Clear Health Pass understands how important the privacy of personal information is to our users. This Privacy Policy will tell you what information we collect about you and your use of Clear Health Pass and its services. It will explain your choices about how your personal information is used and how we protect that information. We urge you to read this Privacy Policy carefully. This Privacy Policy applies to websites owned and operated by Clear Health Pass that are intended for use by consumers (non-professionals) for non-commercial personal, family, or household purposes, including Clear Health Pass.com and CovidPetTests.com and including the mobile optimized versions of these sites and our Mobile Device Applications or “Apps” (we refer to these sites and Apps collectively as the “Clear Health Pass Sites”). We refer to the Clear Health Pass Sites and Apps, along with the information and services made available to you through the Clear Health Pass Sites and Apps, as the “Services.” This Privacy Policy also applies to the consumer-facing version of the Clear Health Pass Health Manager Product. However, if you are an employee or health plan member who has enabled access to your health record at Clear Health Pass.com by registering at your employer’s or health plan’s website, the privacy policy applicable to your information at your employer’s or health plan’s website remains applicable to your personal health record at Clear Health Pass.com. If your employer or health plan account is no longer made available to you by your employer or health plan, you will continue to have access to your health information from Clear Health Pass.com using the same username and password but will be subject to this Privacy Policy. Except where noted, statements in this Privacy Policy concerning the Clear Health Pass Sites also apply to the Apps. If you do not want us to collect, use or disclose information about you and your use of the Services as described in this Privacy Policy, then you should not use the Services. By using the Services, you must agree to the Clear Health Pass Terms of Use, which is the contract between users and us of the Services.  By accepting the Clear Health Pass Terms of Use, you confirm that you have read and understood and consent to this Privacy Policy and the Clear Health Pass Cookie Policy. You consent and acknowledge that we will store, use and otherwise process your information in the United States, where we are located. References to “Clear Health Pass,” “we,” or “us” mean Clear Health Pass LLC, including any company that Clear Health Pass LLC controls (for example, a subsidiary that Clear Health Pass LLC owns). Clear Health Pass may share information among its subsidiaries or websites that it owns or controls, but the information collected under this Privacy Policy is always protected under the terms of this Privacy Policy. Except as otherwise noted in this Privacy Policy, Clear Health Pass LLC is the data controller responsible for the processing of your personal information as described in this Privacy Policy. Information Collected About You Some of our Services (such as specific quizzes or calculators) do not retain your personal information, while others (such as Clear Health Pass Lab Testing and other health-related programs that may be or become available in the Clear Health Pass App and certain of our registration-only Apps like Clear Health Pass Baby, Clear Health Pass Pregnancy and Clear Health Pass Allergy) store your personal information in accordance with this Privacy Policy. Even if you do not register with or provide any personal information to Clear Health Pass, we collect information about your use of the Clear Health Pass Sites, and Apps, and Services. We may also acquire information about our users from external sources. When you use the Services, we collect information as follows: Registration While you may use most of the Services without registering, certain Services require you to register with Clear Health Pass for them to function correctly. If you choose to register or update an existing account with Clear Health Pass or access certain Services, you may be required to provide certain personal information, such as your name, address, telephone number, gender, email address and date of birth, and a username and password to access your Clear Health Pass account. You are responsible for ensuring the accuracy of the personal information you submit to Clear Health Pass.

This Privacy Policy explains how Clear Health Pass Holdings, LLC. (“Clear Health Pass,” “CHP,” “we,” “us,” or “our”) may collect, use, disclose, and otherwise process your personal information through our digital properties that link to this Privacy Policy, including our website and mobile application (the “Service”).

Clear Health Pass has developed different initiatives in coordination with epidemiologists and public health officials to increase the reach and efficacy of the public health response related to COVID-19, improve health equity, improve health and human services, and reduce cost. This Privacy Policy is designed to describe our privacy practices comprehensively. Because several different modules are available through the Service, depending on the module(s) you are using, we may collect less personal information—or disclose information in fewer ways—than described in this Privacy Policy. If a module you use contains more data than described in this Privacy Policy, we will provide an additional notice at or before the collection point.

Your use of Clear Health Pass is voluntary. You may deactivate your account anytime from within the Service and direct us to delete your personal information.

 

HOW WE COLLECT YOUR PERSONAL INFORMATION

When you use the Service, we will ask you to share certain personal information. We will also receive information from U.S. local, state, and federal government organizations, as well as other entities you authorize, and collect specific technical, device, and usage information from your device.

 

Information You Provide to Us. The personal information you may provide to us through the Service or otherwise includes:

Registration and Profile Information. You may provide certain personal information when you register to use Healthy Together, including, among other things, your full name, zip code, phone number, email address, billing and mailing address, date of birth, biographical details, username and password that you may set to establish an online account, and other information that you add to your account profile.

User-Generated Information. You may provide information regarding your non-medical needs and other content or information you generate, transmit, or otherwise make available on the Service.

Health-Related Information. You may submit personal information about yourself through your use of the Service, such as your age, reported height and weight, your pre-existing conditions, and other health-related information.

Vaccination Records and Health Test Results. You may choose to upload a photo of your vaccination records and health test results (including for COVID-19), as well as details such as the type of test, test date, and location so that they can be stored and easily accessed from your account. Clear Health Pass cannot access your camera or stored photos without permission. We will never access or upload stored photos from your device unless you have selected them for upload.

Demographic Information. You may provide information regarding your race, ethnicity, preferred language, and state and county of residency.

Relationship Information. You may provide information about your family members or other third parties.

Transactional Information. You may provide the information needed to complete your orders on or through the Service, including order numbers and transaction history.

Financial and Related Information. You may provide information regarding your finances, such as your stated income and economic standing, as well as your EBT information.

Identification Number Information. You may share your identification number information, such as national identification number (e.g., Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), student ID number, employee ID number, or other forms of identification, and an image of the relevant identification card.

Communications Data. We may collect communications data from our exchanges with you, including when you contact customer support personnel through the Service, social media, or otherwise.

Scans of QR Codes. You may use your device camera to scan a Bar or QR code to connect test results to your account or verify symptom information to a third-party entity, such as a school, employer, or another party. We cannot access your camera without your permission.

Information about Selected Contacts. With your consent, we may receive the name and phone number of individuals from your device’s contact list for case interview purposes if you test positive for a local, state, or nationally notifiable disease. We only receive the specific contacts you choose to share with us whom you believe may have been exposed to a communicable disease (“Selected Contact”). If you choose to share a Selected Contact, we may share this information with U.S. state and local government organizations to assist them with case interview activities.

Other Information. You may provide additional information not explicitly listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-Party Sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

Public Sources. We may receive information about you from our government or school partners to offer health or benefits-related services. For example, suppose we partner with your state of residency to administer public benefits applications or display your medical test results through the Service. In that case, we may receive your contact information and related information to provide these services. You may also connect your Clear Health Pass account with your government or school accounts.

Marketing Partners. We may receive information about you from joint marketing partners.

Third-Party Services. We may combine personal information we receive from you with personal information from third-party services that you use to log into or otherwise link to your Service account. This data may include your username and other information associated with your account on that third-party service made available to us based on your account settings.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications, and other online services, such as:

The device, Technical, and Usage Information. When you access the Service, we collect information about your mobile device or computer system, including MAC address, IP address, and mobile device ID. We also generate usage statistics about your interactions with the Service. This information is typically collected through the use of server log files or web log files, mobile device software development kits, and tracking technologies like browser cookies to analyze certain types of technical information. Some cookies the Service places on your computer are linked to your user ID number. When you respond to communications we send you, we may use automated technology to understand how you interact with the contacts. You can usually remove or reject browser cookies through the settings on your browser or device. Currently, we do not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions. We may also use local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store more significant amounts of data on your device outside your browser in connection with specific applications. We may also use web beacons, also known as pixel tags or clear GIFs, to demonstrate that a webpage or email was accessed or opened or that certain content was viewed or clicked.

 

HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and business operations.  We may use your personal information to:

• Provide, operate and improve the Service and our business;
• Establish and maintain your user profile on the Service;
• Facilitate your invitations to friends whom you want to invite to join the Service;
• Facilitate features of the Service, such as by providing chat or messaging functionality
• Enable security features of the Service, such as by sending you security codes via email or SMS and remembering devices from which you have previously logged in;
• Communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages.
• Connect you with specific U.S. state and local government organizations within your state, county, or city.
• Understand your needs and interests, personalize your experience with the Service and our communications, and;
• Provide support for the Service, and respond to your requests, questions, and feedback.

