Last updated on October 22, 2021.

Your privacy is very important to us.

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We, CFT Clear Finance Technology Corp., its affiliates, subsidiaries, assigns and successors (collectively, “Clearco”, “we”, “us” or “our”) are committed to protecting your privacy and your personal data. This Privacy Policy (“Policy”) will provide you transparency on the personal data we collect, how we secure it and your rights available under law.

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Personal data means any information relating to an identified or identifiable natural person (“Personal Data”). If your information is aggregated, de-identified or anonymized, and it is no longer reasonably associated with an identified or identifiable natural person, we may use such information for any business, research, or statistical purposes.

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This Policy applies to all websites, devices, and applications that we operate (including mobile applications), pages within or associated with each such websites, devices, and applications, and any equivalent, mirror, replacement, substitute or backup to such websites, devices, and applications (“Sites”). This Policy further applies when you access or use our Sites, or our products, services, tools, and functions offered or made available by us, whether online (including via the Site or a mobile application) or in-person, or when you sign up to our newsletters, or when you otherwise interact with us (“Services”).

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If you have any additional business agreements with us, to the extent there is a conflict between this Policy and such business agreement, then the terms of such business agreement will prevail over this Policy with respect to such specific Services.

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It is important you read and understand this Policy along with our Terms of Service. If you do not agree to or do not have the authority to agree to this Policy or Terms of Service, you may not access or use our Sites or our Services.

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To enable you to better understand how we handle your Personal Data, this Policy details:

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What information we collect

When you access or use our Service, we collect information including Personal Data from you, through automatic methods or from third parties. We only collect the minimum necessary Personal Data to provide our Services.

Information you provide:

• Your Identity and Contact information include full name, email address, mailing address, phone number, password, date of birth, social security/social insurance number/national identification/ taxpayer identification number, citizenship, job title and if you are an authorized signatory to enable us to identify and register you for our Services.
• Your Business Information such as type of business, registered and business addresses, financial statements, organizational documents, organizational information, beneficial ownership information, director and employee information, sales volumes, to better understand your business and your business needs.
• Your Banking Information such as bank statements, banking and payment history, credit card information to evaluate your revenue and financial position.
• Your preferred third-party vendors, websites, or internet services (“Third Party Sites”) to enable us to register, set up vendor accounts or provide specific Services.
• Your Profile Information and User Preferences such as preferred Services, your interests, feedback, survey responses to customize your preferences.
• Your Marketing and Communication Preferences such as subscription to our newsletters and blogs to provide you information about Clearco and our Services.
• Your employment application including your resume, contact details, employment history, and education to evaluate your job application.
• Your personal testimonials including your name as a customer of our Services.

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Information we automatically collect:

• We use cookies, web beacons and other similar technology to collect information to support the integrity of our registration process, retain your preferences and account settings, count visits, and help evaluate and compile aggregated statistics about user activity.
• We may collect your computer browser type, geolocation, Internet protocol address, pages visited, and average time spent on our Sites. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our web and mobile application design and functionality.
• When you use the mobile versions of our Sites, we may collect the unique device identifier assigned to that device by phone makers, carriers, or makers of the operating system (the “Device ID”) to uniquely identify your device for purposes of storing application preferences, user activities and other data.

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Information we receive from third parties:

• We may collect, on your behalf, your account and other Personal Data from Third Party Sites that you register under your account via the Services including providers of payment and delivery services.
• We may use third parties to gather your Personal Data, Business Information and Banking Information from financial institutions or registered agents to provide Services.
• We may collect information from our business partners, referral service providers, analytics providers and search information providers about your interests and preferences.
• We may also collect information about you from mailing list providers, publicly available sources, and other third parties, including to process and manage your application and transactions.
• We may allow third party service providers to use cookies (as noted above) or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of our Sites.
• We may obtain Personal Data from recruiters or other entities as part of background checks for an employment opportunity with Clearco.

