Privacy Policy

ClearSale LLC (“Us,” “We,” “ClearSale,” or “Our”) offers fully outsourced fraud-management solutions that provide merchants (“Merchant”) with a recommendation to either “approve” or “deny” transactions in order to prevent fraud (“Fraud Prevention Service” or the “Service”). Merchants integrate Our Fraud Prevention Service onto their eCommerce websites, mobile apps, Mail Order Telephone Order (MOTO) operations, or anywhere you, the consumer, may place an order with an Merchant (a “Sales Platform”). After the order is placed, the Sales Platform may require Us to process your personal data in order to satisfactorily provide Our services.

Our Privacy Policy (“Policy”) explains the privacy practices for Our Fraud Prevention Services. It describes how We collect, use, and share personal information, and the rights and options available to you under relevant and applicable data protection laws.

You are not required by law to provide Us with your personal data, but the Sales Platform may require this information to process the orders you place and to effectively perform Our services in the present and future. Please note that this Policy refers to ClearSale and therefore does not cover the practices or policies of any Merchants or any Merchant Sales Platform or any other third parties.

If you are a resident of the European Economic Area (EEA), the General Data Protection Regulation (GDPR) affords you the following rights related to your personal data:

• The right to access your data personal data.
• The right to rectify your data if any part is inaccurate or incomplete.
• The right to object to Our processing of your personal data.
• The right to restrict Our processing of your personal information.
• The right to have your personal data deleted from Our servers.
• The right to receive a copy of the information We have on you in a structured, machine-readable, and commonly used format (data portability).
• The right to withdraw your consent at any time in cases where ClearSale relied on your consent to process your personal data.

You also have the right to file a complaint with a Data Protection Authority concerning Our collection and use of your Personal Data. For more information, please contact your local Data Protection Authority in the EEA.

You may access, update, or request the deletion of your Personal Data directly within your account settings. If you are unable to perform these actions yourself or if you would like to exercise any of your other rights or learn more about your personal data in our possession, please contact Us by email at contact@clear.sale or by phone at +1 (786) 888-4584.

Be advised that We will require confirmation of your identity before responding to such requests.

This section of Our Privacy Notice only applies to residents of California.

If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires Us to specifically inform you what personal data We collect from you, how We use them, and with whom We share them and why. We are also compelled to disclose whether or not we sell or will sell your personal data to any third parties.

The personal data We collect from you is provided below along with a detailed explanation of Our objectives when collecting this data. In addition, more specific information on with whom we share this information and why is also included herein. Finally, We do not sell any personally identifiable information nor do We share any information related to your location or online activities, whether through cookies or any other online tools, except for those purposes specifically defined in the Analytics section below.

We will not discriminate against you for exercising any of your CCPA rights. We will not deny you any services, charge you a different price, or provide a different quality of service because of your decision to exercise your consumer rights under the CCPA. However, We may offer you certain financial incentives permitted under the CCPA that may result in different prices, rates, or quality levels. Any incentives program involving your personal data will include a description of its most significant features and will necessarily require your express consent, which you may revoke at any time.

You may authorize another person (an “Agent”) to submit a request on your behalf. Be advised that before completing any such requests, and in addition to Our identification validation process, We will need to confirm that your Agent has been authorized by you to request information on your behalf and this may cause a delay in fulfilling your request.

We collect several types of data when you place an order on a Sales Platform or when you contact or communicate with Us, such as your name, email address, physical address, the items you purchased, the price(s) you paid, shipping information, and (if you have one) basic information from your account on the Sales Platform. We also collect basic information on your payment and billing method. However, We will not collect, store, or otherwise preserve your complete credit card number.

We may also collect information on how the Sales Platform is accessed and used (“Usage Data”). This Usage Data may include but is not limited to your computer’s Internet Protocol (IP) address, browser type, browser version, which of Our Service pages you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, location data, and other diagnostic data.

If you have provided a Merchant or the Sales Platform with access to information on third-party platforms (including social networks), then We may also receive the same access permissions to the information that you made public. In some circumstances, We may combine yours with other information acquired from publicly available data sources or contract with third parties for purposes of cross-referencing this information. Some of these third-party providers may use the data We share with them for their own purposes, in accordance with their own terms and conditions.

If you contact Us with any questions or complaints, or if We contact you to confirm any transactional data, We will collect the information related to your inquiry and verify your identity. This may include but is not limited to your name, email address, physical address, telephone number, and other contact information.

