Privacy Notice

When you use ClearToServe, you trust us with your personal data. We're committed to keeping that trust. That starts with helping you understand our privacy practices.

This notice describes the personal data ("data") we collect, how it's used and shared, and your choices regarding this data. We recommend that you read this along with our Terms of Service, available at cleartoserve.com/terms.

In this notice, "ClearToServe," "we," "us," and "our" refer to ClearToServe and its parent companies, holding companies, subsidiaries, affiliates, and related entities.

I. Overview

Scope

This notice applies when you use ClearToServe's apps, websites, or platform to access or receive products or services, including certification courses, training, compliance tracking, and related services.

This notice specifically applies if you:

• Create an account and use the ClearToServe platform to complete certification courses, training programs, or compliance requirements (a "User").
• Are an employer, manager, or organization administrator who uses the ClearToServe platform to manage employee certifications, compliance records, or training requirements (an "Organization Administrator").
• Receive services through ClearToServe's apps or websites at the invitation or direction of an Organization Administrator or another User (an "Invited User").

Our privacy practices are subject to applicable laws in the places in which we operate. The types of data processing that such laws require, allow, or prohibit vary by jurisdiction. If you access ClearToServe from different jurisdictions, our data processing practices described in this notice may differ accordingly.

Please contact us at support@cleartoserve.com with any questions regarding our practices in a particular country or region.

II. Data collections and uses

A. The data we collect

ClearToServe collects data:

1. That you provide
2. When you use our services
3. From other sources

1. Data you provide

a. Account information. We collect data when you create or update your ClearToServe account.

• First and last name
• Contact info (e.g., email address, phone number)
• Address
• Login credentials (username and password)
• Payment method (including related payment verification information)
• Profile photo
• Settings and preferences
• Employer or organization affiliation

b. Demographic data. We may collect demographic data if necessary to enable certain features or verify eligibility.

• Date of birth or age (to verify eligibility for age-restricted certifications or services)

c. Identity verification information. This refers to data we collect to verify your account or identity.

• Government-issued identification documents, such as driver's licenses or state IDs (which may contain identification photos, numbers, expiration dates, and demographics)
• User-submitted selfies or photos for identity verification purposes

Biometric data notice: When you submit a selfie or photo for identity verification, we may use facial recognition or similar technology to compare your photo against your government-issued ID. Any biometric identifiers or biometric information derived from this process are used solely for identity verification and are not sold or shared for unrelated purposes. Biometric data is retained only for as long as necessary to complete the verification process and is deleted within the timeframes described in Section II.E, unless retention is required by law. Where required by applicable state law (such as the Illinois Biometric Information Privacy Act), we will obtain your informed written consent before collecting biometric data.

d. Certification and training data. This refers to data generated through your use of our certification and training services.

• Course enrollment and completion records
• Exam scores and results
• Certificates earned and their expiration dates
• Compliance status and history
• Training progress and activity

e. User content. This refers to data we collect when you:

• Provide ratings or feedback
• Upload photos or documents (including those submitted for customer support)
• Respond to a survey
• Submit content through our platform

2. Data collected when you use our services

a. Usage data. This refers to data about how you interact with ClearToServe's apps and websites.

• App crashes and other system activity
• Access dates and times
• App features or pages viewed
• Search history within ClearToServe
• Data regarding your interactions with marketing and advertising campaigns

b. Device data. This refers to data about the device(s) you use to access ClearToServe.

• Browser type
• Device IP address or other unique device identifiers
• Hardware models
• Mobile network data
• Operating systems and versions
• Preferred languages

c. Communications data. This refers to data we collect when you contact ClearToServe for customer support or other inquiries.

• Communication type (email, phone, or chat)
• Content (including chat logs and call recordings where permitted by law)
• Date and time

3. Data from other sources

a. Organization Administrators. Employers or organization administrators who enroll you in certification or training programs may provide us with your data.

b. Service providers who help us verify your identity or detect fraud.

c. Business partners. ClearToServe may receive your data from business partners through which you create or access your ClearToServe account, such as payment providers or platforms that integrate with ClearToServe.

d. Users or others providing information in connection with customer support issues, claims, or disputes.

