This privacy notice is for RealClear LLC ("we," "us," or "our"), detailing the manners in which we may collect, store, utilize, and/or share ("process") your information during your interaction with our services ("Services"). This interaction encompasses when you:

Visit our website at https://www.realclear.com, or any of our websites that link to this privacy notice

Engage with us in related manners, including through sales, marketing, or events

Should you have any questions or concerns, going through this privacy notice will shed light on your privacy rights and options. If our policies and practices do not align with your preferences, we advise against using our Services. For any lingering questions or concerns, feel free to reach out to us at contact@realclear.com.

SUMMARY OF KEY POINTS

This summary encapsulates key points from our privacy notice. However, for more comprehensive insights on any of these topics, you can click on the link following each key point or navigate through our table of contents below to locate the section of interest.

What kind of personal information do we process? As you visit, utilize, or navigate our Services, we might process personal information based on your interaction with us and the Services, your preferences, and the products or features you engage with. Discover more about the personal information you disclose to us.

Do we process any sensitive personal information? We abstain from processing sensitive personal information.

Do we obtain any information from third parties? We do not acquire any information from third parties.

How do we handle your information? We manage your information to deliver, enhance, and manage our Services, interact with you, ensure security, prevent fraud, and comply with legal obligations. At times, with your consent, we might process your information for other purposes. We handle your information only when there's a valid legal basis for it. Uncover more about how we handle your information.

When and with whom might we share personal information? We may share information under certain circumstances and with specified third parties. Delve deeper into the scenarios and parties with whom we may share your personal information.

How do we safeguard your information? We have set up organizational and technical measures to secure your personal information. However, since no technology or electronic data transmission over the internet is entirely secure, we can't assure absolute security against unauthorized third parties who might bypass our security measures to unlawfully access, collect, or alter your information. Learn more about our security measures.

What rights do you have? Depending on your geographical location, the governing privacy laws might grant you certain rights concerning your personal information. Explore your privacy rights.

How can you exercise your rights? The most straightforward way to exercise your rights is by submitting a data subject access request or by reaching out to us. We will evaluate and respond to any request in compliance with the applicable data protection laws.

INFORMATION GATHERING

Personal Information Shared by You

In a Nutshell: We gather personal information that you willingly share with us.

The personal information you share is collected when you sign up on our Services, show interest in learning more about us or our products and Services, engage in activities on our Services, or when you reach out to us in other ways.

Information Shared by You: The nature of personal information we collect is influenced by your interactions with us and the Services, your choices, and the products or features you utilize. The personal information we may collect comprises:

• Email IDs

• Names

• Passwords

• Card details

• Billing addresses

• Contact numbers

We prioritize the security of the data you upload to our platform by securely housing it within Amazon Web Services, ensuring its confidentiality and integrity. You possess the right to erase your data at any given time, encompassing both the uploaded data and chat conversations. Unlike chatGPT, your data and chat exchanges are never forwarded to OpenAI for model training purposes.

Sensitive Details: We abstain from processing sensitive details.

Payment Information: Should you make purchases, we may collect necessary data to process your payment, like your payment instrument number, and the associated security code. All payment information is secured by Stripe. For more on their privacy practices, visit: https://stripe.com/privacy.

It's imperative that all personal information shared with us is accurate, complete, and true. Notify us promptly of any modifications to such personal information.

Automatically Collected Information

In a Nutshell: Certain information — like your Internet Protocol (IP) address and/or browser and device specifics — is automatically gathered when you use our Services.

As you use our Services, we automatically collect specific information. While this information doesn't reveal your exact identity, it may include device and usage data, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, details about your usage of our Services, and other technical data. This information primarily aids in maintaining the security and operation of our Services, alongside internal analytics and reporting.

Similar to many enterprises, we also gather information through cookies and similar technologies.

The gathered information includes:

Device Information: Information concerning the device you use to access the Services is collected, which may include data like your IP address, device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration information.

Location Information: We gather data about your device's location, which could be either precise or imprecise. The extent of information collected is influenced by the type and settings of the device you employ to access the Services. For instance, technologies like GPS may be used to collect geolocation data based on your IP address. You have the option to disallow this data collection either by refusing access or by disabling your device’s Location setting. However, opting out may impact your ability to use certain facets of the Services.

HOW IS YOUR INFORMATION UTILIZED?

