Privacy Policy of ClearNym

a) Information You Provide Directly

• Full name, email address, phone number, date of birth, and other contact details when creating an account.
• Identifying information such as name(s), aliases, email address(es), phone number(s), and date of birth for our removal Services.
• Mobile phone number for two-factor authentication, processed by us and our trusted service providers.
• Limited payment information such as payer’s ZIP/postal code, IP address, card network type (e.g., Visa, MasterCard), last four digits of the card, and expiration date received from payment processors. No full card numbers or sensitive payment data are stored by ClearNym.
• Personal and business information for participants in our affiliate program as detailed in the affiliate agreement.

b) Information Collected Automatically

• Device and usage data such as IP address, device identifiers, browser type and version, screen resolution, timezone, operating system, and device model.
• Behavioral data including referring URLs, landing pages, number of clicks, pages visited, duration and frequency of visits, error logs, and other analytics.
• Data collected by third-party tools such as Google Analytics, Facebook Ads, Microsoft Ads, Hotjar, etc., via cookies and similar technologies.

4.1 Identity Protection and Insurance Benefit Data

If you enroll in, activate, access, or use an identity protection membership, identity theft protection feature, identity fraud expense reimbursement benefit, cash recovery benefit, investment account cash recovery benefit, health savings account cash recovery benefit, or related insurance benefit made available through ClearNym, we may collect, use, disclose, and retain additional Personal Information as necessary to provide, activate, verify, administer, support, and process that benefit.

This information may include your name, email address, phone number, mailing address, date of birth, account identifier, membership status, selected plan, payment status, activation status, coverage tier, benefit option, applicable membership period, government identification information, Social Security number or other identification numbers, claim forms, proof of loss, receipts, police reports, notices, summons, legal papers, account records, financial institution records, credit reports, credit bureau communications, account statements, documentation showing unrecoverable funds, and correspondence with merchants, creditors, collection agencies, financial institutions, law enforcement, attorneys, accountants, investigators, insurance providers, policyholders, insurance administrators, and claims administrators.

Depending on the claim or benefit, this information may also include information about bank accounts, credit cards, debit cards, prepaid cards, investment accounts, brokerage accounts, retirement accounts, health savings accounts, flexible spending accounts, health reimbursement accounts, tax records, medical records, driver’s licenses, passports, and other documents or accounts involved in an identity fraud event, stolen identity event, unauthorized electronic fund transfer, data breach, or related claim.

If your plan includes or may include coverage for a spouse, domestic partner, family member, child, dependent, or household member, we may collect and process information about those individuals as necessary to determine eligibility, administer the benefit, support claims, prevent fraud, and comply with applicable legal, contractual, insurance, and recordkeeping obligations. By submitting information about another person, you represent that you have the authority to provide that information and to authorize its collection, use, disclosure, and retention as described in this Privacy Policy.

We use Identity Protection and Insurance Benefit Data to:

• determine eligibility for the applicable membership, plan, feature, or benefit;
• activate, administer, maintain, and support the benefit;
• verify your identity, account status, plan status, payment status, coverage tier, and membership eligibility;
• route, support, investigate, process, verify, or administer claims;
• communicate with you about your membership, benefit, claim, required documentation, deadlines, policy changes, termination, or other benefit-related matters;
• prevent, detect, investigate, and respond to fraud, misuse, unauthorized activity, security incidents, or unlawful conduct;
• comply with legal, regulatory, contractual, insurance, tax, audit, reporting, and recordkeeping obligations;
• enforce our Terms of Service, benefit terms, membership terms, and other applicable agreements; and
• protect the rights, property, safety, and security of ClearNym, our users, insurers, policyholders, insurance administrators, claims administrators, service providers, and others.

We may disclose Identity Protection and Insurance Benefit Data to third parties involved in providing, activating, administering, verifying, supporting, investigating, or processing the applicable membership, feature, claim, or insurance benefit. These parties may include:

• the applicable insurer, underwriter, policyholder, insurance administrator, claims administrator, identity protection program provider, and their affiliates;
• American Bankers Insurance Company of Florida, an Assurant company;
• Array US Inc, Identity Theft Guard Solutions, Inc. d/b/a ARRAY US, INC., and their respective affiliates;
• financial institutions, banks, credit unions, credit card issuers, debit card issuers, prepaid card issuers, investment account providers, brokerage firms, retirement account providers, health savings account custodians or administrators, credit reporting agencies, credit grantors, merchants, creditors, and collection agencies;
• law enforcement agencies, courts, regulators, governmental authorities, attorneys, accountants, investigators, expert witnesses, and other professional advisers;
• vendors, processors, service providers, technology providers, hosting providers, customer support providers, compliance providers, fraud prevention providers, analytics providers, and other third parties who assist us in operating the Website, providing the Services, or supporting the benefit; and
• other parties where disclosure is reasonably necessary to administer the benefit, process or verify a claim, recover losses, prevent fraud, comply with law, enforce applicable terms, or protect rights, safety, and security.

Some of these parties may process your information as independent controllers or businesses under their own privacy notices. Others may process information on our behalf as service providers or processors. The applicable insurer, underwriter, policyholder, insurance administrator, claims administrator, and identity protection program provider may have separate privacy notices that apply to their collection, use, disclosure, and retention of your information.

ClearNym does not decide insurance claims. Claim decisions are made by the applicable insurer or claims administrator under the applicable policy, Summary of Benefits, claim procedures, and insurance benefit terms.

We do not use insurance claim information for targeted advertising. We do not sell insurance claim information for monetary consideration. We may disclose Identity Protection and Insurance Benefit Data only as described in this Privacy Policy, as directed by you, as necessary to provide or administer the benefit, or as permitted or required by law.

We retain Identity Protection and Insurance Benefit Data for as long as reasonably necessary to provide the benefit, administer your membership, support claims, resolve disputes, prevent fraud, comply with legal, regulatory, contractual, insurance, tax, audit, and recordkeeping obligations, and enforce our agreements. Because insurance and claim records may be subject to legal, regulatory, contractual, audit, fraud-prevention, and claim administration retention requirements, we may retain certain information after your account, membership, or benefit ends, as permitted or required by law.

Categories of Personal Information Collected

Within the prior 12 months, we may have collected the following categories of Personal Information under the California Consumer Privacy Act (CCPA). Retention is as long as your account remains active unless you request earlier deletion:

Sensitive Personal Information is used only as permitted under the CCPA, such as verifying identity or performing requested services.

If you enroll in, activate, access, or use an identity protection membership, identity fraud expense reimbursement benefit, cash recovery benefit, investment account cash recovery benefit, health savings account cash recovery benefit, or related insurance benefit, we may also collect and disclose additional categories of Personal Information and Sensitive Personal Information for the business and commercial purposes described in this Privacy Policy. These categories may include identifiers, government identification information, financial account information, insurance benefit information, claim information, documents submitted as proof of loss, police reports, credit report information, account statements, correspondence with financial institutions or creditors, and information about covered family members or household members.

We may disclose these categories of information to insurers, underwriters, policyholders, insurance administrators, claims administrators, identity protection program providers, financial institutions, credit reporting agencies, law enforcement agencies, regulators, attorneys, accountants, investigators, service providers, and other parties as necessary to verify eligibility, activate and administer the benefit, process or support claims, prevent fraud, comply with law, enforce applicable terms, and protect rights, safety, and security.

We do not use insurance claim information for targeted advertising and do not sell insurance claim information for monetary consideration.

Sources of Personal Information

Please refer to Section 2 “Information We Collect and How We Collect It.”