Clear Privacy Policy

Privacy Policy

Updated: November 10, 2023

This privacy policy (the "Privacy Policy") is designed to provide users ("you") of our websites, apps, software and other online services (the "Clear", "Service" or "Platform") with clear information relating to how TALENT ME TECHNOLOGY PTE.LTD. and its affiliates ("Talent Me" or "We") personal data or personal information ("Personal Information"). If you do not agree with this policy, you should not use the Service.

In this Privacy Policy, you will find the following information:

1. What is Personal Information and Who is the Provider and Controller?
2. Who are We?
3. What Personal Information Do We collect from you?
4. Cookies
5. Why and how do We use your Personal Information?
6. Who Do We Share Your Personal Information with?
7. Your Rights and Choices
8. Data Security and Data Retention
9. Data Transfers, Storage and Processing Globally
10. Modifications to the Privacy Policy
11. Contact Us
12. European Data Protection Specific Information
13. California Privacy Rights

1. What is Personal Information and who is the provider and controller?

2. Who are We?

TALENT ME TECHNOLOGY PTE.LTD. is a company established at 5001 Beach Road #07-37 Golden Mile Complex Singapore. For Clear, We has appointed a Data Protection Officer whom you can contact at clearaudio01@gmail.com for all matters relating to personal data, including in particular the exercise of your rights in relation to Clear's processing of your data.

3. What Personal Information Do We collect from you?

We collect your information in three ways: Information You Provide, Automatically Collected Information, and Information from Other Sources. More detail is provided below.

Information You Provide

• User Content. We may collect the content you create or publish through the Service, such as separated audio tracks, and the associated metadata (such as when, where, and by whom the content was created). Even if you are not a user, information about you may appear in content created or published by users on the Platform.
• Surveys, Research, and Promotions. We may collect information you provide if you choose to participate in a survey, research, promotion, contest, marketing campaign, or event conducted or sponsored by us.
• Information When You Contact Us. When you contact us, we may collect the information you send us, such as proof of identity or age, feedback or inquiries about your use of the Service or information about possible violations of our Terms of Service (our "Terms") or other policies.

Automatically Collected Information

• Technical Information, the certain device and network connection information we may collect when you access the Service. This information includes your device model, operating system, IP address, and system language. We also collect service-related, diagnostic, and performance information, including crash reports and performance logs. We automatically assign you a device ID and user ID. Where you log-in from multiple devices, we use information such as your device ID and user ID to identify your activity across devices to give you a seamless log-in experience and for security purposes.
• User-Generated Information, the information uploaded, provided, or created by users while using the Service, including information about the content you view, the duration and frequency of your use, your engagement with other users, your search history and your settings.
• Content Characteristics and Features, the characteristics and features we detect and collect about the videos, images, and audio recordings that are part of your User Content, for example, by identifying objects and scenery, the existence or location within an image of a face or other body parts; and the text of words spoken in your User Content. We do this, for example, for content moderation and to provide special effects such as separated audio tracks.
• Cookies, the tracking technology we use to operate and provide the Platform. To learn more about our use of cookies, please see Article 4 of this Policy. We will obtain your consent to our use of cookies where required by law.

Information From Other Sources

• Marketing Information, such as your mobile identifiers for advertising, your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications. Where required under applicable law, We will obtain your separate consent for sending you marketing information.
• Third Party Platforms and Partners, from which we may collect your personal information The personal information we collect is subject to this Privacy Policy. The information collected and stored by a third party remains subject to the third party's privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third party website and service. The third party may allow you to remove the application or feature, in which case we will no longer collect information about you through the application or feature, but we may retain the information previously collected in compliance with all applicable laws.
• Other Information, the information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

4. Cookies

Cookies are small text files that are placed on your device when you browse our Clear platform. We use Cookies for providing users with a simpler and easier-to-use personalized web experience. Cookies enables us to serve you better and faster, and to make your experience on Clear Service more personal.

