Under Disclaimers & Regulatory Disclosures

Use of Artificial Intelligence (AI)

Clear Health Pass Holdings, LLC, and its subsidiaries leverage Artificial Intelligence (AI) technology across multiple domains, including research and development (R&D), virtual testing, client interactions, and data analysis. The integration of AI allows us to enhance the accuracy, efficiency, and effectiveness of our diagnostic, operational, and customer service processes. This statement provides an overview of how AI is used in our operations, outlines the limitations of AI technology, and includes disclaimers on its application.

 

Potential Uses of AI in Clear Health Pass Holdings Operations

 

  • Research and Development (R&D)
    1. Data Analysis and Modeling: AI-driven algorithms analyze large datasets to identify trends, develop predictive models, and explore correlations between biomarkers and disease states. This allows us to enhance the development of new assays, diagnostic methods, and treatment protocols.
    2. AI-Enhanced Drug Discovery: AI may be used in preclinical research stages to simulate chemical interactions, predict drug efficacy, and assess safety profiles, accelerating the discovery process.
    3. Genomics and Bioinformatics: Machine learning algorithms support genomics research by analyzing genetic data, identifying disease markers, and helping to tailor personalized medicine approaches.
  • Virtual Testing and Diagnostics
    1. Simulated Testing Environments: AI technology enables virtual testing environments where algorithms simulate clinical scenarios, allowing for virtual validation of diagnostic assays before physical implementation. This is particularly valuable for Laboratory-Developed Tests (LDTs) that require rapid adaptation.
    2. Predictive Diagnostics: AI models are used to predict outcomes based on historical data and real-time inputs, providing early indicators of health conditions. These insights aid healthcare providers in assessing potential risks or outcomes based on patients’ unique profiles.
  • Client Interaction and Customer Support
    1. AI Chatbots and Virtual Assistants: AI-powered chatbots are used to enhance customer service by addressing common inquiries, guiding clients through services, and scheduling appointments. While AI tools improve accessibility, all complex or clinical inquiries are handled by qualified staff.
    2. Personalized Client Communication: Machine learning algorithms may tailor client communications based on preferences, prior interactions, and specific needs, improving the user experience and ensuring relevant information is provided.
  • Operational Efficiency
    1. Process Automation: AI supports process automation, streamlining workflows in scheduling, logistics, billing, and reporting. This enables Clear Health Pass Holdings to reduce operational costs and improve service delivery timelines.
    2. Quality Control and Compliance Monitoring: AI algorithms are used to monitor quality metrics, detect anomalies, and ensure that operations remain in compliance with regulatory standards, including CLIA and CAP.

Disclaimers on AI Usage

  • Limitations of AI Technology
    1. Non-Substitute for Medical Expertise: AI outputs, such as predictive diagnostics and virtual testing results, are tools to assist professionals and are not a substitute for clinical judgment, diagnosis, or treatment by licensed medical professionals. All final diagnostic interpretations and healthcare decisions should be made by qualified individuals.
    2. Data Limitations: AI predictions and models are based on historical data and may not fully represent real-world complexities or individual variations. AI models can sometimes produce inaccurate predictions, and reliance on these models should be exercised with caution.
    3. Accuracy and Bias: While AI models are trained for high accuracy, they can be limited by biases present in training data or assumptions in the algorithm. We strive to reduce these biases, but users should be aware of inherent limitations in AI outputs, especially in clinical contexts.
  • Privacy and Data Security
    1. HIPAA Compliance: All AI applications that process personal health information (PHI) are designed to comply with HIPAA regulations, ensuring the confidentiality and security of patient data. AI systems are secured through encryption, access controls, and regular audits.
    2. Data Collection and Usage: AI models may use aggregated and anonymized data for continuous improvement and accuracy. Clear Health Pass Holdings ensures that any data used in AI applications complies with applicable privacy laws and does not compromise patient confidentiality.
  • Ethical Use of AI
    1. Transparency and Informed Consent: Patients and clients are informed when AI is used in diagnostics, customer support, or other interactions. Clear Health Pass Holdings is committed to transparency, providing users with the option to opt out of AI-driven interactions where possible.
    2. AI in Decision-Making: Clear Health Pass Holdings’ AI applications are intended to support, not replace, human decision-making. All AI-driven recommendations and outputs are reviewed by qualified staff, especially in scenarios involving patient care or diagnostic interpretation.
  • Disclaimer on AI-Generated Recommendations
    1. No Guarantee of Accuracy or Outcome: While AI technology aims to provide accurate and reliable insights, Clear Health Pass Holdings does not guarantee the accuracy, reliability, or completeness of AI-generated recommendations or outputs. Patients and clients are advised not to rely solely on AI-driven insights and to consult healthcare professionals for final decisions.
    2. Liability Limitations: Clear Health Pass Holdings disclaims liability for any decisions made based on AI-generated recommendations or outputs. The information provided by AI systems is intended for informational purposes only and should be independently verified by a qualified healthcare provider before making any healthcare or operational decisions.
  • Continuous Improvement and Model Updates
    1. AI Model Training and Updates: Our AI models are periodically updated to improve accuracy and incorporate new data. These updates are designed to enhance model performance but may result in changes to outputs or recommendations. Users should be aware that AI-based predictions are dynamic and may evolve over time.

Conclusion

Clear Health Pass Holdings, LLC, is committed to the ethical and compliant use of AI to enhance our diagnostic, operational, and customer service capabilities. Our goal is to leverage AI to support healthcare professionals, improve operational efficiency, and enhance patient care, while upholding the highest standards of quality, accuracy, and data privacy. By using our services, clients acknowledge and accept the terms of this AI disclosure and agree to consult qualified professionals for decisions involving health and diagnostics.

CLIA Certification and Laboratory Accreditation

All testing is conducted by Clear Health Pass Diagnostics, LLC, a College of American Pathologists (CAP)-accredited and Clinical Laboratory Improvement Amendments (CLIA)-certified High Complexity Laboratory (CLIA #45D2133663) located in Irving, TX. We are committed to maintaining the highest standards of laboratory quality and accuracy in compliance with federal and industry regulations. Our laboratory certification and accreditation reflect our dedication to precision, reliability, and excellence in diagnostic testing.

  • CLIA Certification
    Clear Health Pass Diagnostics is certified under the Clinical Laboratory Improvement Amendments (CLIA) as a high-complexity laboratory, which enables us to perform complex diagnostic tests that require a higher degree of skill and expertise. Our CLIA certification (#45D2133663) demonstrates that we meet or exceed the rigorous standards set forth by the Centers for Medicare & Medicaid Services (CMS) under 42 U.S.C. § 263a and 42 CFR Part 493. This certification mandates stringent requirements for laboratory operations, including quality control, personnel qualifications, proficiency testing, and validation of testing methods, ensuring that all test results are accurate and reliable.
  • CAP Accreditation
    Clear Health Pass Diagnostics is also accredited by the College of American Pathologists (CAP), an independent organization recognized globally for its commitment to quality in laboratory practices. CAP accreditation ensures that our laboratory undergoes regular, comprehensive inspections and adheres to best practices for laboratory management, specimen handling, quality assurance, and test accuracy. CAP accreditation requires us to meet high standards in lab protocols, staff qualifications, and equipment maintenance, further ensuring the reliability and quality of every diagnostic test we conduct.
  • Use of CLIA-Certified Affiliate Lab Network
    Clear Health Pass Diagnostics may, on occasion, collaborate with a network of CLIA-certified affiliate laboratories to expand testing capacity, especially in cases of increased demand. Each affiliate lab within our network is fully CLIA-certified, ensuring that all tests outsourced meet the same federal quality standards required by CMS. This collaborative approach allows us to maintain the highest standards of accuracy, efficiency, and compliance with federal regulations while enhancing our ability to provide timely and reliable diagnostic results.
  • Commitment to Quality and Compliance
    Our dual compliance with CLIA and CAP standards represents our commitment to delivering the highest quality of care through laboratory testing. Every test result generated by Clear Health Pass Diagnostics and our affiliate lab network is produced following strict regulatory and accreditation standards, reflecting our dedication to excellence, accuracy, and reliability. By adhering to both CLIA and CAP guidelines, Clear Health Pass Diagnostics ensures that patients, healthcare providers, and stakeholders can trust the quality of our services.

Click Here to verify our CLIA certification via the CMS public portal

HIPAA Compliance and Data Security

Clear Health Pass Diagnostics, LLC, is fully committed to protecting patient privacy and safeguarding all personal health information (PHI) in accordance with the Health Insurance Portability and Accountability Act (HIPAA), including the HIPAA Privacy Rule, Security Rule, and Breach Notification Rule. These rules collectively establish national standards for protecting sensitive patient data, as outlined in 45 CFR Parts 160, 162, and 164.

  • Privacy Practices
    Clear Health Pass Diagnostics follows the HIPAA Privacy Rule, which regulates the use and disclosure of PHI (45 CFR § 164.500-534). We are dedicated to using PHI solely for diagnostic purposes, patient care, and authorized business operations. Access to PHI is strictly controlled and limited to authorized personnel who need the information to perform their duties, ensuring compliance with federal regulations.
  • Data Security Measures
    In accordance with the HIPAA Security Rule (45 CFR §§ 164.300-318), Clear Health Pass Diagnostics has implemented rigorous administrative, technical, and physical safeguards to secure electronic PHI (ePHI) from unauthorized access, loss, or misuse. These security measures include:
      1. Data Encryption: We use encryption protocols for all data both in transit and at rest, ensuring ePHI remains secure and unreadable by unauthorized individuals.
      2. Access Controls: We employ multi-factor authentication, role-based access, and continuous monitoring to protect data integrity and control access.
      3. Regular Audits: Our systems undergo regular security audits and risk assessments to identify and mitigate potential vulnerabilities, aligning with federal security standards.
      4. Patient Rights
        Patients have specific rights regarding their health information under HIPAA, including the right to access their medical records, request amendments, and obtain information about disclosures of their PHI. Clear Health Pass Diagnostics provides mechanisms for patients to exercise these rights as outlined in 45 CFR § 164.524-528. To learn more about your rights, please refer to the official HIPAA regulations.
      5. Breach Notification Policy
        Clear Health Pass Diagnostics follows the HIPAA Breach Notification Rule (45 CFR §§ 164.400-414), which mandates that we promptly notify affected individuals, the Department of Health and Human Services (HHS), and any other required parties in the event of a data breach involving unsecured PHI. We are committed to full transparency and timely communication in compliance with federal law to minimize any potential impact on affected patients.
      6. Third-Party Compliance
        Clear Health Pass Diagnostics only partners with third-party vendors and service providers who are compliant with HIPAA regulations and other applicable privacy standards. All vendors who may encounter PHI are required to sign Business Associate Agreements (BAAs), ensuring their commitment to safeguarding patient data and compliance with HIPAA regulations (45 CFR § 164.314).
      7. Disclaimer
        While Clear Health Pass Diagnostics takes every possible precaution to secure and protect patient information, no method of transmission or electronic storage is completely secure. Patients are encouraged to contact us with any questions or concerns regarding our data security practices. By using our services, patients acknowledge and accept our privacy and security practices as outlined in this disclosure.