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Why we collect your information

Our legal basis to process your Personal Data are:

• Contract: to enable us to enter into a contract with you or to perform and fulfill our contractual obligations
• Legitimate Interest: as detailed in “How we use your information”,
• Legal or regulatory obligations: to comply with our legal and regulatory obligations.

Except in relation to your marketing or cookie preferences, we do not rely on consent as a legal basis for processing your Personal Data.

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How we use your information

We will not reuse your Personal Data for a new purpose other than the aforesaid original one(s) for which it was collected, unless one or more of the following apply:

• the new use is compatible with the original use such that you would reasonably expect such a similar use.
• we have notified you of the new use and given you an opportunity to authorize it; or
• the new use is otherwise permitted or required by law.

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Who do we share your information with

We may share your Personal Data with the parties set out below:

• Internal Third Parties: These third parties include our subsidiaries and affiliates
• External Third Parties: These third parties include our service providers, agents, subcontractors, consultants, insurance providers, financial institutions, funders, payment processors, business partners, referral partners, recruiters, governmental entities (to respond to a request, subpoenas, registrations, or legal processes) or other third parties (as required by law, to comply with our legal and regulatory obligations, or to protect and secure our interests, rights, and our assets)
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law in your jurisdiction. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

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How do we transfer information collected internationally

We may transfer your Personal Data from your current location to the offices and servers of Clearco and to our authorized third parties located in the United States and Canada.

Whenever we transfer your Personal Data out of Australia, United Kingdom (“UK”), Switzerland or European Union (“EU”), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for personal information.
• Where we use certain service providers, we may use specific contracts approved for use in Australia, UK, Switzerland, or EU (as applicable) which give personal information the same protection it has in Australia, UK, Switzerland, or EU (as applicable).

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of Australia, UK, Switzerland, or the EU.

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How long do we keep your information

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, administrative, security, compliance, contractual, tax, accounting, or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

We will continue to retain certain information about our customers for seven (7) years after they cease being customers in accordance with applicable laws. In some circumstances you can ask us to delete your Personal Data: see Request to erase your Personal Data below for further information.

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How we secure your information

We take reasonable measures, including firewall barriers, SSL/TLS encryption techniques, and authentication procedures, to help protect your Personal Data from accidental loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

As the internet or email transmission is not fully secure or error free, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send us via email. Please keep this in mind when disclosing your Personal Data to Clearco via the internet. We encourage you to disclose any suspected security vulnerabilities or bugs to our security team at security@clear.co.

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What are your rights under law

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. Your rights may provide:

Request access to your Personal Data

This enables you to receive a copy of your Personal Data we hold.

Request correction of your Personal Data

This enables you to correct any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your Personal Data

This enables you to ask us to delete or remove Personal Data where we are no longer required to hold it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to Object to Processing. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing your Personal Data

This enables you to object to processing of your Personal Data when it is based on our legitimate interest or those of a third party. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

Request restrictions of processing your Personal Data

This enables you to ask us to suspend the processing of your Personal Data in certain circumstances such as establishing the accuracy of your Personal Data, but you do not want to erase it, where you require us to hold the Personal Data to establish, exercise or defend legal claims etc.

Request transfer of your Personal Data

This enables you to request transfer of your Personal Data to you or (if technically feasible) any third party in a commonly used machine-readable format. Note that these rights only apply to Personal Data which you initially provided us. Certain Personal Data will need to be retained for administrative, legal, security or other legitimate business purposes.

Right to withdraw consent

This enables you to withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you.

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What we may need from you

We will handle your requests and rights in accordance with applicable law. This means there may be legal reasons why we cannot fulfil all requests. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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No fee required

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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Changes to this Policy

What are your rights as a California Resident

This Policy applies to residents of California as required under the California Consumer Privacy Act (“CCPA”). The below provides California residents the right to know the categories of Personal Data collected and whether Clearco disclosed your Personal Data for business purposes in the preceding twelve (12) months: