Clara Capital (hereinafter “Company”) is dedicated to protecting your privacy and providing you with the highest level of service. This Policy explains what the Company does to keep information about you private and secure. This Policy covers only information that you provide to the Company or that it obtains about you from companies that you have chosen to do business with.
Please read this Policy carefully and contact us if you have any questions.
Personal Information We Collect
The personal information we collect about you comes from the following sources:
· Information we receive from you, such as your name, address, and telephone number, or other information that you provide to us over the phone or in documents or applications,
· Information about your transactions, such as your account balances with your creditors, payment histories, account activity, and all other information that may be contained in your credit card statements or other reports relating to your debt, and
· Information we receive from consumer reporting agencies and other sources, such as your credit bureau reports, collection agency reports or other communications, and other information relating to your payment histories, creditworthiness, annual income, or ability to satisfy your obligations.
We will not sell or transfer your personal information to third parties without your consent. We may disclose such information in order to effect or carry out any transaction that you have requested of us or as necessary to complete our contractual obligations with you. We may also share your information with service providers that perform business operations for us, companies that act on our behalf to market our services, or others only as permitted or required by law, such as to protect against fraud or in response to a subpoena. We may also share or transfer our information in the event we transfer or sell your account or our business assets to another provider.
By carrying out those services, we may disclose your information, as we see fit and as permitted by law, to your creditors, credit card companies, collection agencies, banks, and other entities and individuals specifically necessary to effect, administer and perform our services.
Your Choices/Opt-out
We provide you the opportunity to ‘opt-out’ of having your personally identifiable information used for certain purposes. By providing information to the Company you are consenting to the collection, use and disclosure of such personal information in the manner described in this privacy policy. We provide you the opportunity to withdraw your consent when such information is collected.
Such consent may be withdrawn by calling the telephone number provided below or may be done in writing/email and sent to our customer service department at the following physical address or email address:
Clara Capital
575 Underhill Blvd, Suite 205 Syosset, NY 11791
Main Office: 1 (877) 505-8884
Effective Date: July 6, 2023
This Cookie Policy describes the use of cookies and similar tracking technologies by Clara Capital LLC(“Company,” “we,” “us,” or “our”) on our website. By accessing or using our website, you consent to the use of cookies as described in this policy.
Introduction
1.1 Cookies are small text files that are placed on your device (computer, tablet, mobile phone, or any other device with internet access) when you visit our website. Cookies allow us to recognize your device and gather information about your browsing preferences and activities.
1.2 This Cookie Policy applies to our website (www.claracap.com) and any other website or online service operated by Clara Capital LLC that links to this Cookie Policy (collectively referred to as the “Site”).
Types of Cookies Used
2.1 We use the following types of cookies on our Site:
a) Essential Cookies: These cookies are necessary for the operation of our Site. They enable you to navigate through the website and use its features. Without these cookies, certain services on our Site may not be available to you.
b) Analytical/Performance Cookies: These cookies help us understand how visitors interact with our Site by collecting information about the number of visitors, the pages they visit, and the links they click. We use this information to improve the performance and design of our Site.
c) Functionality Cookies: These cookies allow our Site to remember choices you make (such as your username, language, or region) and provide enhanced features. They may also be used to provide services you have requested, such as live chat support.
d) Advertising/Targeting Cookies: These cookies are used to deliver relevant advertisements to you and measure the effectiveness of our advertising campaigns. They track your browsing habits and help us serve personalized content and ads based on your interests.
e) Social Media Cookies: These cookies enable you to share content from our Site through social media platforms or track your interaction with social media plugins.
Third-Party Cookies
3.1 We may also allow third-party service providers, such as analytics companies and advertisers, to place cookies on our Site to collect information about your online activities. These third-party cookies are subject to the privacy policies of the respective companies and are not controlled by us.
3.2 We may use third-party analytics tools, such as Google Analytics, to gather and analyze information about how you interact with our Site. These analytics providers may use cookies and similar technologies to collect and process information about your use of the Site. This information is used to compile reports and help us improve the Site’s functionality and user experience.
Your Cookie Choices
4.1 Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies or receive a notification when a cookie is being sent. However, please note that blocking or deleting cookies may impact your ability to use certain features of our Site.
4.2 You can manage your cookie preferences and opt-out of certain types of cookies by adjusting the settings in your browser or using the opt-out mechanisms provided by the third-party service providers we use. Please refer to the relevant third-party’s privacy and cookie policies for more information.
Updates to this Cookie Policy
5.1 We may update this Cookie Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. Any updates will be posted on our Site with a revised “Effective Date” at the top of this page.
Contact Us
6.1 If you have any questions or concerns about our use of cookies or this Cookie Policy, please contact us at:
Clara Capital
Address: 6901 Jericho Tpke. Ste 215 Syosset, NY 11791
Phone: 1 (888) 395-3563
How We Protect Your Information
We train our employees to protect all customer information. We maintain physical, electronic and procedural controls that comply with government standards. We authorize our employees, agents and contractors to get information about you only when they need it to do their work with us. You can help to maintain the security of your online transactions by not sharing your personal information or password with anyone. Remember, no method of transmission over the Internet, or method of electronic storage, is 100% secure.
This Policy applies to current and former customers. If you have any questions, please contact Clara Capital at:
575 Underhill Blvd, Suite 205 Syosset, NY 11791
Main Office: 1 (877) 505-8884
NOTICE TO CALIFORNIA RESIDENTS
The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.