B. How we use data

ClearToServe uses data to provide reliable certification, training, and compliance services. We also use data:

• To enhance the safety and security of our users and services, and to prevent and detect fraud
• For marketing and advertising
• For customer support
• For research and development
• To send non-marketing communications to users
• In connection with legal proceedings

ClearToServe does not sell your personal information for monetary consideration. We may share data with advertising and marketing partners as described in Section II.D below, which may constitute "sharing" for cross-context behavioral advertising under certain state privacy laws such as the California Consumer Privacy Act. You may opt out of this sharing as described in Section IV below.

1. To provide our services

ClearToServe uses data to provide, personalize, maintain, and improve our products and services. This includes:

• Creating and updating your account
• Delivering certification courses and training programs
• Tracking course progress, exam results, and certification status
• Generating and issuing digital certificates
• Enabling compliance tracking and reporting for Organization Administrators
• Sending reminders for expiring certifications or required training
• Processing payments
• Personalizing your experience, such as recommending courses or certifications relevant to your role or industry

2. For safety, security, and fraud prevention

• Verifying your account and identity
• Preventing, detecting, and combating fraud
• Enforcing ClearToServe's Terms of Service and other policies

3. For marketing and advertising

• Personalizing marketing and advertising relating to ClearToServe products and services
• Measuring the effectiveness of marketing and advertising, and optimizing our campaigns

4. For customer support

This includes investigating and addressing user concerns, monitoring and improving our customer support responses and processes.

5. For research and development

We use data for analysis, research, and product development. This helps us make our services more convenient and easy to use, enhance the safety and security of our services, and develop new services and features.

6. For non-marketing communications

This includes service-related notifications, surveys, and communications regarding regulatory or compliance changes that may affect our services or your certifications.

7. For legal proceedings and requirements

We use data to investigate or address claims or disputes relating to use of ClearToServe's services; to satisfy requirements under applicable laws, regulations, or agreements; or pursuant to legal process or governmental request, including from law enforcement.

8. Automated decision-making

ClearToServe may use automated systems to help determine certification eligibility, detect fraud, personalize your experience, or deliver compliance reminders. These systems may process your data without manual review in certain cases. Where automated decision-making produces legal or similarly significant effects on you, you may have the right to request human review of the decision, express your point of view, and contest the outcome, as described in Section IV below.

C. Cookies and related technologies

ClearToServe and its partners use cookies and other online identifiers on our apps, websites, emails, and online ads for purposes described in this notice.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and ads. ClearToServe uses cookies and similar technologies for purposes such as:

• Authenticating users
• Remembering user preferences and settings
• Determining the popularity of content
• Delivering and measuring the effectiveness of advertising campaigns
• Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

Managing cookies: Most web browsers are set to accept cookies by default. You can usually adjust your browser settings to remove or reject cookies. Please note that removing or rejecting cookies may affect the availability and functionality of our services.

D. Data sharing and disclosure

We share your data with other users where necessary to provide our services or features, at your request, or with your consent. We also share data with our affiliates, subsidiaries, service providers, and partners, for legal reasons, or in connection with claims or disputes.

1. With other users

• Organization Administrators: If you are enrolled in ClearToServe through an employer or organization, we may share your certification status, course progress, compliance records, and related data with your Organization Administrator.
• Other users in your organization, as determined by your Organization Administrator's settings.

2. Upon request or with your consent

• Third-party services you choose to connect with your ClearToServe account.
• Regulatory or licensing bodies, at your direction, to verify your certification status.

3. With ClearToServe service providers and business partners

These include third parties that assist us in providing our services, such as cloud storage providers, customer support platforms, payment processors, identity verification providers, ad and marketing partners, research partners, and AI/ML service providers.

4. With ClearToServe subsidiaries and affiliates

We share data with our parent companies, subsidiaries, and affiliates to help us provide our services or conduct data processing on our behalf.

5. For legal reasons or in the event of a claim or dispute

ClearToServe may share your data if we believe it's required by applicable law, regulation, operating license, agreement, legal process, or governmental request. This includes sharing data with law enforcement officials, government authorities, or other third parties as necessary.

We may also share data in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business.

E. Data retention and deletion

ClearToServe retains your data for as long as necessary for the purposes described above. Users may request account deletion through the ClearToServe platform.