For further information on HIPAA regulations, visit the official HIPAA Regulations page.

 

FDA Compliance for Laboratory-Developed Tests (LDTs)

Clear Health Pass Diagnostics, LLC, as an affiliated entity of Clear Health Pass Holdings, LLC—a recognized tribal agent of a Section 17 federally recognized, wholly owned corporation, or a federally recognized tribe under 25 U.S.C. § 477—commits to ensuring compliance with applicable federal regulations governing Laboratory-Developed Tests (LDTs). We recognize and adhere to the regulatory guidance provided by the Food and Drug Administration (FDA) to maintain the safety, efficacy, and accuracy of our diagnostic services.

FDA Regulatory Standards
While Laboratory-Developed Tests (LDTs) have historically been regulated under the Clinical Laboratory Improvement Amendments (CLIA) and are currently not subject to FDA premarket review, Clear Health Pass Diagnostics follows FDA guidance where applicable. Our laboratory maintains high standards for test development, validation, and reporting in alignment with the Federal Food, Drug, and Cosmetic Act (FD&C Act), 21 U.S.C. § 301 et seq., to ensure that all tests we develop and utilize are safe, accurate, and clinically meaningful.

Quality and Safety of LDTs
Clear Health Pass Diagnostics upholds the quality and safety of Laboratory-Developed Tests through strict adherence to CLIA and other relevant federal quality standards. Although the FDA has exercised enforcement discretion for LDTs, our commitment to quality means we adhere to internal validation processes aligned with FDA’s recommendations for test sensitivity, specificity, and reproducibility, per FDA guidance on Laboratory Developed Tests.

Tribal Sovereignty and Compliance

As a Tribal Agent of a Federally Recognized, Section 17 Corporation, Clear Health Pass Diagnostics operates under the sovereignty of federally recognized tribal status. Section 17 of the Indian Reorganization Act of 1934, codified at 25 U.S.C. § 5124 (formerly § 477), authorizes the Secretary of the Interior to issue charters of incorporation to federally recognized tribes. These charters enable tribes to create federally chartered corporations—often referred to as “Section 17 corporations”—which possess distinct legal identities separate from the tribal government. This structure allows tribes to engage in business activities with certain legal protections and benefits. Clear Health Pass Diagnostics, operating under tribal domicile, benefits from this unique status, providing certain flexibilities in business operations and allowing adherence to both federal guidelines and tribal regulations. Our commitment to regulatory compliance is upheld as part of our dedication to providing reliable and safe diagnostic services to both tribal and non-tribal communities.

 

  • Disclosure of Special Federal Relationships

The Food and Drug Administration (FDA), Centers for Medicare & Medicaid Services (CMS), and Department of Health and Human Services (HHS) recognize the unique relationship between the U.S. government and federally recognized tribes, which is grounded in tribal sovereignty and federal trust responsibilities. Each agency has established policies to ensure meaningful consultation with tribal nations before issuing new guidance or regulations that may impact tribal communities. The FDA’s Tribal Consultation Policy and CMS’s Tribal Consultation Framework are designed to actively engage tribal leaders and seek their input on regulatory changes or guidance that could affect tribal health services, economic enterprises, and regulatory autonomy. These policies align with the HHS Tribal Consultation Policy, which mandates collaboration with tribes in a government-to-government relationship as outlined in Executive Order 13175. This order requires that federal agencies provide tribal governments with the opportunity to shape policies with tribal implications, recognizing tribes’ rights to self-governance. By consulting with tribal entities before finalizing guidance or regulatory measures, these agencies uphold their commitment to tribal sovereignty, address the unique needs of tribal health systems, and ensure that tribal voices are integral to federal policy development impacting Native communities.

For further reference, you can review each agency’s specific policies:

Disclaimer
Clear Health Pass Diagnostics discloses that Laboratory-Developed Tests (LDTs) are not subject to FDA premarket review, and as such, they have not been evaluated by the FDA in the same manner as in vitro diagnostic tests that require premarket approval. Patients and healthcare providers should be aware that LDTs are performed in accordance with CLIA standards and follow FDA guidance where applicable, but they are not formally FDA-approved. For more information on FDA’s guidance regarding LDTs, please see the FDA’s LDT Guidance page.

Clear Health Pass Diagnostics is dedicated to maintaining the highest standards for all diagnostic testing, leveraging both tribal sovereignty and adherence to federal guidelines to provide safe, effective, and high-quality laboratory services.

  1. Medical Disclaimer

Clear Health Pass Diagnostics, LLC provides diagnostic testing services and information that are intended solely for informational purposes. All results, reports, and content generated by Clear Health Pass Diagnostics are not intended to diagnose, treat, cure, or prevent any disease. The information provided should not be used as a substitute for professional medical advice, diagnosis, or treatment. Always consult a qualified healthcare provider for questions regarding your health or any medical condition.

  • No Substitute for Medical Advice
    The test results and health information provided by Clear Health Pass Diagnostics are not intended to replace the professional judgment or advice of healthcare providers. Under 21 U.S.C. § 321(h), diagnostic tests are considered “devices” by the FDA when used to diagnose or manage medical conditions, and Clear Health Pass Diagnostics adheres to all relevant regulatory standards. However, our tests are not designed to replace consultation with your primary healthcare provider or licensed medical professional.
  • Scope of Services
    Clear Health Pass Diagnostics conducts testing within the limits of our CLIA and CAP certifications and as regulated by the Clinical Laboratory Improvement Amendments (42 U.S.C. § 263a). While we strive to provide accurate and timely information, users should not rely on test results as definitive or sole indicators for making any health-related decisions. It is the responsibility of the patient and their healthcare provider to interpret test results in the context of their overall health condition and history.
  • Limitations of Laboratory-Developed Tests (LDTs)
    Some tests offered by Clear Health Pass Diagnostics may be Laboratory-Developed Tests (LDTs), which are regulated by the Centers for Medicare & Medicaid Services (CMS) under CLIA standards but are not subject to the same level of FDA review as other medical devices. Per FDA guidance and 42 CFR Part 493, the use of LDTs is regulated under CLIA but does not constitute FDA approval or endorsement. Patients should be aware that LDTs are used as part of a broader diagnostic approach and should be interpreted in conjunction with other clinical evaluations by healthcare providers.
  • Reliance on Data and Limitations of Liability
    Clear Health Pass Diagnostics exercises reasonable care in generating accurate and reliable test results. However, we cannot guarantee that test results will be 100% accurate or applicable to every individual. Under 42 CFR § 493.1291, Clear Health Pass adheres to CLIA standards for reporting results, but we are not liable for any decisions or actions taken based on the information provided through our services. Users accept full responsibility for any reliance on the provided test information and assume the risks involved.
  • Patient Responsibility
    It is the patient’s responsibility to ensure that all healthcare decisions are made in consultation with licensed medical providers. Clear Health Pass Diagnostics strongly encourages users to discuss any test results with a healthcare provider, especially before starting, stopping, or changing any treatment. Under 45 CFR Part 164, Clear Health Pass protects the confidentiality of all personal health information; however, patients are responsible for ensuring proper handling of their health information outside our facility.
  • No Warranties or Guarantees
    Clear Health Pass Diagnostics provides test results “as is” without warranties or guarantees of any kind. Under 15 U.S.C. § 2301 et seq. (Magnuson-Moss Warranty Act), Clear Health Pass makes no express or implied warranties regarding the accuracy, completeness, or reliability of test results for any specific application or use. Clear Health Pass Diagnostics disclaims any liability for incidental or consequential damages resulting from the use of our test results.

Medical Disclaimer for Lab Testing and Result Interpretation

Clear Health Pass Holdings, LLC, and its subsidiaries provide various lab testing services, including 510(k)-cleared tests and Laboratory-Developed Tests (LDTs). ALL TESTING IS FOR RISK ASSESSMENT AND INFORMATIONAL PURPOSES ONLY. These tests are designed to identify specific genomic markers, gene expression patterns, or biomarkers associated with certain health conditions. However, these results are not intended to diagnose, treat, cure, or prevent any disease or condition. TEST RESULTS FROM CLEAR HEALTH PASS DIAGNOSTICS SHOULD BE INTERPRETED ONLY BY TRAINED MEDICAL PROFESSIONALS AS PART OF A COMPREHENSIVE CLINICAL EVALUATION.

Limitations of Test Results

  1. Informational Purposes Only
    The results provided by Clear Health Pass Diagnostics are intended exclusively for informational purposes and are not a substitute for professional medical diagnosis, advice, or treatment. These results should be used as part of a broader health risk assessment and are not definitive medical advice. Patients should consult a licensed healthcare provider for any health-related questions or concerns.
  2. Risk Assessment, Not Diagnosis
    The tests offered by Clear Health Pass Diagnostics are intended to assess the presence of certain genomic markers or biomarkers that may indicate increased risk for specific health conditions. These tests are not approved by the U.S. Food and Drug Administration (FDA) for diagnostic use and are conducted under the Clinical Laboratory Improvement Amendments (CLIA) framework (42 U.S.C. § 263a; 42 CFR Part 493). Clear Health Pass complies with FDA guidance on LDTs, intended as healthcare aids, not standalone diagnostic tools.
  3. Interpretation by Qualified Healthcare Professionals
    Results from these tests should be interpreted only by qualified healthcare providers who can assess genetic and biomarker information within the context of the patient’s health history, clinical background, and family history. Test results should be used by healthcare providers to make clinical decisions in conjunction with other clinical assessments.
  4. No Guarantee of Predictive or Diagnostic Value
    While Clear Health Pass Diagnostics strives to deliver accurate and scientifically validated tests, the predictive value of genomic markers or biomarkers may vary by individual factors, including environment and lifestyle. There is no guarantee that certain markers or biomarkers will result in specific health outcomes. Results should be used as part of a comprehensive health assessment and not as definitive indicators of disease presence or progression.
  5. FDA and CLIA Compliance
    LDTs provided by Clear Health Pass Diagnostics are regulated under the CLIA standards for laboratory quality but are not subject to FDA premarket approval for diagnostic purposes. Clear Health Pass adheres to relevant FDA guidelines for LDTs, which are developed, validated, and offered within a single CLIA-certified lab to support personalized risk assessments rather than as a substitute for traditional diagnostic testing.
    • For more information on LDT regulations, refer to the FDA’s Laboratory Developed Tests (LDTs) Guidance.

Disclaimers

  1. Indemnification and Liability Limitation
    By using Clear Health Pass Diagnostics’ tests, patients acknowledge that results are for risk assessment and informational purposes only. Clear Health Pass Holdings, LLC, and its subsidiaries disclaim any liability for decisions or actions taken based on test results. Patients and healthcare providers agree to hold Clear Health Pass Holdings harmless from any claims or damages arising from the use or interpretation of these results.
  2. No Warranties or Guarantees
    Clear Health Pass Diagnostics provides testing services and results “as is,” without express or implied warranties. Under the Magnuson-Moss Warranty Act (15 U.S.C. § 2301 et seq.), Clear Health Pass Holdings disclaims implied warranties regarding the completeness, accuracy, or reliability of test results for clinical use. Patients and healthcare providers should interpret these results as part of a larger clinical assessment and not as definitive indicators of health outcomes.
  3. Full Disclaimer of Interpretation
    All results from Clear Health Pass Diagnostics are subject to further interpretation by qualified healthcare providers. Clear Health Pass Diagnostics does not provide medical advice, and all interpretations should be made in consultation with a healthcare professional. Patients should not make health decisions based solely on test results and are advised to discuss findings with a healthcare provider within the context of their broader clinical profile.

Important Notice to Patients

By using the services provided by Clear Health Pass Holdings, LLC, and its subsidiaries, you acknowledge and accept that:

  • The results from testing are intended for risk assessment only and should not be used to diagnose or treat any health condition.
  • The presence of specific genomic markers or biomarkers provides limited information and must be evaluated by a trained healthcare provider in conjunction with other clinical assessments.
  • The FDA has not approved LDTs as diagnostic tools, and they are regulated under CLIA for laboratory quality assurance purposes only.

Clear Health Pass Holdings, LLC, is dedicated to providing reliable and high-quality laboratory services. We encourage all users to consult licensed healthcare professionals with any questions or concerns regarding test results.

For further information on LDT regulation and FDA guidance, please visit the FDA’s Laboratory Developed Tests (LDTs) Guidance page.

 

Quality Assurance Commitment

Clear Health Pass Diagnostics, LLC is committed to maintaining the highest standards of accuracy, reliability, and consistency in all our laboratory testing and diagnostic services. Our quality assurance program is designed to comply with regulatory requirements and industry standards, ensuring that every test result is produced with meticulous care and precision.

Regulatory Compliance
Clear Health Pass Diagnostics operates as a High Complexity Clinical Laboratory Improvement Amendments (CLIA)-certified and College of American Pathologists (CAP)-accredited facility. Our laboratory complies with all CLIA regulations under 42 U.S.C. § 263a and 42 CFR Part 493, which mandate strict requirements for laboratory operations, including personnel qualifications, proficiency testing, and quality control. The CAP accreditation further underscores our commitment to laboratory excellence, as it involves rigorous audits, quality management practices, and adherence to best-in-class standards for diagnostic accuracy and laboratory operations.

Personnel Training and Qualifications
Our team comprises highly qualified laboratory professionals, all of whom meet or exceed the qualifications required for high-complexity testing under CLIA guidelines (42 CFR § 493.1441 – § 493.1495). Every laboratory technician, technologist, and supervisor undergoes continual training and skill assessments to ensure they adhere to best practices in diagnostic testing, specimen handling, and laboratory safety.

Quality Control and Proficiency Testing
As part of our quality assurance program, Clear Health Pass Diagnostics implements rigorous quality control procedures and participates in regular proficiency testing programs as mandated by CLIA regulations (42 CFR § 493.801). Quality control processes include routine checks on equipment calibration, test method validation, and process reviews to prevent errors and maintain the consistency of test results. Proficiency testing involves sending specimens to third-party evaluators to verify our accuracy, allowing our laboratory to benchmark its performance against national standards.

Accuracy and Reliability of Test Results
Clear Health Pass Diagnostics is committed to delivering accurate and reliable test results. We follow strict validation processes for all testing methodologies, ensuring that each assay meets or exceeds industry standards for sensitivity and specificity. Our quality assurance program also includes continuous monitoring and evaluation of test methods, equipment, and processes to identify and rectify any potential issues before they affect patient results.

Ongoing Quality Improvement
Our laboratory continuously seeks to improve its quality assurance practices by staying informed of the latest developments in laboratory science, diagnostics, and regulatory requirements. We conduct regular internal audits and performance reviews to identify areas for enhancement and implement corrective actions as necessary to maintain our standards of excellence.

Data Integrity and Patient Safety
Clear Health Pass Diagnostics takes data integrity seriously, following best practices to secure patient information, prevent errors, and ensure the accuracy of each patient’s health data. Our laboratory systems are equipped with multiple safeguards, and all test results are reviewed by qualified personnel before they are reported to healthcare providers.

Disclaimers

  • Limitations of Laboratory Testing
    While Clear Health Pass Diagnostics exercises the highest levels of quality control and precision, no laboratory testing is infallible. Factors such as specimen quality, timing of sample collection, and inherent limitations of specific assays may affect test results. Patients and healthcare providers should interpret results within the full clinical context.
  • Liability Disclaimer
    Clear Health Pass Diagnostics disclaims any liability for decisions made based on test results provided. Test results are intended to assist healthcare providers in diagnosing and managing patient health but are not definitive diagnoses. All medical decisions should be made by qualified healthcare professionals, who should consider other clinical evaluations, symptoms, and patient history in conjunction with laboratory findings.
  • No Warranties or Guarantees
    While Clear Health Pass Diagnostics adheres to rigorous standards, we provide results “as is” without any warranties or guarantees of accuracy beyond what is standard for laboratory practices. Under the Magnuson-Moss Warranty Act (15 U.S.C. § 2301 et seq.), Clear Health Pass Diagnostics disclaims any implied warranties regarding the suitability of test results for any particular medical decision.
  • Continuous Improvement Disclaimer
    Quality assurance practices and protocols at Clear Health Pass Diagnostics are subject to continuous review and improvement. As such, testing procedures, equipment, and methodologies may change over time to reflect the latest advancements in laboratory science and regulatory standards. Any updates to these practices are implemented with the goal of enhancing diagnostic accuracy and reliability.

Clear Health Pass Diagnostics is dedicated to ensuring that every patient receives the highest standard of care through accurate, reliable, and compliant laboratory testing. Our commitment to quality assurance reflects our dedication to providing healthcare providers with trustworthy diagnostic information essential for patient care.

Third-Party Vendor Compliance (HIPAA and CLIA)

Clear Health Pass Diagnostics, LLC, is committed to ensuring that all third-party vendors and service providers who may access, process, or handle sensitive patient data adhere to the same stringent standards of compliance, confidentiality, and security that we uphold within our own operations. Our commitment to HIPAA and CLIA compliance extends to all external partners and is enforced through contractual obligations, regular assessments, and strict data protection practices.

  • HIPAA Compliance for Third-Party Vendors
    Under the Health Insurance Portability and Accountability Act (HIPAA), Clear Health Pass Diagnostics enters into Business Associate Agreements (BAAs) with each third-party vendor that may access Protected Health Information (PHI) on our behalf. These agreements establish that vendors must adhere to the HIPAA Privacy Rule, Security Rule, and Breach Notification Rule requirements as outlined in 45 CFR Parts 160 and 164. All vendors are required to implement safeguards to protect the confidentiality, integrity, and availability of PHI, ensuring that data is only used for authorized purposes and managed in accordance with HIPAA standards.
  • CLIA Compliance for Laboratory Services
    When Clear Health Pass Diagnostics outsources or collaborates with other laboratories in our network, we ensure that each third-party lab is fully compliant with the Clinical Laboratory Improvement Amendments (CLIA), specifically 42 U.S.C. § 263a and 42 CFR Part 493. Every affiliated lab is required to hold a CLIA certification appropriate to the complexity of the testing they perform. Clear Health Pass Diagnostics conducts due diligence to verify that all partner laboratories maintain the same high standards of accuracy, reliability, and regulatory compliance in their testing processes.
  • Data Security and Access Control
    Clear Health Pass Diagnostics mandates that all third-party vendors follow strict data security practices to prevent unauthorized access, breaches, or misuse of patient data. Vendors must implement data encryption, access controls, and monitoring practices in alignment with HIPAA and industry standards. Regular audits and assessments are conducted to ensure that all security practices are upheld, minimizing the risk of data breaches or unauthorized disclosures.
  • Ongoing Monitoring and Compliance Audits
    We perform regular compliance audits and reviews of our third-party vendors to verify adherence to HIPAA and CLIA standards. Any vendor that fails to meet our compliance requirements is subject to corrective action, including contract termination if necessary. Continuous monitoring of vendor practices ensures that Clear Health Pass Diagnostics maintains a network of reliable and compliant partners.

Disclaimers

  • Limitations of Liability for Third-Party Actions
    While Clear Health Pass Diagnostics takes every measure to ensure that third-party vendors are compliant with HIPAA and CLIA, we cannot be held liable for any unauthorized actions or data breaches that occur solely due to the actions or negligence of these third parties. Each vendor operates as an independent entity and is responsible for their own compliance practices. Clear Health Pass Diagnostics encourages patients to consult with our customer service for any questions or concerns regarding third-party data handling.
  • No Warranties on Third-Party Vendor Compliance
    Clear Health Pass Diagnostics disclaims any implied warranties regarding the performance, data security, or compliance practices of third-party vendors. While we conduct thorough vetting and monitoring, Clear Health Pass Diagnostics does not guarantee that third-party vendors are infallible. Patients should be aware that data shared with or processed by third parties is subject to the third party’s data handling policies and practices.
  • Right to Change Third-Party Vendors
    Clear Health Pass Diagnostics reserves the right to change, add, or remove third-party vendors as needed to maintain high standards of service and compliance. Any changes to our third-party vendor network are made with consideration of patient privacy, regulatory requirements, and quality of service. By using our services, patients acknowledge and accept that certain aspects of their data may be processed by vetted third-party vendors in compliance with HIPAA and CLIA.

Clear Health Pass Diagnostics is dedicated to protecting patient information, ensuring the integrity of diagnostic services, and working exclusively with vendors who share our commitment to compliance and security.

Safe Harbor Statement (If Applicable for Investor Information)

This website and any materials provided by Clear Health Pass Holdings, LLC, contain forward-looking statements, which are based on current expectations, assumptions, estimates, and projections about our business and industry. These statements involve known and unknown risks, uncertainties, and other factors that may cause our actual results, performance, or achievements to differ materially from those expressed or implied by these forward-looking statements. Such risks include, but are not limited to, business strategy, market acceptance, regulatory changes, and the economic environment. Clear Health Pass Holdings undertakes no obligation to update or revise any forward-looking statements publicly.

