Privacy Policy

Last Revised: August 8, 2023

We are ClearFP IP LLC, an Oregon limited liability company doing business as ClearFP and ClearFPSecurities.com (“us” or “ClearFP” or “ClearFP”). We respect your privacy and try to comply with all applicable privacy and data protection rules. Our privacy practices are based on the fundamental principles of notice, choice, accuracy, data minimization, and limited disclosure. Read on for the details about how ClearFP handles personal data.

Personally Identifiable Information. Personally identifiable information (“PII”) is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. PII does not include information that has been effectively aggregated or de-identified.

Sales: We do not sell PII for monetary compensation, and we will not do so in the future unless we first provide you notice and an opportunity to exercise your rights. We do share PII with service providers for purposes of targeted advertising and marketing of our own goods and services; this sharing may be considered a “sale” under state law. We take appropriate measures to help protect PII in our control from misuse or unauthorized access.

Application: This Privacy Policy is our representation and notice to you regarding our information privacy practices. It applies to all PII collected at our ClearFP offices, and also to PII collected from your use of any online services that post a link to this Privacy Policy, including our websites (at ClearFP.com, clearfpadvisor.com, clearfpsecurities.com, and somethingsmartaboutmoney.com), applications, platforms and any other ClearFP programs (collectively the “ClearFP Services”).

When you visit or use the ClearFP Services, we collect the following categories of information:

Identifiers – We collect PII, such as your first and last name, phone number, email address, postal address, day and month of your birthday, and demographic information (such as gender). We may ask you to create a username and password linked to your PII, or to share your contacts with us.
Financial – We collect PII necessary to process payments for fees or purchases through the ClearFP Services, such as financial account or payment card information.
Commercial – We may collect PII about your transactions in our offices, on our websites or via our Application, including what services you use.
Online Activity – We collect information about your device such as its IP address, MAC address, and associated advertising identifier (such as IDFA or AAID). If permitted, we collect PII related to your online activity, such as your browsing history. This Privacy Policy describes some ways to limit this type of collection.
Geolocation – We collect PII about your location of your device, but our ability to collect this information can be limited. We may use location-based technology in our retail locations, to detect the presence of your device, if your device settings allow this.
Likeness & Biometrics – We collect biometric PII such as your image or likeness when you use certain ClearFP Services. Video surveillance cameras are installed at some of our retail locations for premises security. These cameras collect visual images and similar information. With your notice and consent, we may also record voice or video calls to our customer service for quality assurance.
Content – We collect the content of messages sent to us, our customer service or marketing teams.
Resume Data – If you apply for employment, we will collect PII such as your name, email, phone number, employment and education history.
Inferences – We may draw inferences from the PII and other information described above, such as inferences about the identity of the user of a particular device.

This Privacy Policy explains:

what categories of PII we collect and from where;
how we use the PII;
with whom we may share the PII;
what choices you have about our collection, use and disclosure of the PII;
what data security procedures we employ to protect PII under our control;
how you can correct any inaccuracies in the PII; and
how you can exercise any additional rights granted by applicable state law.

Updates & Changes: We may update or modify this Privacy Policy from time to time, and we will post the changes here. If we change this Privacy Policy in a way that materially alters your rights, we will provide notice to the last-known email address, and an opportunity to exercise your rights. If state law or other applicable law gives you additional rights in these circumstances, we will follow the applicable law.

Limiting Our Collection and Use of Your PII

Industry Organization Opt-Outs
Two major US-based trade organizations offer opt-outs from interest-based advertising by their members. The Digital Advertising Alliance (DAA) and the Network Advertising Initiative (NAI) offer opt-out of interest-based advertising from their members. See the DAA’s opt-out portal and the NAI’s opt-out portal, and for mobile applications the DAA’s application.

