Legal

Last Modified Date: 05/01/2023

This policy describes how Clearing Tech Inc. (“Clearing,” “we,” “us,”) collects, aggregates, stores, safeguards and uses the data and information (including non-public personal information, or “NPI”) provided by users through our website, https://getclearing.co/ (the “Site”), as well as information collected by us through other means, including by email, over the phone, or in offline communications. This Site is operated by Clearing and has been created to provide information about our Clearing, products, and services (together, the “Services”). We take your privacy and the security of your information seriously.This policy explains:

• What information we collect, and how we use it
• Choices you can make about the way your information is collected and used
• How we protect personal information electronically and physically

This policy is incorporated into and a material term of your registration and/or use of Clearing’s products and services, including our website, https://getclearing.co/. By using the Site or Services, you consent to the practices set forth in this Privacy Policy. When the Privacy Policy mentions “Company,” “we,” “us,” or “our,” it refers to the Clearing Tech Inc, a Delaware C-corp corporation you are contracting with in this policy.

INFORMATION WE COLLECT

Information You Provide to Us

Clearing collects information from you when you choose to provide it to us through the Site or through any other means. This may include when you create an account on the Site, register or request products or services, request information from us, sign up for newsletters or our email lists, use our Site, or otherwise contact us.The information we collect may include the following:

Identification Information

• Name
• Email address
• Postal address
• Date of birth
• Phone number
• Social Security Number or Taxpayer Identification Number if you are a US person
• A copy of your passport number if you are not a US person
• Other government-issued identification number, if needed

Commercial information

Such as information about properties you own or manage, e.g., property address if you choose to provide it.

Transaction Information

Such as information about rent or other payments you make or receive, like the names of the transacting parties, a description of the transactions, the payment or transfer amounts, billing and shipping information, and the devices and payment methods used to complete the transactions. As explained below, this type of information may also be collected through your use of the Services.

Tax information

Such as withholding allowances and tax filing status.

Information We Automatically Collect

We may use cookies or other technologies to automatically collect certain information when you visit our Site or interact with our emails. For example, if you are responding to an offer, promotional email or other email from us, we may automatically populate your personal information into our system once you enter your offer code or similar identifying device or otherwise accept your offer or promotion. Additionally, we may automatically collect certain non-personal information from you such as your browser type, operating system, software version, and Internet Protocol ("IP") address. We also may collect information about your use of the Site, including the date and time of access, the areas or pages that you visit, the amount of time you spend using the Site, the number of times you return, whether you open, forward, or click-through emails, and other Site usage data.You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Site or take full advantage of all of our offerings. Check the "Help" menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences. Please note that our system may not respond to Do Not Track requests or headers from some or all browsers.

HOW WE USE INFORMATION WE COLLECT

Clearing uses the data and information you provide in a manner that is consistent with this Privacy Policy and applicable law. If you provide personal data for a certain reason, we may use the personal data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the personal data you provide to answer your question or resolve your problem. Also, if you provide personal data in order to obtain access to the Site or Services, we will use your personal data to provide you with access to such services and to monitor your use of such services.Clearing may also use your personal data and other personally non-identifiable information collected through the Site or the provision of the Services to help us improve the content and functionality of the Site or the Services, to better understand our users and to improve the Site and the Services. Clearing and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you.Clearing uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using the Service, you grant Clearing and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy.

SHARING OF INFORMATION WE COLLECT

Clearing does not sell or re-sell information it has obtained from its customers and website visitors. There are, however, certain circumstances in which we may share your personal data with certain third parties without further notice to you, as set forth below:

Service Providers

Service Providers help us operate, maintain, and update our Services e.g.:

• Dwolla, Inc. (“Dwolla”) provides us with ACH and account services; You will need to accept the Dwolla Terms of Service and Privacy Policy
• Plaid Inc. (“Plaid”) to gather your data from financial institutions. You can learn more about how personal and financial information is transferred, stored, and processed by Plaid through the Plaid Privacy Policy.
• Specialist vendors who help us with fraud prevention, identity verification, and fee collection services;
• Companies that help us run our advertising campaigns, contests, special offers, or other events or activities;
• Other companies who deliver services on our behalf, including via the use of cookies and similar automated technologies, such as third-party analytics and interest-based advertising.

Agents, Consultants, and Third-Party Service Providers

Clearing, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Business Transfers

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets.

Related Companies

We may also share your personal data with our corporate affiliates and subsidiaries, if any, for purposes consistent with this Privacy Policy.

Legal Requirements

Clearing may disclose your personal data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Clearing, (iii) act in urgent circumstances to protect the personal safety of users of the Site, the Services or the public, or (iv) protect against legal liability.

LINKS TO OTHER WEBSITES

The Site may have links to third-party websites, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites, nor does any such link imply that Clearing endorses or has reviewed the third party site subject to such link. We suggest contacting those sites directly for information on their privacy policies.

CHILDREN AND MINORS

Clearing does not knowingly collect personal data from minors under the age of 18. If you are under the age of 18, please do not submit any personal data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal data without their permission. If you have reason to believe that a minor under the age of 18 has provided personal data to Clearing through the Site or the Services, please contact us, and we will endeavor to delete that information from our databases.

DATA SECURITY

We recognize that you are providing some sensitive information in connection with your use of the Services and that security is critical to our Services. As such, we take security precautions, and will continue to vigilantly safeguard your sensitive Personal Information. Our servers are maintained by a reputable third-party service provider. We separate the application server (servers that you interact with) and the database servers (servers that store our data). We encrypt any stored sensitive information, such as bank numbers, routing numbers, and all passwords using 256-bit encryption technology.While we make reasonable efforts to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any personal data to Clearing via the Internet.

ACCESS TO YOUR PERSONAL INFORMATION

We will honor the following requests that you may have about the personal information we have collected from and about you. We will extend our best efforts to respond within a calendar month of your request.

Verifying Your Request

Only you or a person who you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request. We may otherwise limit our response to your request.

Obtain a copy

Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of Personal Information we have collected about you.
• The categories of sources for the Personal Information we have collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you

Update or Correct

Upon request, we will update or correct specific pieces of Personal Information we have collected from you. We may ask you to provide additional verification information to confirm and justify such changes.

Delete

Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.We may deny your deletion request if retaining the Personal Information is necessary for us or our service providers, for example, to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify and repair errors that impair existing intended functionality;
• Comply with a legal obligation such as data retention obligation under the Bank Secrecy Act.

Upon your request to terminate your account entirely, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Opt out of Sharing

Once we receive and confirm your verifiable consumer request, we will stop further sharing of your Personal Information to the extent that such sharing is not necessary for the continuation of our services to you, as described in Section 3 above.In particular, you may request not to receive any future marketing communications from us, or you wish to have your name deleted from our mailing lists if you do not have an active account with us.

CHANGES TO THIS POLICY

Clearing reserves the right to revise this Privacy Policy at any time. When we do, we will post the change(s) on the Site. This Privacy Policy was last updated on the date indicated above. Your continued use of the Site and the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

CONTACT INFORMATION

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your access rights described in Section 7 above,  please do not hesitate to contact us:

• By email at: privacy@getclearing.co
• In writing at: Data Protection Officer, Clearing Tech Inc., 122 W 29th Street, 4th Floor, New York, 10001 NY
• By completing the online contact form inside your Clearing online account

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