Exemption Filing Under Rule 506(c) of Regulation D

Clear Health Pass Holdings, LLC, is conducting certain investment offerings pursuant to an exemption from registration under Rule 506(c) of Regulation D, as provided by the Securities Act of 1933. Under Rule 506(c), Clear Health Pass Holdings may generally solicit and advertise its securities offering; however, investments can only be made by “accredited investors” as defined by Rule 501 of Regulation D. Accredited investors must meet income or net worth thresholds and provide verification of their status before participating in any investment opportunity offered by Clear Health Pass Holdings.

  1. General Solicitation and Accredited Investor Verification
    Clear Health Pass Holdings, under Rule 506(c), may utilize general solicitation and advertising to communicate information about its investment opportunities. However, investment in any offering is limited to individuals or entities that qualify as accredited investors under 17 CFR § 230.501(a). Investors must undergo a verification process to confirm their accredited status, which may include providing financial statements, third-party verification, or other methods specified by the SEC.
  2. Forward-Looking Statements Disclaimer
    The information provided in this website or other communications may include forward-looking statements that involve significant risks and uncertainties. Factors that could affect actual results include regulatory changes, market conditions, operational performance, and other risks outlined in our offering materials. Investors should not place undue reliance on these forward-looking statements, as they reflect the company’s perspective as of the date of publication. Clear Health Pass Holdings disclaims any obligation to update or revise forward-looking statements in response to new information, future events, or other factors.
  3. Risk Disclosure for Investors
    Investment in Clear Health Pass Holdings involves a high degree of risk, including the potential loss of the entire investment. Investors should be aware that these securities are illiquid, may not have a public market, and may be subject to resale restrictions. Prospective investors are encouraged to consult with their financial advisors, accountants, or attorneys before making any investment decision. This investment is intended for individuals who can bear the financial risk of such an investment, and there is no guarantee of return.
  4. Limitations of Liability and No Guarantees of Performance
    Clear Health Pass Holdings makes no guarantees regarding the future performance of any investment and expressly disclaims liability for any loss or damages that may occur as a result of an investor’s reliance on information provided. Past performance is not indicative of future results. Investors are solely responsible for their own due diligence and investment decisions.
  5. No Registration with the SEC
    Clear Health Pass Holdings’ offerings under Rule 506(c) of Regulation D are exempt from registration with the U.S. Securities and Exchange Commission (SEC). As a result, the SEC has not reviewed or approved any offering materials or information about Clear Health Pass Holdings. Exempt securities offerings are not subject to the same regulatory requirements as registered securities, and prospective investors should be aware of the increased risks involved in non-registered offerings.
  6. Exemption from State Registration and Blue Sky Laws
    Offerings conducted under Rule 506(c) are exempt from state-level registration requirements, known as “Blue Sky Laws,” which may ordinarily require registration or qualification of securities at the state level. However, Clear Health Pass Holdings complies with any required state filings for exemptions where applicable.

Disclaimer

By accessing this website or any materials provided by Clear Health Pass Holdings, LLC, you acknowledge and agree that:

  • Investment opportunities are available only to accredited investors, and Clear Health Pass Holdings is not soliciting investments from non-accredited individuals.
  • All investment opportunities are exempt from registration under Rule 506(c) of Regulation D and carry a high level of financial risk.
  • No federal or state securities regulators have passed upon or endorsed any offering or the accuracy or adequacy of the information provided.

Important Notice
The content on this website is not intended as an offer to sell or a solicitation of an offer to buy any securities. Any offers to invest will only be made through private offering documents provided by Clear Health Pass Holdings. This Safe Harbor Statement is intended to comply with the requirements of Rule 506(c) of Regulation D and relevant securities laws.

Click Here for Clear Health Pass Holding’s Notice of Exempt Offering of Securities

Clear Health Pass User and Privacy Policy

Clear Health Pass understands how important the privacy of personal information is to our users. This Privacy Policy will tell you what information we collect about you and your use of Clear Health Pass and its services. It will explain your choices about how your personal information is used and how we protect that information. We urge you to read this Privacy Policy carefully. This Privacy Policy applies to websites owned and operated by Clear Health Pass that are intended for use by consumers (non-professionals) for non-commercial personal, family, or household purposes, including Clear Health Pass.com and CovidPetTests.com and including the mobile optimized versions of these sites and our Mobile Device Applications or “Apps” (we refer to these sites and Apps collectively as the “Clear Health Pass Sites”). We refer to the Clear Health Pass Sites and Apps, along with the information and services made available to you through the Clear Health Pass Sites and Apps, as the “Services.” This Privacy Policy also applies to the consumer-facing version of the Clear Health Pass Health Manager Product. However, if you are an employee or health plan member who has enabled access to your health record at Clear Health Pass.com by registering at your employer’s or health plan’s website, the privacy policy applicable to your information at your employer’s or health plan’s website remains applicable to your personal health record at Clear Health Pass.com.

If your employer or health plan account is no longer made available to you by your employer or health plan, you will continue to have access to your health information from Clear Health Pass.com using the same username and password but will be subject to this Privacy Policy. Except where noted, statements in this Privacy Policy concerning the Clear Health Pass Sites also apply to the Apps. If you do not want us to collect, use or disclose information about you and your use of the Services as described in this Privacy Policy, then you should not use the Services. By using the Services, you must agree to the Clear Health Pass Terms of Use, which is the contract between users and us of the Services.  By accepting the Clear Health Pass Terms of Use, you confirm that you have read and understood and consent to this Privacy Policy and the Clear Health Pass Cookie Policy. You consent and acknowledge that we will store, use and otherwise process your information in the United States, where we are located. References to “Clear Health Pass,” “we,” or “us” mean Clear Health Pass LLC, including any company that Clear Health Pass LLC controls (for example, a subsidiary that Clear Health Pass LLC owns).