We collect the information from your transactions, including information on your device, geolocation, cross-referenced data, and other analytical points. We use this information first and foremost to analyze whether or not the transaction is fraudulent.

We have a lawful interest in collecting and processing your information, because the purpose is to prevent fraudulent transactions, and this interest extends to include Our third-party service providers who assist Us in providing these services. However, there may be times when we ask you to explicitly consent to the processing of certain personal data on Our Sales Platform. Should this ever be the case, We will notify you of the specific purpose or purposes for this processing and will not proceed without your express authorization.

Specifically, We use the information We collect from you for the following purposes:

• To improve and enhance Our Fraud Prevention Service and develop new services;
• Statistical analyses of consumer activities;
• To handle your requests and complaints;
• To enforce this Policy and prevent misuse of Our Fraud Prevention Service; and
• Any other action that may be mandated by law or undertaken to protect Our legal rights and property and/or those of third parties.

We may share pieces of your personal data with a Merchant with whom your transaction was made. We may do this is to review or audit your transaction if it had been previously flagged or marked as potentially fraudulent or for other similar reasons.

We may also share your personal data with Our corporate group entities, but their use of such data shall always be in compliance with this Policy. Your data may also be shared if Our Fraud Prevention Services are reorganized to operate within a different framework or through another legal structure or entity, such as due to a merger or acquisition.

Your information, including your personal data, may be transferred to – and maintained on – computers located outside your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. Be advised that ClearSale is and will remain fully compliant with the GDPR, CCPA, and the EU-US and US-Swiss Privacy Shield Frameworks, and other data processing laws in this regard, ensuring your personal data will always be safeguarded.

If you are located outside the United States and choose to provide information to Us, please note that We may transfer this information, including your personal data, to the United States and process it here.

We will take all steps reasonably necessary to ensure that your data are treated securely and in accordance with this Privacy Policy, and to not transfer your Personal Data to any organization unless adequate controls are in place, or to any country unless such country is an EU Member State or Third Country, as this term is defined by the GDPR.

Under certain circumstances, We may be legally required to disclose your personal data in response to a court order or demand from a state or federal government agency.

We may further disclose your personal data in the good faith belief that such disclosure is necessary to:

• Comply with a legal obligation.
• Protect or defend Our rights or property.
• Prevent or investigate potential wrongdoing in connection with the Service.
• Protect the personal safety of users of the Service or the general public.
• Protect ClearSale against legal liability.

The security of your data is important to Us, but bear in mind that no Internet transmission or electronic storage medium is 100% secure. While We strive to use commercially acceptable means to protect your personal data, We cannot guarantee their absolute security.

Our Service does not include the collection of any personal data from anyone under the age of 16 (“Child” or “Children”). Accordingly, We do not knowingly collect personally identifiable information from Children. If you are a parent or guardian and you discover that your child has provided Us with his or her personal data, please contact Us. If We discover that We have collected personal data from Children without confirmed parental consent, We will immediately remove that information from Our servers.

We may update Our Privacy Policy from time to time. When an update is made, we will inform you either via email or place a conspicuous notice on Our Service, and We will then update the “effective date” at the top of this Privacy Policy. Changes to this Privacy Policy become operative as of the moment they are posted on this page. Our current Privacy Policy may be viewed at: https://www.clear.sale/privacypolicy/

This Privacy Policy shall be exclusively governed by and construed in all respects under the laws of the State of Florida, without giving effect to any choice-of-law or conflict-of-law provisions. Any and all legal claims, suits, or actions that arise in connection with this Privacy Policy or with the breach thereof shall be submitted to the jurisdiction of the courts of Miami-Dade County, Florida.

If you have any questions about this Privacy Policy, please contact Us:

By email: contact@clear.sale

By phone number: +1 (786) 888-4584

WEBSITE PRIVACY POLICY

ClearSale LLC (“Us,” “We,” or “Our”) operates the www.clear.sale website (the “Website”). This purpose of this page is to inform you of Our policies regarding the collection, use, and disclosure of personal data when you use Our Website and the options concerning such data.

We are committed to communicating with you in a professional manner and protecting your confidential information. We use the information you provide (name, address, phone number, email, etc.) to contact you and share information about Our products/services. We will not share your information with any third party outside of Our organization, other than as necessary to fulfill any request you may have. We do not sell, trade, or rent your personal information to others.