In a Nutshell: Your information is utilized to provide, enhance, and manage our Services, engage with you, ensure security, prevent fraud, and comply with legal obligations. With your consent, your information might be used for additional purposes.

The processing of your personal information is dependent on your interaction with our Services, and includes:

Facilitating account setup, authentication, and overall user account management. Your information is processed to enable account creation, login, and ensure smooth operation of your account.

Seeking Feedback: Your information might be utilized to seek feedback and engage with you concerning your experience with our Services.

Sending Marketing and Promotional Communications: Subject to your marketing preferences, the personal information you share may be utilized for our marketing endeavors. You have the option to opt out of our marketing emails anytime. For further details, refer to the section “WHAT ARE YOUR PRIVACY RIGHTS?” below.

Preserving or Guarding an Individual's Vital Interests: In certain scenarios, your information might be processed to safeguard or preserve an individual’s vital interests, such as preventing harm.

WHAT ARE OUR LEGAL GROUNDS FOR HANDLING YOUR INFORMATION?

In Brief: We process your personal information only when there's a valid legal reason under the applicable law, such as with your consent, to comply with legal requirements, to provide you with services, to fulfill contractual obligations, to safeguard your rights, or to pursue our legitimate business interests.

For individuals in the EU or UK, this section is pertinent.

The General Data Protection Regulation (GDPR) and UK GDPR necessitate that we elucidate the valid legal grounds we depend on to handle your personal information. Accordingly, we may resort to the following legal grounds to handle your personal information:

Consent: Your information may be processed if you have accorded us permission to utilize your personal information for a particular objective. You have the right to retract your consent anytime. Discover more about retracting your consent.

Legitimate Interests: Your information may be processed when it's reasonably needed to attain our legitimate business interests, provided those interests don't supersede your interests and fundamental rights and freedoms. For instance, your personal information might be processed for the purposes highlighted to:

Share information regarding our special offers and discounts on products and services with users.

Grasp how users interact with our products and services to enhance user experience.

Legal Obligations: Your information may be processed when deemed necessary for adherence to our legal obligations, like collaborating with law enforcement agencies or regulatory bodies, asserting or defending our legal rights, or revealing your information as evidence in litigation we are entangled in.

Vital Interests: Your information may be processed when necessary to safeguard your vital interests or the vital interests of a third party, especially in scenarios involving potential threats to any person's safety.

IN WHAT CIRCUMSTANCES AND WITH WHOM IS YOUR PERSONAL INFORMATION SHARED?

In Brief: Your information may be shared in certain described situations and/or with specific third parties.

Your personal information may be shared in the following scenarios:

Business Transactions: Your information may be shared or transferred in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

WHAT IS OUR POSITION ON THIRD-PARTY WEBSITES?

In Brief: We don't assume responsibility for the safety of any information shared with third parties linked to or advertising on our Services, which aren't affiliated with us.

Our Services may have links to third-party websites, online platforms, or mobile applications, and/or may contain advertisements from third parties unaffiliated with us. We don't guarantee the safety of any information shared with such third parties and won't be held liable for any loss or damage caused by the use of such third-party platforms. The provision of a link to a third-party platform doesn't imply endorsement by us. Your data shared with third parties isn't covered by this privacy notice, and we advise reviewing the policies of such third parties.

DO WE UTILIZE COOKIES AND OTHER TRACKING MECHANISMS?

In Brief: We might employ cookies and other tracking mechanisms to gather and store your information.

Cookies and similar tracking technologies may be used to access or store information. Detailed information regarding our use of such technologies and how you can reject certain cookies is provided in our Cookie Notice.

FOR HOW LONG IS YOUR INFORMATION RETAINED?

In Brief: Your information is retained as long as necessary to fulfill the objectives outlined in this privacy notice or as required by law.

Your personal information is kept only for the duration necessary for the objectives highlighted in this privacy notice, unless a longer retention period is mandated or allowed by law. No objective in this notice will necessitate us retaining your personal information beyond the duration in which you have an account with us.

Upon no ongoing legitimate business necessity to process your personal information, we'll either delete or anonymize such information, or, if this isn’t feasible (for instance, because your personal information has been stored in backup archives), then we'll securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE ENSURE THE SAFETY OF YOUR INFORMATION?

In Brief: We strive to safeguard your personal information through a combination of organizational and technical security protocols.

