Reviewing the CLEAR privacy policy

I've seen the use of CLEAR pop up here and there, especially in airports.

When I learned they use biometric info, I was very apprehensive about using their services. Yesterday, I saw LinkedIn suggesting using CLEAR to get verified. And I thought, let’s see how they are doing with Customer Privacy. So naturally, I searched for Mozilla privacy reports but didn’t see any, so I planned to carve some time up and read their privacy document, which I did late last night.

The following is a summary of what I've learned.

BIG DISCLAIMER: #

I am not a legal expert in any form or shape. The following, at best, could be deemed as a privacy-concerned ignorant layperson report!#

1. CLEAR emphasizes securing data and protecting privacy. They promise never to sell or rent personal information.
2. Although they do not sell or rent personal information. They may share biometric data, health data, and other personal information with service providers, the U.S. Transportation Security Administration, airport authorities, and other government agencies if legally required.
3. They also share non-biometric and non-health personal information with their affiliates. This point is vague, and I hope this means any affiliate we explicitly consent to.
4. They collect various types of personal information, including contact details, business contacts, physical characteristics, government-issued identification info, digital images and videos, biometric data, travel information, device info, payment info, financial, demographic, location, health information, and more.
5. They use the collected information to facilitate the application and enrollment processes, operate and administer programs, verify identities, comply with legal requirements, communicate with consumers, offer products or services, and conduct data analysis.
6. They maintain administrative, technical, and physical safeguards to protect personal information. They use encryption, firewalls, and intrusion detection and prevention systems to safeguard sensitive information.
7. If you terminate your CLEAR membership, you can request the removal of any personal information they maintain about you. They will honor such requests unless they are legally obligated to keep a record of that transaction.
8. Their website is not directed to children; they do not knowingly collect personal information online from children under 13.
9. They may periodically update their Privacy Policy to reflect new program features or changes in personal information practices. It is also vague that, until we accept their new privacy policy, does the previous policy bind us or are we automatically assumed to accept the new privacy.
10. For California residents, they detail the categories of personal information they collect and how long they retain it.

If you have concerns about specific data handling practices or want to exercise your rights, you can contact them directly.

Thank you for reading this!