Online Privacy & HIPAA Policy
At CLEAR TECHNOLOGIES LLC (“CLEAR”), we understand the importance of protecting your personal information. We are committed to processing your information responsibly and in compliance with all applicable data protection laws in all countries that may use our websites.
Why and How We Collect and Use Your Personal Information
Access and use of websites or other online services: When entering a CLEAR website or using an online service, we will record the information necessary to provide you with access to the operation of our sites, such as passwords, IP addresses, and browser settings. We also collect information about your activities during your visit to personalize your preferences and settings, and to collect statistics to help us improve and further develop our website, products, and services.
Responding to requests for information or support: When you contact CLEAR (online or offline) to access support, order tests, request information, or other communication, we collect the necessary information to assist you. For example, we may collect your name and contact information, the type of services needed, information for purposes of invoicing or payment, and may include other client information. We retain this information for administrative purposes and to reinforce our relationship with you.
When you provide your name and contact information to register in connection with such a request, the registration may serve to identify you when you visit our websites.
For accessing results or ordering tests, we require you to register with your email, your mobile number, and a password.
Your use of CLEAR websites and services: CLEAR collects information about your use of CLEAR services and our website in order to improve your user experience, tailor our interactions/marketing practices, inform our clients on the overall use of CLEAR services, provide support, and improve/develop our services. For details regarding the personal information we collect, the technologies we use, and how to control or block tracking, or delete cookies, please refer to the sections below.
Contacting the employees of our clients, prospects, vendors, and partners: In our relationship with clients, prospects, vendors, and partners, we maintain business contact information (i.e., name, business name, contact information, position/title, authorized users) for purposes such as contract fulfillment, support, invoicing, and management of services. If you are an employee of a CLEAR partner or customer, information may be shared with your employer or contractor, so long as you have consented to such authorized use.
PASS Participation Agreement:
Visitor information: CLEAR registers visitors to CLEAR’s laboratory, offices, and businesses. We gather business contact information and use camera supervision for the purposes of security and safety, as well as regulatory purposes. Any stored audio or video is the exclusive property of CLEAR.
Marketing: We collect marketing data based on direct interactions with you. For example, if you register for an event, we may collect information (online or offline) in relation to the event organizers and during the event, such as participation in sessions and survey results. We combine the personal information we collect to develop aggregate analysis and business intelligence for conducting business and marketing purposes. You can choose to receive information about our services by email, telephone, mail, or sign-up for subscriptions. When visiting our website or using our services, we may provide you with personalized information. You can always opt-out of receiving personalized communication by sending an email to email@example.com or by clicking on Unsubscribe on the footer of emails you receive from CLEAR.
When CLEAR uses your personal information in relation to marketing, improvement, or development of our products and/or services for reasons of safety, security, or regulatory requirements other than in connection with your agreement or request, we do so based on legitimate interests or with your consent.
You do not have to disclose any information to visit any CLEAR site. However, while browsing our sites, you may find your needs can be better accessed by disclosing some information. The information you provide will not be sold, traded, or leased to any other organization outside of CLEAR unless you have agreed to such use. You will have the opportunity to accept the storage of cookies in your browser when visiting a CLEAR website.
We may use demographic information that does not personally identify you and/or information you voluntarily provide to improve the features of the site or for general statistical purposes. In certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceedings, court order, or legal process. We may also share your personal information to protect the rights or property of CLEAR and our clients, patients, business partners, vendors, or employees when we have reasonable grounds to believe that such rights or property have been or could be affected.
Information Automatically Collected and Stored
As with other sites you may visit on the internet, CLEAR does collect certain system information from its users. CLEAR websites automatically store the following information during your visit:
Internet location (IP address)
Date and time of visit
A device used to access our site (i.e., mobile, desktop, tablet)
Traffic to and from our site
Referral URLs (i.e., Google search, publication/news article, or partner site)
The information collected is not associated with your name or any other information you voluntarily provide. This information is stored and used for statistical purposes that allow us to improve the quality of this site, and meet the needs of our users.
As stated above, we collect your computer’s IP address during your visit. An IP address is a number automatically assigned to your computer that allows computers and servers to recognize and communicate with each other. We use IP addresses to determine the geographic characteristics of our users and to allow internal users to view internal pages. Analyzing geographical information allows us to make our site more accessible to users.
Cookies are text files that a website transfers to memory to record certain information about your visit. Some CLEAR sites place cookies in the browser files of your computer to provide you with tailored information. You can choose not to download cookies, to disable cookies, or delete cookies.
This website uses Google Analytics, a web analytics service provided by Google.
Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.