 

Research and development. We may use your personal information for research and development purposes to analyze and improve the Service and our business.  As part of these activities, we may create aggregated, de-identified, and anonymized data from the personal information we collect.  We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you.  We may use this aggregated, de-identified, or otherwise anonymized data and share it with third parties for our lawful business purposes to analyze and improve the Service and promote our business.

Marketing. We may collect and use your personal information for marketing purposes. We may send you direct marketing communications.  You may opt out of our marketing communications as described in the Opt-out of marketing section below.

Compliance and protection.  We may use your personal information to:

• comply with applicable laws, lawful requests, and legal processes, such as responding to subpoenas or requests from government authorities.
• protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims).
• Audit our internal processes for compliance with legal and contractual requirements or our internal policies.
• enforce the terms and conditions that govern the Service; and
• Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

With your consent.  In some cases, we may ask for your consent to collect, use, or share your personal information, such as when required by law.

To create aggregated, de-identified, and anonymized data.  We may create aggregated, de-identified, and anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified, and anonymized data and share it with third parties for our lawful business purposes to analyze and improve the Service and promote our business. We may also share de-identified information with public interest organizations, healthcare organizations, and researchers. We will prohibit these organizations from attempting to re-identify the information we share with them to the extent practical.

Use of Cookies and Similar Technologies

Cookies and similar technologies. In addition to the other uses included in this section, we may use the cookies and similar technologies described above for the following purposes:

Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site and whether you are logged in when you visit password-protected areas of the Service.

Functionality. To enhance the performance and functionality of our services.

Analytics. To help us understand user activity on the Service, including which pages are most and least visited, how visitors move around the Service and user interactions with our emails. For example, we may use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

 

How We Share Your Personal Information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

• We may share your personal information with third parties where you have instructed us or provided your consent. With your Consent, we may share your personal information with U.S. local, state, and federal government organizations and public health organizations for the purposes we have set out in this Privacy Policy relating to public health efforts. For example, a government or public health organization may request your checkup data or your test results if you have tested positive for communicable diseases (e.g., COVID-19) to assist with case interview efforts. We may also share your personal information with other third parties relating to public health intervention and response efforts, such as your university or employer if you have authorized us to do so.
• If you log into the Service with or otherwise link your Clear Health Passaccount to a third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

 

Other Disclosures

We may share personal information with third-party service providers that perform services on our behalf, including lab services, quality assurance testing; facilitating the creation of accounts, optimizing the platform performance, providing technical support; and provide other related services.  We may also share your personal information with professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

We may share personal information with the government, law enforcement officials, or private parties as required by law, when we believe such disclosure is necessary or appropriate (a) to comply with legal obligations, law enforcement requests, or legal directives such as a court order or subpoena; (b) enforce the terms and conditions that govern the platform; (c) protect our rights, privacy, safety or property, and that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

We may share your personal information with acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) such as a merger, consolidation, acquisition, spinoff, reorganization, or sale of assets or in the event of bankruptcy. We will notify you of any change in ownership that affects your personal information so that you may decide whether to keep your account active or delete your account.

We make commercially reasonable efforts to verify that the parties with whom we share personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as defined in their privacy policies.

Please note that we do not sell personal information.

Protection of Your

We may make features available on the Service, or link, that allow you to share information with third parties. Please be careful when sharing your personal information with third parties, and only share sensitive personal information with those whom you trust. We have no control over the use of your data by third parties with whom you choose to share your information.

 

RETENTION OF YOUR INFORMATION

We generally retain personal information to fulfill the purposes for which we collected it, including to satisfy any legal, accounting, or reporting requirements, establish or defend legal claims, or prevent fraud.  To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your data and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing. You may also delete your personal information and deactivate your account, as described below under Your Choices.

 

SECURITY OF YOUR INFORMATION

We have implemented several security measures reasonably designed to protect your personal information. It is essential that you save and maintain the security of your account, and you should immediately notify us of any unauthorized use of your account. No website, mobile application, or Internet transmission is completely secure. Therefore we cannot guarantee that unauthorized access, hacking, data loss, breaches, or other types of misuse will ever occur. Be careful where and how you share personal information—use public WiFi spots wisely and avoid clicking unfamiliar links or using foreign devices.