For example, to make the login process of the Clear platform faster, you can choose to save the username in a Cookies. This will make it easier and faster to login into Clear Service next time. Cookies can help us to determine the webpages and content you are connected to, the time you spend on certain Clear Service and the Clear service you have chosen.

Using such technologies, we, our service providers, and our business partners may automatically log information about you, your computer or mobile device (if any), and activity over time occurring on or through the Services and other online services. We use them for the following purposes:

• Remember your identity. For example: Cookies and web beacons help us identify you as our registered user, or save your preferences or other information provided by you to us.
• Analyze your use of our services. We can use Cookies and web beacons to understand for which activities you use Talent Me Service, or which services or service is the most popular, We may request your consent prior to using Cookies and web beacons for these purpose.
• Advertising optimization. Cookies and web beacons help us to provide you with advertisements related to you based on your information instead of general advertising, We may request your consent prior to using Cookies and web beacons for these purpose.

If you consented to our use of cookies but later wish to opt out, you may change, at any time, your cookies preferences through the browser (if you access Clear Services via a browser) or user selection mechanism, you can use your browser settings in order to block the cookies. The following links provide instructions in order to manage your cookies preferences:

• Chrome: https://support.google.com/chrome/answer/95647?hl=en
• Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac
• Internet Explorer: http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies
• Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preference

In addition, if you do not want Google Analytics to be used in your browser, you can:

• Disable the Google Analytics browser add-on at https://tools.google.com/dlpage/gaoptout
• Opt-out through the Network Advertising initiative consumer opt-out system accessible at the following link: http://optout.networkadvertising.org/#!/

In addition, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers.

Moreover, you can use another online service enabling you to manage the advertisement cookies placed on your devices: http://www.youronlinechoices.com/.

5. Why and how do We use your Personal Information?

We may use the information we collect for a variety of purposes, such as the purposes outlined below:

• Providing the Service
• Communicating with You
• For Research and Development
• Maintaining and Enhancing the Safety, Security, and Stability of the Service
• Sharing Your Information with Third Party Platforms to Provide You with Features
• Legal Reasons Terms of Service
• With Your Consent

6. Who do We share your Personal Information with?

For the purposes referred to under this Privacy Policy, We may share your Personal Information with certain recipients. Such recipients will either act as another controller or as processor acting on behalf and upon our instructions.

The processors which We may share your Personal Information with are the following:

• Our Affiliates
• Third Party Service Providers
• Customer Communications and Insights Platforms. We may share email, app usage and interactions with our third-party customer communications platform provider for the following business purposes: performing services that allow us to communicate with you and administer your account as well as track your usage for our internal analytics.
• Internal Business Insights Platforms. Our third-party internal business analytics platform provides us with the tools to help us understand app usage and interactions and uncover insights that allow us to improve our product and features. We may share or make available unique user identifiers, IDFA, device id, IP address and app usage and events (such as when you subscribed to our services) with these providers for the following business purposes: performing services that allow us to (i) monitor and understand usage in order to enhance existing Services or develop new products and features and better understand our customers in order to market our products more effectively.
• Measurement and Data Partners. We also share Technical Information and Usage Information with third party measurement providers who help us measure advertising served on the Platform and help our advertisers determine how effective their ads have been.
• Other technology providers necessary to provide our services (including cloud storage and web hosting providers). We may make certain Automated Information and/or aggregate or non-personally identifiable information available for various purposes including monitoring network traffic to detect malicious actors and to protect against malware, fraud or other unlawful uses or activity.
• Marketing providers. We, or the third-party service providers we use to assist us with marketing our own products to you, may use the information we collect from you to provide advertisements and offers for our other products. Additionally, we may share certain information with Facebook that allows us to create Custom or Lookalike Audiences here. You may learn more about Facebook Lookalike Audiences here and about your off-Facebook activity and how to opt out of having such activity sent to Facebook ere. We encourage you to review Facebook's Privacy Policy. We may also use Google Ads and Google Analytics to advertise our products, and for remarketing and optimization purposes. For example, where individuals allow for personalized ads in their Google settings, we use Google Signals on our websites to target those interested in our products with advertisements. You may opt-out of the use of this tracking technology by visiting Google's Advertising and Privacy page or by interacting with our website cookie banners.
• Legal Purposes: We may disclose your Personal Information to any person or authority to comply with applicable law, respond to valid legal process, investigate or participate in civil discovery, litigation, or other adversarial legal proceedings, or investigate potential violations of or enforce our Terms of Service.
• With Consent: We may communicate your Personal Information to any other person subject to your prior consent.