We have put in place suitable and reasonable technical and organizational security arrangements aimed at safeguarding the security of the personal information we handle. However, notwithstanding our security measures, no electronic data transmission over the Internet or information storage technology can be assured to be 100% secure. Hence, we cannot pledge or guarantee that hackers, cybercriminals, or other unauthorized entities will not be able to defeat our security measures and improperly gather, access, steal, or alter your information. While we endeavor to protect your personal information, the transmission of personal information to and from our Services is carried out at your own risk. It's advisable to access the Services within a secure environment.

WHAT ARE YOUR PRIVACY ENTITLEMENTS?

In Brief: In certain regions, such as the EU, you have rights that afford you greater access to and control over your personal information. You can review, amend, or terminate your account anytime.

In particular regions (like the EU), you are granted certain rights under the applicable data protection laws. These might include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. Under certain circumstances, you may also have the right to object to the processing of your personal information. Such requests can be made by reaching out to us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in compliance with applicable data protection laws.

If you are situated in the EEA or UK and believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection authority or the UK data protection authority.

If you are situated in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent anytime. You can withdraw your consent at any time by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

Opting out of marketing and promotional communications: You can opt out of our marketing and promotional communications anytime by clicking on the unsubscribe link in the emails we send, or by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from our marketing lists. However, we may still communicate with you for service-related matters, requests, or other non-marketing purposes.

Account Information

Should you wish to review, amend, or delete the information in your account or terminate your account, you can:

Log in to your account settings and update your user account.

Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot issues, assist with any investigations, enforce our terms and comply with legal requirements.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies. Opting to remove or reject cookies may affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services.

For queries or comments regarding your privacy rights, feel free to email us at contact@realclear.ai.

MEASURES FOR DO-NOT-TRACK FEATURES

Most web browsers, some mobile operating systems, and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to indicate your privacy preference of not having data about your online browsing activities monitored and collected. Currently, no uniform technology standard for recognizing and implementing DNT signals has been finalized. Therefore, we do not presently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is established that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Brief: Yes, California residents have certain rights concerning their personal information under state law.

California Civil Code Section 1798.83, known as the "Shine The Light" law, allows our users residing in California to request and obtain from us, once a year and free of charge, information regarding the categories of personal information (if any) we shared with third parties for direct marketing purposes and the names and addresses of all third parties with whom we shared personal information in the immediately preceding calendar year. If you are a California resident and wish to make such a request, please submit it in writing to us using the contact information provided below.

If you are below 18 years of age, reside in California, and have a registered account with the Services, you have the right to request the removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement confirming your residency in California. We will ensure the data is not publicly displayed on the Services, but be advised that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a "resident" as:

(1) every individual present in the State of California for other than a temporary or transitory purpose and

(2) every individual domiciled in the State of California but currently outside the State for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, certain rights and obligations regarding your personal information come into play.

What categories of personal information do we collect?

We have collected the following categories of personal information in the last twelve (12) months:

Category Examples Collected

A. Identifiers

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

YES

B. Personal information categories listed in the California Customer Records statute

Name, contact information, education, employment, employment history, and financial information

YES

C. Protected classification characteristics under California or federal law

Gender and date of birth

NO

D. Commercial information

Transaction information, purchase history, financial details, and payment information

NO

E. Biometric information

Fingerprints and voiceprints

NO

F. Internet or other similar network activity

Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

NO

G. Geolocation data

Device location

NO

H. Audio, electronic, visual, thermal, olfactory, or similar information

Images and audio, video, or call recordings created in connection with our business activities

NO

I. Professional or employment-related information

Business contact details to provide you our Services at a business level, job title, work history, and professional qualifications if you apply for a job with us

NO

J. Education Information

Student records and directory information

NO

K. Inferences drawn from other personal information

Inferences drawn from any of the collected personal information listed above to create a profile or summary, for instance, an individual’s preferences and characteristics

NO

L. Sensitive Personal Information

NO

We will utilize and retain the collected personal information as needed to provide the Services or for:

Category A - For the duration the user maintains an account with us

We may also collect additional personal information outside these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

Receiving assistance through our customer support channels;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

You can find more details about our data collection and sharing practices in this privacy notice.

You may reach out to us by email at hello@formulabot.com, or by referring to the contact details at the end of this document.

If you are using an authorized agent to exercise your right to opt out, we may deny the request if the authorized agent fails to provide proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may share your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, and they are bound by the same strict privacy protection obligations as per the CCPA.