In the unlikely event that Health Together experiences a security breach affecting your personal information, we will notify you as required by applicable law. This notice will include information about what happened and the data involved, what steps we have taken to address the incident, and what steps you can take to protect yourself further.

 

Consent to User Communication Choices

You are accessing and Updating Your Information. If you have an account with us, you can access and edit your profile information directly within the profile page of the Service.

You are deactivating Your Account and Deleting Your Information. You may deactivate your account at any time by following the instructions within the Service settings. If you deactivate your account, we will delete all of your personal information within 45 days, except to the extent we are required to retain the information by law or record retention policies of the governmental authority on whose behalf we provided the Service to you.

You are opting Out of Push Notifications. If you opt-in to receive push notifications within our mobile applications, we may send push notifications or alerts to your mobile device from time to time. You can deactivate push notifications and alerts anytime by deleting the mobile app, changing your device settings, or changing the push notification settings within the mobile app.

You are opting Out of SMS Communications. If you opt-in to receive SMS messages by providing your phone numbers, we may send you notifications and other SMS messages from time to time. You may opt out of receiving SMS communications at any time by responding to any SMS with the single-word command “STOP.” In addition, if you have an account, you can opt-out of SMS communications by changing your settings within the Service. You may opt back into SMS communications anytime by adjusting your account settings within the Service. Please note that we may not be able to determine if you deleted or uninstalled the mobile app or blocked the number that delivers the communications. Therefore we may be unable to automatically stop you from receiving SMS communications unless you have specifically opted out of SMS communications by following the instructions above.

 

AGE REQUIREMENTS

Clear Health Pass is not intended for children under 13, and we do not knowingly collect any personal information from children under 13. However, we have certain features where we request information from a parent or guardian about their dependent(s).

If we become aware that an individual under the age of 13 has used the Service, then we will promptly delete their information unless we are prohibited by law from doing so.

 

ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

This section describes how we collect, use, and share the Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights concerning that Personal Information.  For purposes of this section, the term “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA.  In some cases, we may provide an additional privacy notice to specific categories of California residents, such as job applicants. That notice will apply instead of this section.

We collect the types of Personal Information from you as described above (How We Collect Your Personal Information). We use this Personal Information for the business purposes described above (How We Use Your Personal Information). We share personal information under How We Share Your Personal Information.

Your California privacy rights. California residents have the rights listed below under the CCPA. However, these rights are not absolute, and in some instances, we may decline your request as permitted by law. Please note that we do not sell your personal information.

Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:

• The categories of Personal Information that we have collected.
• The types of sources from which we collected Personal Information.
• The business or commercial purpose for collecting and selling Personal Information.
• The types of third parties with which we share Personal Information.
• The types of Personal Information that we trade or disclose for a business purpose.
• The types of third parties to whom the Personal Information was sold or disclosed for a business purpose.

Access. You can request a copy of the Personal Information we collected about you during the past 12 months.

Deletion. You can ask us to delete the Personal Information we ordered from you.

Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

Exercising your right to information, access, and deletion. You may submit requests to exercise your right to information, access, or deletion by emailing us at support@healthytogether.zendesk.comor by mailing your request to:

Twenty Labs, LLC, 382 NE 191st, St PMB 42782, Miami, Florida 33179-3899

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

We will need to verify your identity to process your information, access, and deletion requests and reserve the right to confirm your California residency.  We may require government identification, a declaration under penalty of perjury, or other information to verify your identity.

Your authorized agent may request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent under California Probate Code Sections 4000-4465.  Suppose you have not provided your agent with such a power of attorney. In that case, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity and confirm that you have given the authorized agent permission to submit the request.

 

CHANGES TO OUR PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you if we make material changes to our Privacy Policy by either posting the changes on the Service or by contacting you directly using the contact information you have on file. The notification will also state when the changes will become effective.

By continuing to use the Service after the Privacy Policy is updated, you will have agreed to the new Privacy Policy.

 

CONTACTING US

If you have any feedback, questions, comments, or concerns about this Privacy Policy or our privacy practices, please send an email to  support@clearhealthpass.zendesk.com or write to us at the following address:

Clear Health Pass Holdings, LLC

Legal

30 Wall Street, 8^th Floor

New York, NY 10005