By using the Website, you agree to the collection and use of your personal information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used herein have the same meaning as those in Our Terms and Conditions, which are accessible at www.clear.sale’.

If you are a resident of the European Economic Area (EEA), the General Data Protection Regulation (GDPR) affords you the following rights related to your personal data:

• The right to access your data personal data.
• The right to rectify your data if any part is inaccurate or incomplete.
• The right to object to Our processing of your personal data.
• The right to restrict Our processing of your personal information.
• The right to have your personal data deleted from Our servers.
• The right to receive a copy of the information We have on you in a structured, machine-readable, and commonly used format (data portability).
• The right to withdraw your consent at any time in cases where ClearSale relied on your consent to process your personal data.

You also have the right to file a complaint with a Data Protection Authority concerning Our collection and use of your Personal Data. For more information, please contact your local Data Protection Authority in the EEA.

You may access, update, or request the deletion of your Personal Data directly within your account settings. If you are unable to perform these actions yourself or if you would like to exercise any of your other rights or learn more about your personal data in our possession, please contact Us by email at contact@clear.sale or by phone at +1 (786) 888-4584.

Be advised that We will require confirmation of your identity before responding to such requests.

This section of Our Privacy Notice only applies to residents of California.

If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires Us to specifically inform you what personal data We collect from you, how We use them, and with whom We share them and why. We are also compelled to disclose whether or not we sell or will sell your personal data to any third parties.

The personal data We collect from you is provided below along with a detailed explanation of Our objectives when collecting this data. In addition, more specific information on with whom we share this information and why is also included herein. Finally, We do not sell any personally identifiable information nor do We share any information related to your location or online activities, whether through cookies or any other online tools, except for those purposes specifically defined in the Analytics section below.

We will not discriminate against you for exercising any of your CCPA rights. We will not deny you any services, charge you a different price, or provide a different quality of service because of your decision to exercise your consumer rights under the CCPA. However, We may offer you certain financial incentives permitted under the CCPA that may result in different prices, rates, or quality levels. Any incentives program involving your personal data will include a description of its most significant features and will necessarily require your express consent, which you may revoke at any time.

You may authorize another person (an “Agent”) to submit a request on your behalf. Be advised that before completing any such requests, and in addition to Our identification validation process, We will need to confirm that your Agent has been authorized by you to request information on your behalf and this may cause a delay in fulfilling your request.

Website: This refers to the www.clear.sale website operated by Us.

Personal Data: Refers to data about a living individual who can be identified from those data (or from data and other information either in Our possession or likely to come into Our possession).

Usage Data: Usage Data are automatically collected data either generated by the use of the Website or from the Website infrastructure itself (e.g., the duration of a page visit).

Cookies: Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller: Refers to the natural or legal person who, either alone or jointly with others, determines the purposes and manner in which any personal data is, or will be, processed. For the purpose of this Privacy Policy, We are the Data Controller of your Personal Data.

Data Processors (or Website Providers): A Data Processor (or Website Provider) refers to any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Website Providers to process your data more effectively.

Data Subject (or User): A Data Subject (or User) is any living individual who uses Our Website and is the subject of Personal Data.

We collect several different types of information in order to provide and improve Our Website. While you are using Our Website, We may ask you to supply certain personally identifiable information that can be used to contact or identify you. This personally identifiable information may include, but is not limited to:

• Your first and last name
• Your email address
• Your phone number
• Address, City, State, Province, ZIP/Postal code

This is your Personal Data. We may use your Personal Data to send you newsletters, marketing or promotional materials, or other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send.

We may also collect information concerning how the Website is accessed and used, which is your Usage Data. This Usage Data may include information such as your device’s Internet Protocol (IP) address, browser type, and browser version, as well as the pages you visit on Our Website, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

We may use and store information about your location if you give Us permission to do so, which is called your Location Data. We use this data to provide and enhance features of Our Website and improve and customize Our Website. You may enable or disable your Location Data at any time while using Our Website through your device settings.

We use cookies and similar tracking technologies to monitor your activity on Our Website and store certain information. Cookies are files with small amounts of data that may include an anonymous unique identifier. These cookies are sent to your browser from a website and stored on your device. Other tracking technologies include beacons, tags, or scripts, which are used to collect and track data and improve and analyze the performance and layout of Our Website.