CLEAR uses JivoChat online chat, a real-time customer support option. This solution provides website users with an option to connect directly with CLEAR Client Services through a web-based text chat. During this secure, online chat, your information will be entered into CLEAR’s customer relations management system (CRM) to record your interaction with CLEAR as part of your client record. During a chat session, CLEAR may ask for personal information in order to validate your identity and provide information about an appointment, test results, and other information you may be inquiring about.
CLEAR will not retain personal information longer than necessary to fulfill the purposes for which it is processed, including complying with legal and regulatory obligations (i.e., audit, accounting, statutory retention terms), disputes, and for the establishment, excise, and/or defense of legal claims.
Because the circumstances may vary depending on the context and the services, the information provided in our Online Privacy Statement or provided in a specific notice may provide detailed information on applicable retention terms.
CLEAR uses a variety of information security measures to protect your online transactions with us. CLEAR sites use encryption technology, such as Secure Sockets Layer (SSL), to protect your personal information during data transport. SSL protects information you submit via our website (e.g., ordering information, including your name, company name, payment information, email, and others). We have taken reasonable steps to ensure the integrity and confidentiality of personally identifiable information that you may provide. You should understand, however, that electronic transmissions via the internet are not necessarily secure from interception, so we cannot absolutely guarantee the security or confidentiality of such transmissions.
We are committed to protecting children’s privacy on the internet, and we do not knowingly collect personal information from children.
Links to Other Websites
All information contained on this website is copyright protected unless otherwise noted. All images, text, and information shall be protected information owned, licensed, or shared by and with the CLEAR. Information may be reprinted and/or downloaded for personal use only. Permission to reprint or electronically reproduce any document or graphic in whole or in part for non-personal or commercial use is prohibited unless prior written consent is obtained from the respective copyright holder(s).
By using this site, you agree that you understand and accept the terms listed above. If you do not agree to these terms, you may not use this site. Privacy, as it applies to the internet, is a rapidly developing area. We reserve the right to change our privacy practices from time to time and will include any changes on this site.
Questions or Comments Relating to Privacy
If you have additional questions and/or comments, email firstname.lastname@example.org.
We have a long-standing commitment to protecting the privacy rights of our clients. In keeping with this commitment, and as required by law, we:
May obtain your consent to use and disclose records about your health and healthcare.
We are required to maintain the privacy and security of your protected health information and restrict disclosure only to those individuals or entities you have authorized;
We must follow the duties and privacy practices described in this notice and give you a copy of it;
We will not use or share your information other than as described here unless you tell us we can in writing, or otherwise required by law, judicial decree, or legal authority.. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind; and
We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
How we may use and disclose health information
When you initially register to receive services or treatment at a CLEAR location or authorized partner, you will be asked to sign an acknowledgment of this notice that describes how we use and disclose information about you in ways that are permitted by federal law. Federal law provides for significant privacy protections of health information.
The following categories describe ways that we may use and disclose health information that identifies you. Some of the categories include examples, but not every type of use or disclosure of health information in a category is listed.
Except for the purposes described below, we will use and disclose health information only with additional written permission from you. If you give us permission to use or disclose health information for a purpose not discussed in this notice, you may revoke that permission at any time by sending a written request to our Privacy Officer (or their authorized designee) at the address listed at the end of this notice.
Protected Health Information may also be disclosed to the Secretary of the Department of Health and Human Services for the purpose of investigating or determining the covered entity’s compliance with the HIPAA Privacy Rule.
a) For Treatment. We may use health information to treat you or provide you with healthcare services. We may disclose health information to doctors, nurses, technicians or other personnel, including people or companies outside of the CLEAR team, who may be involved in your medical care. For example, upon providing consent we may exchange health information with other healthcare providers like your primary care physician regarding the care we provided you, a specialist so they can provide you with additional services, or your pharmacy about the medicines you are taking or are prescribed.
b) For Payment. We may use and disclose health information so that we or others may bill or receive payment from you, an insurance company, or a third party for the treatment and services you receive. For example, we may give your health plan information about your treatment so they will pay for such treatment. We also may tell your health plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment.
c) For Healthcare Operations. We may use and disclose health information for healthcare operations and administrative purposes. These uses and disclosures are necessary to make sure all our patients receive quality care and for operation and management purposes. For example, we may use health information to review the treatment and services we provide to ensure the care you receive is of the highest quality, or we may post in employee areas thank-you notes or pictures you send us.
d) Appointment Reminders, Treatment Alternatives, and Health-related Benefits and Services. We may use and disclose health information to contact you as a reminder that you have an appointment with us. We may use and disclose health information to tell you about treatment options or alternatives or health-related benefits and services that may be of interest to you. We also may make your health information available for you to access through a secure online patient portal.
e) Internal Employees. We may list your name, general condition (e.g., fair, critical), and location in our directory for use by internal CLEAR employees.
f) Individuals Involved in Your Care or Payment for Your Care. We may disclose health information to a person, such as a family member or friend, who is involved in your medical care or who helps pay for your care. We also may notify your family about your location or general condition or disclose such information to a family member, relative, close personal friend, or any other person identified by you who may be involved in your care or payment related to your healthcare, or for notification purposes. We may also disclose health information to a personal representative. A personal representative is generally a person who has the legal authority to act on your behalf in making decisions related to your healthcare.
g) Research. Under certain circumstances, we may use and disclose health information for research purposes. For example, a research project may involve comparing the health and recovery of all patients who received one medication or treatment to those who received another, for the same condition. In addition, we may use your data for health services research to improve the health of our patients and the communities we serve. However, before we use or disclose health information for research, the project will go through a special approval process. This process evaluates a proposed research project and its use of health information to balance the benefits of research with the need for privacy of health information. Even without special approval, we may permit researchers to look at records to help them identify patients who may be included in their research project or for other similar purposes, as long as they do not remove or take a copy of any health information with them. If you are eligible for participation in a study, we may contact you to discuss your potential participation. In the unfortunate event of your death, we may use or disclose your health information to people who are conducting research using the information of deceased persons. In addition, we may use de-identified patient information and test results or test samples in clinical trials conducted by us or other third parties.
h) We may also share your information with the CLEAR and affiliated entities as is required in the following special circumstances:
a) As Required by Law. We will disclose health information when required to do so by international, federal, state, or local law.
b) To Avert a Serious Threat to Health or Safety. We may use and disclose health information when necessary to prevent or lessen a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, will be to someone who may be able to help prevent the threat.
c) Business Associates. We may disclose health information to our business associates who perform functions on our behalf or provide us with services if the information is necessary for such functions or services. For example, we may use another company to perform billing services on our behalf. All of our business associates are obligated by law and under contract with us, to protect the privacy of your information and are not allowed to use or disclose any information other than as specified in our contract.
e) HIV Test Results. If you received an HIV test and did not give us permission to use and disclose the results, we will use and disclose the results of HIV tests that identify you only: (1) to provide you with healthcare services (for example, we may tell a specialist about your HIV status so the specialist can treat you); (2) when compiling or reviewing your records as part of routine billing; (3) if necessary, to enable us to protect the quality of our services (for example, we may disclose HIV test results to our committees to monitor and evaluate our programs); (4) to childplacing or child-care agencies, family foster homes, residential facilities or community-based care programs that are directly involved in placement, care, control or custody and that have a need to know such information; (5) to sex- or needle-sharing partner in accordance with the law; (6) in accordance with a court order that specifically requires us to release HIV test results; and (7) in connection with organ donation.
g) Workers’ Compensation. We may disclose health information for workers’ compensation or similar programs that provide benefits for work-related injuries or illnesses.
h) Public Health Risks. We may disclose health information for public health activities. These activities generally include disclosures to prevent or control disease, injury, or disability; report births and deaths; reporting child abuse or neglect; report reactions to medications or problems with products; notifying people of recalls of products they may be using; tracking certain products and monitor their use and effectiveness; notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition; and conduct medical surveillance of our facilities in certain limited circumstances concerning workplace illness or injury. We also may release health information to an appropriate government authority if we believe a patient has been the victim of abuse, neglect, or domestic violence; however, we will release this information only if you agree or when we are required or authorized by law.
h) Health Oversight Activities. We may disclose health information to a health oversight agency for activities authorized by law. For example, these oversight activities include audits, investigations, inspections, and licensure as well as quarterly reports to the Agency for Healthcare Administration. These activities are necessary for the government to monitor the healthcare system, government programs, and compliance with civil rights laws.
i) Lawsuits and Disputes. If you are involved in a lawsuit or a dispute, we may disclose health information in response to a court or administrative order. We also may disclose health information in response to a subpoena, discovery request, or other lawful processes by someone else involved in the dispute, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.
j) Law Enforcement. We may release health information if asked by a law enforcement official for the following reasons: (1) in response to a court order, subpoena, warrant, summons, or similar process; (2) limited information to identify or locate a suspect, fugitive, material witness or missing person; (3) about the victim of a crime if, under certain limited circumstances, we are unable to obtain the person’s agreement; (4) about a death we believe may be the result of criminal conduct; (5) about criminal conduct on our premises; and (6) in emergency circumstances to report a crime, the location of the crime or victims, or the identity, description or location of the person who committed the crime.
k) National Security and Intelligence Activities. We may release health information to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.