Our Clear may contain links to third-party websites, tools or services. Those third parties have separate and independent privacy policies that you are invited to read carefully. This Privacy Policy does not apply to your use of such third-party sites, tools or services. We do not own or control those third parties, and We assume no responsibility or liability for their content and activities.

7. Your Rights and Choices

You can access and edit most of your profile information by signing into our Service. You can delete the User Content you uploaded. You may also be afforded certain rights under applicable laws, which may include the right to access, delete, update, or rectify your data, to be informed of the processing of your data, to file complaints with authorities, and potentially other rights.

Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our services may not be able to take account of your interests and preferences. If collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate.

If you have any questions on how to use the above tools, want to know about what rights you may have or want to exercise them, or have any requests, inquiries, or complaints, please contact us pursuant to the means mentioned in Article 12 of this Policy.

8. Data Security and Data Retention

Security of your information is important to us. We maintain appropriate technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods. However, you should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

We retain information for as long as necessary to provide the Service and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Service, and enhancing its safety, security and stability), and for the exercise or defense of legal claims.

Upon expiry of the applicable data retention period, We undertake to erase or irrevocably anonymize the relevant Personal Information.

9. Data Transfers, Storage and Processing Globally

The personal data we collect from you may be stored on a server located in United States, Singapore and Hong Kong, outside of the country where you live. We maintain major servers around the world to bring you our services globally and continuously.

We operate globally and may transfer your personal information our Affiliates or third parties in locations around the world for the purposes described in this Privacy Policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. These steps may include implementing standard contractual clauses which recognized by law, obtaining your consent, or other lawful means of transferring personal information.

When we transfer your information outside of the EEA, the UK, or Switzerland, we ensure it benefits from an adequate level of data protection by relying on:

• Adequacy Decisions: These are decisions from the European Commission under Article 45 GDPR (or equivalent decisions under other laws) where they recognize that a country offers an adequate level of data protection. We transfer your information as described in What Information We Collect to some countries with adequacy decisions.
• Standard Contractual Clauses: The European Commission has approved contractual clauses under Article 46 of the GDPR that allows companies in the EEA to transfer data outside the EEA. These (and their approved equivalent for the UK and Switzerland) are called standard contractual clauses. We rely on standard contractual clauses to transfer information to certain entities in our affiliates and third parties in countries without an adequacy decision.

10. Modifications to the Privacy Policy

We reserve the right to change this Privacy Policy at any time. When we update the Privacy Policy, we will notify you by updating the "Last Updated" date at the top of this policy and posting the new Privacy Policy and providing any other notice required by applicable law. We recommend that you review the Privacy Policy each time you visit the Platform to stay informed of our privacy practices.

11. Contact Us

If you have any requests, questions, comments, or concerns regarding this Privacy Policy or privacy practices, please contact our Data Protection Officer at clearaudio01@gmail.com.

12. European Data Protection Specific Information

Data Subjects Rights

If you are in the European Economic Area ("EEA"), Switzerland, or the United Kingdom ("UK"), You have various rights in relation to the processing of your Personal Information:

• Access to Personal Information processed concerning you
• Rectify inaccurate Personal Information
• Delete any Personal Information concerning you
• Restrict processing
• Receive your Personal Information provided to us in an interoperable format (data portability)
• Object to the processing on grounds relating to your particular situation

In order to exercise any of your rights, or if you have any other questions about our use of your Personal Information, please send a request at the contact details specified at the Article 12 of this Privacy Policy. We will reply your requests in 30 days, for complicated issues we may need a 60-day extension period. Please note that We may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to access the relevant Personal Information.

