ClearSpend Privacy Policy

Effective Date: March 24, 2022

ClearSpend, Inc. (“ClearSpend,” “we,” “our,” or “us”), provides this Privacy Policy to describe how we collect, use, and share the information of individuals who visit our website at www.clearspend.com (the “Site”) or use the ClearSpend App (the “App”) (collectively the “Services”).  Information Collection When using our Services, you may voluntarily provide information about yourself, including your name, address, contact information, log-in credentials, and any other information you choose to provide.  For example, we collect this information when you join our email list, create an account, contact us, or interact with the Services for any purpose.  Through the provisioning of the Services, we may also collect bank account number, credit card number, transaction history, expenses, receipts, location of transactions, and invoices.  We may also request information to verify your identity or determine your creditworthiness, such as date of birth, social security number, drivers’ license, passport, or bank statement.  In order to provide our Services, we may also collect information about the ownership of certain corporate entities and information in relation to the authorized users of ClearSpend cards. This can include name, date of birth, social security number, address, contact information, and transaction history. We (and other entities) automatically collect information relating to your interactions with us and our Services, including browser type, IP address, pages visited and other activities through the Services, device type, MAC address, and time and date of visit, and other information we collect through the use of cookies and similar technology.  See the “Digital Advertising & Analytics” section of this Privacy Policy to learn more about the use of this information and the choices available to you.  

Information Use
We may use your information for any lawful purpose, including the following:

  • To provide services you or our customers request, including analytics based on inferences, determinations of creditworthiness, and account underwriting;
  • To develop case studies and marketing insights;
  • To verify your identity;
  • To prevent and detect fraud;
  • To provide multi-factor authentication and for data security purposes;
  • To respond to your inquiries, including questions about the Services;
  • To operate, personalize, and improve the Services, including for analytics purposes;
  • To send updates, promotions, and marketing materials that may be of interest to you;
  • To comply with the law and to maintain the security of our Services; or
  • With your consent, or as otherwise disclosed at the time information is collected.

Information Sharing
We may share the information we collect with other parties, including the following:

  • With the Bank as that term is defined in the General Terms and Conditions;
  • With third-party service providers who process information on our behalf, such as banking applications, payment processors, data hosting services, and email service providers;
  • With any affiliates or joint venture partners;
  • With third parties for marketing and advertising purposes;
  • With integrated applications at your request;
  • With government agencies, as required by law;
  • As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, including as part of a bankruptcy proceeding;
  • Pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law, to protect our rights or the rights of third parties, or to protect the safety or security of any person or entity;
  • With your consent or as otherwise disclosed at the time of data collection or sharing.

We may share information that has been de-identified or aggregated without limitation.  

Information Retention
We may retain information as long as necessary for transaction enablement, accounting, fraud prevention, and legal purposes or as set forth in our data retention schedule.

Digital Advertising & Analytics
We may partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms.  Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Services and other sites or apps over time, including information about relationships among different browsers and devices.  This type of advertising is known as interest-based advertising.ClearSpend adheres to the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles in connection with this interest-based advertising activity.  You may visit the DAA Webchoices tool at www.aboutads.info to learn more about this type of advertising and how to opt out of this advertising on websites by companies participating in the DAA self-regulatory program.  If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choices exercised through the DAA Webchoices tool.  Note that electing to opt out will not stop advertising from appearing in your browser or applications.  It may make the ads you see less relevant to your interests.  We may also work with third parties that collect data about your use of the Services and other sites or apps over time for non-advertising purposes.  ClearSpend uses Google Analytics and other third-party services to improve the performance of the Site and for analytics and marketing purposes.  For more information about how Google Analytics collects and uses data when you use our Site, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout. Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, our Site may not function as intended.

Third-Party Links and Tools
The Services may provide links to third-party websites or apps.  We do not control the privacy practices of those websites or apps, and they are not covered by this Privacy Policy.  You should review the privacy policies of other websites or apps that you use to learn about their data practices.

Your Choices
To opt out of our email marketing, you can use the link provided at the bottom of each marketing message or by visiting https://marketing.clearspend.com/hs/manage-preferences/unsubscribe-simple.  If you opt out of our email marketing, we will still send you messages related to our transactions and relationship with you, such as information about your account.To opt out of push notifications from the ClearSpend app, you can use controls provided by iOS and Android on your device.

Updating Your Information
When you have an account with us, you may review, change, or update your contact information by logging into your account.  

Changes to Our Privacy Policy
If our information practices change, we will post these changes on this page.  We encourage you to visit this page periodically to learn of any updates.

California Privacy Rights
This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA.  

Personal Information We Collect.  
In the preceding 12 months, we collected all categories of personal information described in the “Information Collection” section of this Privacy Policy about California consumers.  We do not sell personal information.

Categories of Sources. We collect personal information from the following categories of sources:

  • Consumers;
  • Payment processing partners;
  • Data analytics providers;
  • Credit reporting agencies;
  • Data brokers;
  • Service providers; and
  • Government entities

Why We Collect, Use, and Share California Information. We use and disclose the personal information we collect for our commercial and business purposes, as described in the “Information Use” section of this Privacy Policy.  

Recipients of California Personal Information.  We disclose the categories of personal information described in the “Information Collection” section of this Privacy Policy to the categories of third parties listed below for business purposes:

  • Payment processing partners;
  • Service providers;
  • Government entities;
  • Advertising networks;
  • Internet service providers;
  • Data analytics providers; and
  • Operating systems and platforms.

Your Rights Regarding Personal Information. California residents have certain rights with respect to the personal information collected by businesses.  We do not sell personal information. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

  • The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you; the categories of sources from which we collected personal information about you; our purposes for collecting or selling personal information about you; the categories of personal information about you that we have either sold or disclosed for a business purpose; and the categories of third parties with which we have shared personal information.
  • The right to request that we delete the personal information we have collected from you.
  • The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:
By email at privacy@clearspend.com or
By mail at: ClearSpend, Attn: Privacy Department, 9541 Julian Clark Ave, Suite 109-G, Charlotte, NC 28078.

Verification Process and Required Information. Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled.  We will require you to provide, at a minimum: your full name, email address, and mobile phone number.    

Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf by providing proof of such designation (e.g., Power of Attorney) via email or in writing as above.    

Minors’ Right to Opt In. We do not have actual knowledge that we sell the personal information of minors under 16 years of age.

Contact
If you have questions, comments, or concerns about this Privacy Policy, please contact us at privacy@clearspend.com.