The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “NOTICE TO CALIFORNIA RESIDENTS” section we will refer to this information as “Personal Information.”
Notice at Collection of Personal Information
We currently collect and, in the 12 months prior to the Last Updated date of this Privacy Policy, have collected the following categories of Personal Information:
- Identifiers (name, postal address, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number)
- Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology)
- Telephone number
- Signature
- Bank account number
- Other financial information including bank routing number, income information, bank account history, transaction balances, transaction parties, payment history, overdraft history, voided checks, bank statements, and gross revenue information
- Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement)
- Geolocation data
- Commercial information (records of personal property, products or services purchased)
- Professional or employment-related information (including employment history)
- Characteristics of protected classifications under California or federal law (age (40 and older)
- Audio or similar information (recordings for monitoring and training purposes)
- Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
We collect Personal Information directly from California residents and from lenders, credit reporting agencies, and third-party data providers. We do not collect all categories of Personal Information from each source.
In addition to the purposes stated above in the Section “HOW WE USE YOUR INFORMATION” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
- Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
- Debugging to identify and repair errors that impair existing intended functionality
- Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us, provided that your Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, providing financing, or providing similar services
- Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the Personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with Personal Information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of a service and to improve, upgrade, or enhance the service
- Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction
Sale, Sharing, and Disclosure of Personal Information
The CCPA defines “sale” as the transfer of Personal Information for monetary or other valuable consideration. Although we do not “sell” Personal Information as that term may be commonly interpreted, we engage in online activities that may constitute a sale or a share of Personal Information under California law. This may include showing you advertisements on other websites.
The following table identifies the categories of Personal Information that we sold or shared to third parties in the 12 months preceding the Last Updated date of this Privacy Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:
Category of Personal Information
Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology)
Categories of Third Parties
Advertising network; data analytics provider
We shared Personal Information to third parties to advance our commercial and economic interests.
The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated date of this Privacy Policy and, for each category, the categories of recipients to whom we disclosed Personal Information:
Category of Personal Information
Identifiers (name, postal address)
Clara Capital and subsidiaries; business partners; data storage providers; independent sales organizations; banks; third-party collection agency
Identifiers (email address)
Telephone number
Signature
Bank account number
Other financial information including bank routing number, income information, bank account history, transaction balances, payment history, overdraft history, and gross revenue information
Geolocation data
Commercial information (records of personal property and personal credit information)
Professional or employment-related information (including employment history)
Characteristics of protected classifications under California or federal law (age (40 and older)
Audio or similar information (recordings for monitoring and training purposes)
Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, behavior, and abilities
Categories of Recipients
Clara Capital and subsidiaries; business partners; data storage providers; independent sales organizations
Identifiers (Social Security number, driver’s license number, passport number)
Clara Capital and subsidiaries; data storage providers; security, anti-fraud, and verification providers;
Clara Capital and subsidiaries; business partners; data storage providers; independent sales organizations; third-party collection agency
Clara Capital and subsidiaries; business partners; data storage providers; security, anti-fraud, and verification providers
Clara Capital and subsidiaries; business partners; data storage providers; lenders; banks; third-party collection agency
Clara Capital and subsidiaries; business partners; data storage providers; independent sales organizations; third-party collection agency
Data storage providers; security, anti-fraud, and verification providers
Clara Capital and subsidiaries; business partners; data storage providers; security, anti-fraud, and verification providers
Clara Capital and subsidiaries; business partners; data storage providers; security, anti-fraud, and verification providers; independent sales organizations
Clara Capital and subsidiaries; data storage providers; security, anti-fraud, and verification providers
Customer support providers; security, anti-fraud, and verification providers
Security, anti-fraud, and verification providers
We disclosed Personal Information for the following business or commercial purposes:
- Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, and providing financing
- Advancing our commercial or economic interests
We do not knowingly collect, sell, or share the Personal Information of consumers under 16 years of age. We do not use Sensitive Personal Information for purposes other than those the CCPA and its regulations allow for.
Retention of Personal Information
We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.
Your Rights
If you are a California resident, you have the following rights with respect to your Personal Information:
- The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
- The right to delete Personal Information that we collected from you, subject to certain exceptions;
- The right to correct inaccurate Personal Information that we maintain about you;
- If we sell or share Personal Information, the right to opt out of the sale or sharing;
- If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
- The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.
How to Submit a Request to Know, Delete, and/or Correct
You may submit a request to know, delete, and/or correct by emailing us at support@claracap.com or by calling us toll free at 1-888-395-3563.
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.
Our Process for Verifying a Request to Know, Delete, and/or Correct
We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.
We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable.
For requests to access categories of Personal Information and for requests to delete or correct Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
For requests to access specific pieces of Personal Information or for requests to delete or correct Personal Information that is sensitive and poses a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, we may request that you submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.
To verify your request, we will match the personal information you submit with the information we have about you. If we cannot conclude your information matches what we have, you may be directed to contact us with further instructions to assist us in responding to your request. To verify your request, we may ask you to submit the following information:
- Your first and last name;
- The last 4 digits of your Social Security number;
- Your date of birth; and
- The name of your business
Right to Opt Out of Sale or Sharing of Personal Information
If you are a California resident, you have the right to direct us to stop selling or sharing your Personal Information.
You may submit a request to opt out of sales by emailing support@claracap.com: “Do Not Sell or Share My Personal Information.” If you have enabled privacy controls on your browser (such as a plugin), we will also treat that as a valid request to opt out.