You may request that we delete your account through the settings in the ClearToServe app or website. We generally delete data within 90 days of an account deletion request, except where retention is necessary for safety, security, fraud prevention, or compliance with legal or regulatory requirements.

III. Choice and transparency

ClearToServe enables you to access and/or control data that ClearToServe collects, including through:

• Privacy settings
• Device permissions
• Marketing and advertising choices

You may also request access to or copies of your data, make changes or updates to your account, request account deletion, or request that ClearToServe restrict its processing of your data.

IV. Your privacy rights

A. Rights for all users

Regardless of where you are located, ClearToServe provides you with the ability to:

• Access your account data through the ClearToServe app or website.
• Request a copy of your data by contacting us at support@cleartoserve.com.
• Request correction of inaccurate data.
• Request deletion of your account and data.
• Opt out of marketing communications.

We will not discriminate against you for exercising any of your privacy rights.

B. California residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"). These include rights to know, delete, correct, opt out of sale or sharing, and limit use of sensitive personal information.

To submit a request, contact us at support@cleartoserve.com or visit the privacy section of your ClearToServe account settings. We will respond to verified requests within 45 days.

C. Residents of Virginia, Colorado, Connecticut, and other states

If you reside in a state with a comprehensive consumer privacy law, you may have additional rights including access, correction, deletion, portability, and the right to opt out of targeted advertising, sale of personal data, or profiling. To exercise these rights, contact us at support@cleartoserve.com.

D. Right to appeal

If we decline to take action on your privacy rights request, you have the right to appeal that decision. To submit an appeal, contact us at support@cleartoserve.com with the subject line "Privacy Rights Appeal" within 30 days of receiving our response. We will respond to your appeal within 60 days.

V. Data security

ClearToServe is committed to protecting your personal data. We implement and maintain reasonable administrative, technical, and physical safeguards designed to protect your data from unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encryption of data in transit and at rest.
• Access controls that restrict data access to authorized personnel on a need-to-know basis.
• Regular security assessments and testing.
• Employee training on data privacy and security practices.
• Incident response procedures to address potential data breaches.

While we strive to protect your data, no method of transmission over the Internet or method of electronic storage is completely secure. If we become aware of a data breach that affects your personal information, we will notify you in accordance with applicable law.

VI. Children's privacy

ClearToServe's services are designed for use by food and beverage industry professionals and are not directed at children under the age of 16. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us at support@cleartoserve.com.

VII. Do Not Track

Some web browsers transmit "Do Not Track" (DNT) signals to websites. Because there is no universally accepted standard for how to respond to DNT signals, ClearToServe does not currently respond to DNT browser signals. However, you can manage your cookie preferences and opt out of certain tracking as described in Sections II.C and IV of this notice.

VIII. Legal information

A. Data controllers

ClearToServe and its associated entities are controllers of the data processed when you use ClearToServe's services. For questions about data controllership or to contact our privacy team, email us at support@cleartoserve.com.

B. Our legal bases for using your data

Depending on where you use our services and our purpose for using your data, ClearToServe relies on the following legal bases:

• Contract: When we must use your data to provide the services you request and meet our responsibilities under our Terms of Service.
• Consent: When we notify you of how we will collect and use your data, and you voluntarily agree. You have the right to withdraw your consent at any time.
• Legitimate interests: When ClearToServe has a legitimate interest for using your data (such as safety, security, and fraud prevention) and the benefit is not outweighed by risks to your privacy.
• Legal obligation: When we are required to use your data to comply with the law.

C. Legal framework for data transfers

ClearToServe operates and processes user data in the United States and potentially in other jurisdictions. We are committed to protecting your personal data regardless of where it is processed, including through encryption, access controls, and employee training.

D. Updates to this Privacy Notice

We may occasionally update this notice. If we make significant changes, we will notify you in advance through the ClearToServe platform or through other means, such as email. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.

E. Contact us

If you have questions or concerns about this Privacy Notice or ClearToServe's data practices, you may contact us at:

ClearToServe Privacy Team
Email: support@cleartoserve.com
Website: cleartoserve.com/privacy

You may also submit a privacy request through your ClearToServe account settings.