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    Privacy Policy

    Last Revised: August 8, 2023

    We are ClearFP IP LLC, an Oregon limited liability company doing business as ClearFP and SomethingSmartAboutMoney.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 and somethingsmartaboutmoney.com), applications, platforms and any other ClearFP programs (collectively the "ClearFP Services").

    Information We Collect

    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.
    • 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.
    • 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.

    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. 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.

    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.

    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.

    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.

    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.

    Use for Internal Business Purposes

    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

    ClearFP discloses your PII as follows:

    • To Service Providers: We may share your PII with professional service providers that perform services on our behalf.
    • To Providers of Analytics and Targeted Advertising: We use Google Analytics and other analytics providers to help measure trends, performance and traffic, and to provide targeted advertisements.
    • 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 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 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.

    Accuracy and Maintenance of Your PII

    Accuracy: We will strive to ensure that your PII held by us, if any, is accurate. You may 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.

    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.

    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.

    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.

    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 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.

    Colorado, Connecticut, and Virginia

    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.

    • 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.
    • 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.

    Contact Us

    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.