer Agreement will control to the extent permitted by applicable law. Please note that in certain instances, Clair may act as an independent controller or business of personal information or personal data with respect to its own processing activities. 

This Website Privacy Policy does not apply to any personal information or data collected by Clair on the Clair mobile application (“App”) or through other channels for marketing purposes. Our Mobile App, and other third parties have their own privacy policies, which we encourage you to read before providing information on or through them .

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 our Website. By accessing, registering, or using this Website, you agree to this privacy policy and consenting to the practices described in this policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Our Product Privacy Policy Explains:

  • Information We Collect About You
  • How We Use Your Information
  • How We Share Information
  • How We Retain and Protect Information
  • Accessing and Correcting Your Information
  • Persons Under the Age of 18
  • Cross-Border Data Transfer
  • Data Subject Rights under GDPR & Right to Request to Know or Request to Delete Under CCPA
  • Additional Information Regarding European Union, Swiss, and UK Personal Data
  • Additional Information Regarding Californian Personal Information
  • Changes to the Product Privacy Policy
  • Contact Us

Information We Collect About You

As a user of the Clair Website, you will be asked to provide us with the following categories of information:

CategoryExamples
A. Personal and Associated Identifiers.Name, email address, telephone number, company name, and number of employees in company.
F. Internet or other similar network activity.Information based upon your use of the Website including browsing history, search history, and information on a consumer's interaction with the Website.

We obtain the categories of personal information listed above from the following categories of sources:

  • Personal and Associated Identifiers: Directly from you. When registering for the Services, create an account, or from forms you complete.
  • Internet or other similar forms of network activity: Indirectly from you. Through the use of cookies and from observing your actions on our Website.

How We Use Your Information

Clair uses or discloses the personal information we collect for one or more of the following purposes: 

  • To provide, support, personalize, and develop our Website and Services;
  • To create, maintain, customize, and secure your account with us;
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud; 
  • To help maintain the safety, security, and integrity of our Website and Services, databases, and other technology assets, and business;
  • Enforce the terms and conditions that govern the Services; and other agreements, including for billing and collection purposes; and
  • For testing, research, analysis, and product development, including to develop and improve our Website, and Services.

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.

How We Share Information

We may share the information or data We collect, or you provide as described in this privacy policy: 

  • With Clair’s customers, only to the extent necessary as the information pertains to the customer’s end users; 
  • With Clair subsidiaries and corporate affiliates;
  • With service providers (including processors, sub-processors), and other third parties for a business purpose (i.e. to help us provide, manage, and improve our Services). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. 
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Clair, and/or that of you or others; and
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us  about our Website users is among the assets transferred.

How We Retention and Protect Information

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. 

Accessing and Correcting Your Information

You can review and change your personal information by logging into the App and visiting your account profile page

You may also send us an email at support@clairpay.com 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.

Persons Under the Age of 18

In compliance with the Children’s Online Privacy Protection (“COPPA”), our Website is not intended for persons under 18 years of age. No one under age 18 may provide any information to or on the Website. 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 this Website or on or through any of its features. 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:

902 Broadway, Floor 6

New York, NY, 10010

support@getclair.com

+18334625247 

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.

Cross-Border Data Transfer

Clair provides its Services primarily from the United States, where we are headquartered. In order 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. See the Customer Agreements for additional information regarding how Clair and its sub-processors safeguard the personal information they, respectively, transfer across borders.

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.

Additional Information regarding European Union, Swiss, and UK Personal Data

Clair’s legal bases for our processing of personal information is based on one or more of the following: 

Bases for ProcessingExplanation.
ConsentThe consent provided to us when an end user shared or submitted their personal information with or to us.
Legitimate InterestFor example, we may use your data for fraud and security monitoring to ensure our networks and Websites are secure, to administer or conduct our business (for example, record keeping and billing), and to respond to your inquiries and complaints.
Legal ObligationOur compliance with a legal obligation that we are or may be subject to.
ContractOur performance of the Customer Agreements.

Data Subject Rights under GDPR & Right to Request to Know or Request to Delete under CCPA

Clair customers are the data controllers/businesses of end users’ personal information or personal data. As the data controllers/businesses, Clair customers are responsible for receiving and responding to requests from end users and other individuals to exercise any rights afforded to them under applicable data protection law. Clair will assist customers in responding to such requests as set forth in the Customer Agreement.

Additional Information regarding Californian Personal Information 

Clair understands and will comply with the foregoing restrictions and the applicable requirements of the CCPA. For the purposes of the CCPA, Clair is a service provider. Clair does not receive any personal information, as defined by the CCPA, from its customers as consideration for the Services. Clair will not collect, retain, share or use personal information except as necessary to provide the Services. We do not, and will not, sell, as defined under CCPA, personal information.

Changes to This Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website. If we make material changes to this Website Privacy Statement, we will notify you in a manner that we believe will be reasonably likely to reach you (which may include email, a specific announcement on this page, our Website, or on our blog). The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Clair collects and uses your information described here, your choices and rights regarding such use, please do not hesitate to contact us at:

902 Broadway, Floor 6

New York, NY, 10010

support@getclair.com

+18334625247 

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