We may utilize your personal information for our own business purposes, such as conducting internal research for technological development and demonstration. This is not deemed to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have no plans to sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your rights concerning your personal data

Right to request deletion of the data — Request to delete

You have the right to request the deletion of your personal information. Upon receiving such a request, we will respect it and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) situations where the exercise of free speech by another consumer is involved, our legal obligations, or any processing required to prevent illegal activities.

Right to be informed — Request to know

Depending on the situation, you have the right to know:

whether we collect and use your personal information;

the categories of personal information collected;

the purposes for which the collected

The information provided outlines the privacy rights of Virginia residents under the Virginia Consumer Data Protection Act (CDPA). The CDPA grants specific rights to consumers in Virginia regarding the collection, use, and disclosure of their personal data by entities that conduct business in Virginia or produce products or services that are targeted to residents of Virginia.

Key Points:

Definitions:

"Consumer" refers to a natural person residing in Virginia, acting in an individual or household context.

"Personal data" refers to any information linked or reasonably linkable to an identified or identifiable natural person, excluding de-identified data or publicly available information.

"Sale of personal data" refers to the exchange of personal data for monetary consideration.

Rights Under CDPA:

Right to be informed about whether personal data is being processed.

Right to access personal data.

Right to correct inaccuracies in personal data.

Right to request deletion of personal data.

Right to obtain a copy of the personal data shared.

Right to opt out of processing personal data for targeted advertising, sale of personal data, or profiling that leads to legal or similarly significant effects.

Exercise of Rights:

Consumers can exercise their rights by contacting Campground Sociall LLC via email at hello@realclear.ai, by submitting a data subject access request, or by referring to the contact details provided in the document.

Verification may be required to process requests, and authorized agents may need to provide proof of authorization.

Responses to requests will be provided within 45 days, extendable by an additional 45 days when necessary.

Appeals:

If a request is declined, consumers can appeal the decision by emailing hello@realclear.ai. Campground Social LLC will respond to appeals within 60 days, and if the appeal is denied, consumers may contact the Attorney General to submit a complaint.

Updates to Privacy Notice:

The privacy notice may be updated to remain compliant with relevant laws. Material changes will be notified either by posting a notice or by direct notification.

Contact Information:

For questions or comments regarding the privacy notice, contact Campground Social LLC via email at hello@realclear.ai or by post at the provided address.

Review, Update, or Deletion of Data:

Based on applicable laws, consumers may have the right to request access to, change, or delete their personal information by submitting a data subject access request.

This privacy notice demonstrates Campground Social LLC's commitment to comply with the Virginia CDPA, ensuring transparency and control for Virginia residents regarding their personal data.

RealClear's Data Privacy & Security section highlights the company's dedication to safeguarding customer data through enterprise-grade best practices. The key points from the provided information are:

Enterprise-grade Best Practices:

RealClear is committed to data privacy and security, with robust measures in place across all operational aspects to protect user data while delivering the services.

Infrastructure and Third-Party Services:

RealClear builds on infrastructure provided by Amazon Web Services (AWS), OpenAI, and Bubble.io, ensuring industry-leading security, privacy, and compliance.

It also leverages third-party services like Google Analytics and Google Sheets to enhance user experience, requiring user authorization for data access.

Data Collection and Usage:

RealClear collects and stores user-uploaded data to fulfill service requests, ensure data security, comply with legal obligations, and communicate service updates.

Data Security Measures:

Robust security measures include technical, administrative, and physical safeguards, access controls, data backup procedures, and regular security assessments.

Data uploaded to the RealClear Tool is protected by encryption using the Advanced Encryption Standard (AES-256).

Data Retention:

RealClear retains user data as long as necessary for the intended purposes or as mandated by law, with an option for users to request data deletion or anonymization.

Data Sharing and Disclosure:

RealClear doesn't share user data with third parties for marketing purposes without explicit consent.

Files and inputs are shared with OpenAI solely for generating relevant code/outputs, with the data being aggregated and anonymized.

OpenAI's Data Policy:

OpenAI, a service provider, shares RealClear's commitment to data security, employing robust encryption for data in transit, and adhering to SOC 2 Type 2 compliance.

User Agreement:

Users agree to the terms of the Data Privacy Policy by using RealClear's services, fostering transparency and adherence to data protection laws.

RealClear’s approach emphasizes a continuous commitment to enhancing data security, promoting transparency, and ensuring compliance, which are crucial for fostering trust and delivering a reliable and secure user experience.