Do Not Contact & Do Not Track
If you do not want to be contacted by us, we will promptly honor your do-not-contact request. You can opt out by replying STOP to any SMS message, following the instructions at the bottom of any ClearFP marketing email, calling us at (503) 579-1000, or sending a letter to ClearFP, Attention: Customer Relations, Suite 100, 15573 Bangy Rd., Lake Oswego, OR 97501. Opting out will void eligibility for the giveaway offered by us through clearfpsecurities.com. The ClearFP Services recognize the Global Privacy Control browser setting, which opts the user out of cookies on the browser for which it is enabled. See https://globalprivacycontrol.org
PII of Minors
We do not knowingly collect or maintain the PII of any persons under 13 years of age. If you are the parent or guardian of a person under 13 years of age and you believe we have collected such information, please tell us to delete it by calling us at (503) 579-1000, or sending a letter to ClearFP, Attention: Customer Relations, Suite 100, 15573 Bangy Rd., Lake Oswego, OR 97501.

For persons aged 13-18, we will not sell or share PII for purposes of marketing the goods or services of third parties in the future with your PII, unless we first ask for and obtain verifiable consent from you or (if required by applicable law) your parent or guardian.

Sources of PII

PII We Collect Directly from Your Input

The ClearFP Services collect PII directly from you when you use the ClearFP Services, such as when you visit our offices or contact us to express interest in employment, for customer service, to order merchandise or to express interest in our products. If you use our ClearFP Clock™ mobile application, we collect PII associated with your use of the application such as name, phone number, device identifier, services and locations. To be eligible for the giveaway offered through clearfpsecurities.com, participants must submit their name, email address, and phone number; for an additional incentive, they may also submit their physical addresses and ranges for income and net worth. Participants in the giveaway also agree to be contacted by us during the term of the promotion, and withdrawal of such consent voids their eligibility for the giveaway.

PII We Collect Passively

The ClearFP Services passively collect PII or information that may be combined with PII (such as browser type, ISP, IP address, referring/exit pages, platform type, date/time stamp, and number/nature of clicks) when you use the ClearFP Services. Sources for this type of collection include internet service providers, device operating systems, our advertising and data analytics providers. If we combine your PII with information that is not by itself personally identifiable, we will treat the combined result as PII.

PII from Cookies, Web Beacons & Other Technologies

The ClearFP Services use various technical means to collect information about the usage of our sites and mobile applications, such as cookies, web beacons, local storage, entity tags and JavaScript. Most device and software browser settings can be adjusted to prevent or reduce the use of these technologies.
The ClearFP Services use first and third-party cookies to collect information about how the ClearFP Services are used, such as the pages viewed and the amount of time. The ClearFP Services use both session ID cookies and persistent cookies. The session ID cookie terminates once you close the browser or application. The persistent cookie stores a text file on your computer. If you allow the persistent cookie, we can recognize your computer and your browser can remember your login information. If you reject the cookie, your user experience may be limited.

Third-party web beacons and similar technologies may associate your actions across different web sites. Web beacons (also known as clear gifs or pixel tags) are graphics with a unique identifier, used to track the online actions or movements of users. We may include web beacons in email messages or newsletters to determine whether messages have been opened and acted upon. We may use such information to improve the ClearFP Services, reconstruct activity from a session or by a user, and for troubleshooting.

Local storage and entity tags allow sites to store part of their content on your device, allowing the site to load more quickly. These technologies are also used for performance monitoring and targeted advertising.

JavaScript is code embedded in sites or applications. The code is executed (if allowed) by your device and software e.g. to speed load times and monitor systems usage.

PII From Social Media & Other Sources

We may collect PII from our interactions with you on social media websites and applications, and we may use this PII for the purposes and uses described in this Policy. If you follow or interact with one of our social media accounts, our access to your information on that platform will be as allowed by the terms of service and privacy policy of that platform. Generally, when you use a separate entity’s site, platform, or service, the terms of service and privacy policy of that entity apply, so you should determine the information practices of that separate entity. We also may obtain PII of actual or potential clients from third parties such as consumer data resellers, credit reporting agencies, government agencies, public records and other sources.

Our Use of Your PII

Use for Marketing Communications: We may send you notices about ClearFP products or services, unless you withdraw your permission to receive marketing communications from us. You may do this at any time. You can opt out by replying STOP to any SMS message, following the instructions at the bottom of any ClearFP marketing email, calling us at (503) 579-1000 or sending a letter to ClearFP, Attention: Customer Relations, Suite 100, 15573 Bangy Rd., Lake Oswego, OR 97501.