In any case, you also have the right to lodge a complaint with the competent data protection authority.

Legal Bases for Processing

We rely on the following legal bases when we process Personal Information about individuals in the EEA, Switzerland, or the UK:

• Contractual Necessity: We process Personal Information for the management of our relationship on the basis of the contract between Talent Me and you in order to provide you with the Clear and any online learning services that you request, send you communications related to your purchase, manage our relationship and carry out any related administration, etc.
• Consent: We rely on your prior consent, to send you marketing communications to promote our products and services, and invite you to events, and to store cookies on your device as described in the section specific to cookies. In this regard, please note that you have the right to withdraw your consent at any time (without calling into question the processing previously carried out) by sending a request at the contact details specified at the end of this Privacy Policy.
• Legal Obligations: We process Personal Information to comply with the legal obligations to which We are subject.
• Legitimate Interests: We process Personal Information based on our legitimate interests which consist in: (i) complying with non-EU laws and responding to requests from, and other communications with, competent public, governmental, judicial or other regulatory authorities; (ii) meeting our corporate and social responsibility commitments; and (iii) protecting our rights, property or security and the one of our clients. In this respect, please note that you have the right to be informed about how We have assessed that it is in our legitimate interest to collect your Personal Information for these purposes by sending a request at the contact details specified at the end of this Privacy Policy.

International Data Transfers

The personal data we collect from you is stored on a server located in United States, Singapore and Hong Kong. We maintain major servers around the world to bring you our services globally and continuously. These entities commit to processing information in compliance with applicable privacy laws and to implementing appropriate security measures to protect your information.

When we transfer your information outside of the EEA, the UK, or Switzerland, we ensure it benefits from an adequate level of data protection by relying on:

• Adequacy Decisions: These are decisions from the European Commission under Article 45 GDPR (or equivalent decisions under other laws) where they recognize that a country offers an adequate level of data protection. We transfer your information as described in What Information We Collect to some countries with adequacy decisions.
• Standard Contractual Clauses: The European Commission has approved contractual clauses under Article 46 of the GDPR that allows companies in the EEA to transfer data outside the EEA. These (and their approved equivalent for the UK and Switzerland) are called standard contractual clauses. We rely on standard contractual clauses to transfer information to certain entities in our affiliates and third parties in countries without an adequacy decision.

13. California Privacy Rights

California Consumer Privacy Act

The California Consumer Privacy Act of 2018 (CCPA) provides California residents the right to request:

• Disclosure of our practices: The categories of Personal Information we collect, the categories of sources from which the Personal Information is collected, our purpose(s) for collecting the Personal Information, and the categories of third parties with whom we have shared Personal Information.
• Access to specific pieces of your Personal Information we have collected.
• Deletion of any of your Personal Information we have collected.
• Opt out of "sale": That your Personal Information not be sold to third parties.

As required by the CCPA, we will not discriminate against you for exercising any of these rights.

You may exercise your rights by sending a request at the contact details specified at the Article 12 of this Privacy Policy. We will acknowledge receipt of your request within 10 business days, and provide a substantive response or notify you of the reason and extension period within 45 days. Under the CCPA, only you or an authorized agent may make a request related to your Personal Information. We must verify your identity to respond to certain requests. We may do so by requiring you to log into your account, provide information relating to your account or other additional information, or give a declaration as to your identity under penalty of perjury.

To opt out of the use of cookies on the Service for interest-based advertising purposes, follow the instruction mentioned in Article 4 of this Policy.

California's Shine the Light Law

California Civil Code Section 1798.83, also known as "Shine The Light" law, permits California residents to annually request, free of charge, information about the disclosure of their Personal Information (if any) to third parties for the third parties' direct marketing purposes in the preceding calendar year. If applicable, this information would include the categories of customer information, as well as the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To submit a request, you could contact us with the method mentioned in Article 12 in this Policy.