You can direct your browser to refuse all cookies or indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of Our Website.

Below are some examples of Cookies We use:

• Session Cookies. We use Session Cookies to operate Our Website. These cookies are used to keep track of your movements from page to page so you do not get asked to enter the same information you have already given.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings will you engage Our Website.
• Security Cookies. We use Security Cookies for security purposes, such as authenticating users, preventing the fraudulent use of login credentials, and protecting user data from unauthorized parties.

We use the collected data for numerous purposes, such as:

• To provide and maintain Our Website.
• To notify you about changes to Our Website.
• To allow you to participate in the interactive features of Our Website when you choose to do so.
• To provide customer support.
• To analyze or collect valuable information so that We can improve Our Website.
• To monitor the usage of Our Website.
• To detect, prevent, and address technical issues on Our Website.
• To send you news, special offers, or general information about other goods, services, or events We offer and that are similar to those you have already purchased or enquired about, unless you have opted out of receiving such information.

We may also request your permission to use your personal data in other ways, which will be subject to your express written consent.

We do not support Do Not Track (DNT), which is a preference you can set in your web browser to inform websites that you do not want your online actions monitored. You can enable or disable the DNT feature by visiting your web browser’s Preferences or Settings page.

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy and retain and use your Personal Data to the extent necessary to comply with Our legal ore regulatory obligations, resolve disputes, or enforce Our legal agreements and policies. We will also retain Usage Data for internal analysis purposes. Usage Data are generally retained for a shorter period of time, except when the data are used to strengthen the security or to improve the functionality of Our Website, or when We are legally required to retain this data for longer time periods.

We may employ Website Providers to facilitate and maintain Our Website, to carry out other Website-related services, or to assist Us in analyzing how Our Website are used. These Website Providers will have access to your Personal Data only to perform these tasks on Our behalf and are legally bound to not disclose or use it for any other purpose.

We may also share non-personally identifiable information with trusted third-party partners to provide website-related services to Us, and these partners will also be legally bound to the provisions of this Privacy Policy at all times. Any data processing conducted by the above third parties will be governed at all times by a data processing agreement to preserve your statutory data protection rights.

We may also use Website Providers to monitor and analyze the use of Our Website.

Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of Our Website. These data are shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its advertising network. You can opt out of having your activity on the Website made available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visit activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en.

Behavioral Remarketing: We use remarketing services to advertise on third-party websites after you have visited Our Website. We and Our third-party vendors use cookies to inform, optimize, and serve ads based on your past visits to Our Website.

Google AdWords: Google AdWords remarketing services are provided by Google Inc.

You can opt out of the Google Analytics Display Advertising and customize Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads.

Google also recommends installing the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout) for your web browser. Google Analytics Opt-out Browser Add-on allows visitors to avoid their data from being collected and used by Google Analytics.

For more information on Google’s privacy practices, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en.

Facebook: Facebook remarketing services are provided by Facebook Inc.

you can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950.

To opt out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217.

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt out of Facebook and other participating companies through the Digital Advertising Alliance in the USA (http://www.aboutads.info/choices/),, the Digital Advertising Alliance of Canada in Canada (http://youradchoices.ca/), or the European Interactive Digital Advertising Alliance in Europe (http://www.youronlinechoices.eu/), or opt out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation.

Our Website may contain links to other sites that are not operated by Us. If you click on a third-party link, you will be directed to that third party’s website. We strongly advise you to review the privacy policies of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

You have the ability to opt out of receiving marketing communications from Us at any time. You can opt out by either changing your email preferences or using the link provided at the bottom of each email message. You may not opt out of administrative emails (e.g., emails about your transactions or policy changes) while you are a registered user.

We do not send emails to anyone without permission and We do not sell or rent email addresses to any unauthorized third party. If you believe that you have received an unsolicited email from Us, please email Us at contact@clear.saleand We will investigate the matter for you.

The information contained on the Website is for general information purposes only. ClearSale assumes no responsibility for errors or omissions in the content of the Website. In no event shall ClearSale be liable for any special, direct, indirect, consequential, or incidental damages or any damages whatsoever, whether in contract, negligence, or other tort, arising out of or in connection with the use of the Website or the content thereon. ClearSale reserves the right to add, delete, or modify the content of the Website at any time without prior notice. ClearSale does not warrant that the Website is free of viruses or other harmful components.