Use for Employment Communications:

If you express interest in employment at ClearFP, we will communicate with you about the application process and use your PII to evaluate your eligibility. You may terminate your application process at any time and opt out of further communications from us. If you have consented to receive employment-related communications via phone or text message (SMS), you can opt out replying STOP to any SMS message, following the instructions at the bottom of any ClearFP marketing email, calling us at (503) 579-1000 or sending a letter to ClearFP, Attention: Employment, Suite 100, 15573 Bangy Rd., Lake Oswego, OR 97501.

Use for Internal Business Purposes (last 12 months): We use PII for our internal business purposes, such as:

To administer, maintain, and understand your use of, or interest in, the ClearFP Services;
To personalize the ClearFP Services to your preferences;
To respond to you or communicate with you;
To measure and improve the overall effectiveness of our advertising and content; and
For data analysis, research, audits, fraud monitoring and prevention, and new product development.

Our Disclosures of Your PII (last 12 months):

ClearFP discloses your PII as follows:

To Service Providers: We may share your PII with professional service providers that perform services on our behalf. For our clients, they include our payment processor and the provider of our mobile application. These third parties are required to treat your PII according to their own respective privacy policies, and to follow applicable law.

To Providers of Analytics and Targeted Advertising on Our Behalf (last twelve months):
We use Google Analytics and other analytics providers to help measure trends, performance and traffic, and to provide targeted advertisements. These analytics providers collect PII through tracking technologies, including those embedded in the ClearFP Services. The tracking technologies use PII to make inferences based on connections among related browsers and devices, such as those using the same wi-fi access point, combined with geolocation data if available, and to show advertisements based on such inferences. You may limit some of this tracking and advertising through technical means, such as the Google Analytics opt-out browser extension, and by exercising industry organization opt-outs as described above.

To ClearFP Affiliates: If you work with someone in our ClearFP network, we will share your PII with the ClearFP affiliate or business partner.

As Required by Law or Legal Process: We may disclose your PII in response to a lawful subpoena, court order or request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as we reasonably believe is required by law. In such cases, we may raise or waive any legal objection or right available to us.

To Protect Our Business: We may disclose your PII when we reasonably believe disclosure is necessary to investigate or prevent actual or suspected unlawful activity; to protect and defend the rights, property or safety of our company, employees, customers or others; or to enforce our Terms of Service or other agreements between us and you.

To Successors in Business Transitions: If ClearFP goes through a business transition, such as a merger, being acquired by another company, or sale of its assets, PII held by us will, in most instances, be part of the assets transferred. We will use our best efforts to ensure that the transferee assumes the responsibility of maintaining the PII under a policy at least as protective as this Policy.

Accuracy and Maintenance of Your PII

Accuracy: We will strive to ensure that your PII held by us, if any, is accurate. Prospective employees have multiple opportunities to review, update and correct PII during the application process. You may also contact us to inquire about or correct the accuracy of your records by calling us at (503) 579-1000 or sending a letter to ClearFP, Attention: Customer Relations, Suite 100, 15573 Bangy Rd., Lake Oswego, OR 97501.

Maintenance and Retention: We retain PII as long as necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law. In determining the retention period, we consider the need to satisfy our legal or reporting requirements; the nature and sensitivity of the PII; the potential risk of harm from unauthorized use or disclosure of the PII; the purposes for which we use the PII; and whether we can achieve the purposes through other means. We may be unable to delete your information from our database until the expiration of the applicable period. State law may give you additional rights; see the state-specific notices at the end of this Privacy Policy.

Data Security: We take reasonable precautions in accordance with industry standards to protect PII held by us from unauthorized access. We reasonably restrict access to PII according to its sensitivity, and we employ information security safeguards when allowing employees and service providers with proper authorization to access it. We use firewalls and other intrusion detection and prevention controls to help prevent unauthorized persons from gaining access to your PII. We also use administrative and physical security measures. These measures include secured files and buildings. Security measures are by nature not a perfect or complete defense against malicious actors. Accordingly, we do not guarantee that your PII will be completely secured against unauthorized access.