PASS Participation Agreement and Disclosure
By seeking services and entering into a relationship with CLEAR, you authorize us to share your health information with third parties with which we have a business associate relationship, and specifically with PASS, pursuant to an existing participation agreement between CLEAR and PASS. As a PASS-certified partner, CLEAR requires your authorization to provide testing information, results, and data obtained from you to PASS. To review the privacy policies as it relates to PASS, you may click here.
Your participation in receiving services and testing from CLEAR will allow us to communicate results with PASS and other participating business associates. The following rules will be steadfastly followed in order to ensure your privacy to the greatest extent possible.
Identifying information about yourself with reactive test results is never to be shared without their explicit consent to do so.
When necessary to indicate a participant with an active test result, you will only be referred to as “Participant X,” and all referent pronouns will be gender neutral.
No identifying information regarding potential exposures is to be shared with anyone other than what is necessary to ensure that any potential risk to the participant pool is identified and contained.
Regarding production holds; incident documentation with identifying information will be kept on a secure server (if digital) or locked file cabinet (if printed) accessible only by PASS staff.
Uses and Disclosures with Your Authorization
CLEAR cannot use your protected health information for anything other than the reasons mentioned above without your signed authorization: a written document signed by you giving us permission to use or disclose your protected health information for the purposes you specifically set forth. You may revoke your authorization at any time by delivering a written statement to CLEAR’s Privacy Officer (identified below). If you revoke your authorization, CLEAR will no longer use or disclose your protected health information as previously permitted in your written authorization document. However, your revocation of the authorization will not reverse the use or disclosure of your protected health information made while your authorization was in effect.
Your Individual Rights
Right to request your protected health information: You have the right to access your protected health information (laboratory testing). You must make the request for such protected health information by emailing email@example.com. A Consent Form will be required prior to disclosing protected health information. You will receive an electronic copy of the laboratory testing within 30 calendar days unless an exception applies.
Exceptions include if the access is reasonably likely to endanger the life or physical safety of you or another person as determined by a licensed health care professional. If the results cannot be produced within 30 days, you will be notified by e-mail.
To request the forwarding of your protected health information to your healthcare provider, write to CLEAR’s Privacy Officer, as set forth below. We may charge a fee for the costs of copying, mailing, or other supplies associated with your request, but we will let you know about the fee in advance.
Right to request amendment of protected health information you believe is erroneous or incomplete: If you examine your protected health information and believe that some of the information is wrong or incomplete, you may ask us to amend your record. We will comply with your request, unless we are not the originator of the information, believe that the information you request to be amended is accurate and complete, or special circumstances apply. To ask us to amend your protected health information, write to CLEAR’s Privacy Officer.
Right to receive an accounting of disclosures of your protected health information: You have the right to request a list of certain disclosures we make of your protected health information. Under the law, this does not include disclosures made for purposes of treatment, payment, healthcare operations, or certain other purposes. If you would like to receive such a list, write to CLEAR’s Privacy Officer. Your request must state a time period desired for the accounting, which must be within the past six years. We will provide the first list to you free of charge, but we may charge you for any additional lists you request during the same 12-month period. We will tell you in advance of any associated fees, at which time you may withdraw or modify your request.
Right to request restrictions on how CLEAR will use or disclose your protected health information for treatment, payment, or healthcare operations: You have the right to request us not to make uses or disclosures of your protected health information to treat you, to seek payment for care, or to operate our laboratories. We will consider your requests carefully, but we are not required to agree to your requested restriction. If you want to request a restriction, submit your request in writing to CLEAR’s Privacy Officer and describe your request in detail. CLEAR’s Privacy Officer will reply within 30 calendar days of receiving your request.
Right to request special communications: You have the right to ask us to communicate your protected health information by alternative means of communication or at alternative locations. For example, you can ask us not to call your home, but to communicate with you only by mail. To make such a request, write to CLEAR’s Privacy Officer.
Right to receive a paper copy of this notice: If you have received this notice electronically, you have the right to a paper copy at any time. You may download or print a paper copy of the notice (click here) or by calling or writing to CLEAR’s Privacy Officer.
Changes to This Notice
From time to time, we may change our practices concerning how we use or disclose protected health information or how we will implement patient rights concerning such information. We reserve the right to change this notice and to make the provisions in our new notice effective for all protected health information we maintain. If we change these practices, we will publish a revised notice.
Questions, Concerns, or Complaints
If you have any questions about this notice or have further questions about how CLEAR may use and disclose your protected health information, please contact the Privacy Officer by emailing firstname.lastname@example.org. We welcome your feedback regarding any problems or concerns you have with your privacy rights or how CLEAR uses or discloses your protected health information.