Data Breach Notification: ClearFP maintains procedures for notifying you in the event of a data security breach. If ClearFP experiences a data security breach and is required to notify you under applicable law, ClearFP will notify you by electronic mail using the last-known e-mail address you have provided. You are responsible for ensuring that your contact information is current and correct. You can review or change your information and correct any inaccuracies by calling us at (503) 579-1000 or sending a letter to ClearFP, Attention: Customer Relations, Suite 100, 15573 Bangy Rd., Lake Oswego, OR 97501.

Procedures

Questions about this Policy:If you have questions about this Policy, our information practices or other aspects of privacy on our ClearFP Services, please call us at (503) 579-1000 or send a letter to ClearFP, Attention: Customer Relations, Suite 100, 15573 Bangy Rd., Lake Oswego, OR 97501.

Rights under Applicable State Law

If your state has adopted a law granting you additional rights relating to PII collected by us, and the state law applies to us, we will comply with the state law. As of August 2023, four states have currently effective and potentially applicable laws of this type: California, Colorado, Connecticut, and Virginia.

California

If you are a resident of California, you have the rights to request additional information from us regarding our collection and use of PII, to ask us to correct or delete your PII, to opt out of the sale or sharing of your personal information, to limit our use and disclosure of sensitive PII, and to opt out of the use of your PII for automated decision-making.

To maintain data security, we will verify your identity before taking action on your request. Our procedure for verifying your identity is to match identifying information provided by you with PII held by us. We may need to request additional information to verify your identity, but if so we will use it only to process your request. We may also use a third-party identification service. We will not discriminate or take any adverse action against you for exercising these rights. You may designate an authorized agent to exercise these rights on your behalf. To exercise these rights, call us at (503) 579-1000 or send a letter to ClearFP, Attention: Customer Relations, Suite 100, 15573 Bangy Rd., Lake Oswego, OR 97501. We will respond within 10 days or the period required by applicable law. We will comply with verifiable requests within 45 days (90 days if we notify you of the reason for the delay), or as required by applicable law.

You have the right to ask us for the specific PII we have collected about you during the preceding calendar year, as well as the following for the preceding calendar year:

The categories of PII we collected;
The categories of sources of PII we collected;
The purposes for which we collected PII;
The categories of third parties that received PII from us;
The categories of business purposes for which we used PII; and
The categories of PII sold/shared for marketing purposes and the categories of the recipients.

California Residents – Individual Rights

Correction or Deletion. You have the right to ask us to correct or delete your PII collected or maintained by us. If we use deidentification to satisfy a deletion request, we will maintain the PII in deidentified form and not attempt to reassociate it with PII. Applicable laws, regulations and legal obligations may prevent us from completely deleting all of your PII.

Sensitive PII. You have the right to ask us to limit our use and disclosure of sensitive PII in a way that reasonably corresponds to the purpose of collection.
Advertising Opt-Out.You have the right to opt out of the sale of your PII, and to request that we not share your PII for targeted or behavioral advertising.

Colorado, Connecticut, and Virginia – Individual Rights

ClearFP does not sell PII as sales are defined under the laws of Colorado, Connecticut, or Virginia. Residents of these states, and of any other state that makes effective a law granting similar rights, may exercise these rights using the same mechanisms as California residents (above).

Access & Portability. You have the right to obtain a copy of your PII in data-portable format.
Correction or Deletion.You have the right to ask us to correct or delete your PII collected or maintained by us. If we use deidentification to satisfy a deletion request, we will maintain the PII in deidentified form and not attempt to reassociate it with PII. Applicable laws, regulations and legal obligations may prevent us from completely deleting all of your PII.

Advertising Opt-Out. You have the right to opt out of sales of your PII, and to request that we not share your PII for targeted or behavioral advertising.

Automated Decision Making. You may have the right to opt out of use of your PII for automated decision making.
Appeals. You may have the right to appeal any decision by us denying a request by you under applicable state law.

Last Revised: August 8, 2023