Clear Health Pass may share information among its subsidiaries or websites that it owns or controls, but the information collected under this Privacy Policy is always protected under the terms of this Privacy Policy. Except as otherwise noted in this Privacy Policy, Clear Health Pass LLC is the data controller responsible for the processing of your personal information as described in this Privacy Policy. Information Collected About You Some of our Services (such as specific quizzes or calculators) do not retain your personal information, while others (such as Clear Health Pass Lab Testing and other health-related programs that may be or become available in the Clear Health Pass App and certain of our registration-only Apps like Clear Health Pass Baby, Clear Health Pass Pregnancy and Clear Health Pass Allergy) store your personal information in accordance with this Privacy Policy. Even if you do not register with or provide any personal information to Clear Health Pass, we collect information about your use of the Clear Health Pass Sites, and Apps, and Services. We may also acquire information about our users from external sources. When you use the Services, we collect information as follows: Registration While you may use most of the Services without registering, certain Services require you to register with Clear Health Pass for them to function correctly. If you choose to register or update an existing account with Clear Health Pass or access certain Services, you may be required to provide certain personal information, such as your name, address, telephone number, gender, email address and date of birth, and a username and password to access your Clear Health Pass account. You are responsible for ensuring the accuracy of the personal information you submit to Clear Health Pass.

This Privacy Policy explains how Clear Health Pass Holdings, LLC. (“Clear Health Pass,” “CHP,” “we,” “us,” or “our”) may collect, use, disclose, and otherwise process your personal information through our digital properties that link to this Privacy Policy, including our website and mobile application (the “Service”).

Clear Health Pass has developed different initiatives in coordination with epidemiologists and public health officials to increase the reach and efficacy of the public health response related to COVID-19, improve health equity, improve health and human services, and reduce cost. This Privacy Policy is designed to describe our privacy practices comprehensively. Because several different modules are available through the Service, depending on the module(s) you are using, we may collect less personal information—or disclose information in fewer ways—than described in this Privacy Policy. If a module you use contains more data than described in this Privacy Policy, we will provide an additional notice at or before the collection point.

Your use of Clear Health Pass is voluntary. You may deactivate your account anytime from within the Service and direct us to delete your personal information.

 

HOW WE COLLECT YOUR PERSONAL INFORMATION

When you use the Service, we will ask you to share certain personal information. We will also receive information from U.S. local, state, and federal government organizations, as well as other entities you authorize, and collect specific technical, device, and usage information from your device.

 

Information You Provide to Us. The personal information you may provide to us through the Service or otherwise includes:

Registration and Profile Information. You may provide certain personal information when you register to use Healthy Together, including, among other things, your full name, zip code, phone number, email address, billing and mailing address, date of birth, biographical details, username and password that you may set to establish an online account, and other information that you add to your account profile.

User-Generated Information. You may provide information regarding your non-medical needs and other content or information you generate, transmit, or otherwise make available on the Service.

Health-Related Information. You may submit personal information about yourself through your use of the Service, such as your age, reported height and weight, your pre-existing conditions, and other health-related information.

Vaccination Records and Health Test Results. You may choose to upload a photo of your vaccination records and health test results (including for COVID-19), as well as details such as the type of test, test date, and location so that they can be stored and easily accessed from your account. Clear Health Pass cannot access your camera or stored photos without permission. We will never access or upload stored photos from your device unless you have selected them for upload.

Demographic Information. You may provide information regarding your race, ethnicity, preferred language, and state and county of residency.

Relationship Information. You may provide information about your family members or other third parties.

Transactional Information. You may provide the information needed to complete your orders on or through the Service, including order numbers and transaction history.

Financial and Related Information. You may provide information regarding your finances, such as your stated income and economic standing, as well as your EBT information.

Identification Number Information. You may share your identification number information, such as national identification number (e.g., Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), student ID number, employee ID number, or other forms of identification, and an image of the relevant identification card.

Communications Data. We may collect communications data from our exchanges with you, including when you contact customer support personnel through the Service, social media, or otherwise.

Scans of QR Codes. You may use your device camera to scan a Bar or QR code to connect test results to your account or verify symptom information to a third-party entity, such as a school, employer, or another party. We cannot access your camera without your permission.

Information about Selected Contacts. With your consent, we may receive the name and phone number of individuals from your device’s contact list for case interview purposes if you test positive for a local, state, or nationally notifiable disease. We only receive the specific contacts you choose to share with us whom you believe may have been exposed to a communicable disease (“Selected Contact”). If you choose to share a Selected Contact, we may share this information with U.S. state and local government organizations to assist them with case interview activities.

Other Information. You may provide additional information not explicitly listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-Party Sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

Public Sources. We may receive information about you from our government or school partners to offer health or benefits-related services. For example, suppose we partner with your state of residency to administer public benefits applications or display your medical test results through the Service. In that case, we may receive your contact information and related information to provide these services. You may also connect your Clear Health Pass account with your government or school accounts.

Marketing Partners. We may receive information about you from joint marketing partners.

Third-Party Services. We may combine personal information we receive from you with personal information from third-party services that you use to log into or otherwise link to your Service account. This data may include your username and other information associated with your account on that third-party service made available to us based on your account settings.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications, and other online services, such as:

The device, Technical, and Usage Information. When you access the Service, we collect information about your mobile device or computer system, including MAC address, IP address, and mobile device ID. We also generate usage statistics about your interactions with the Service. This information is typically collected through the use of server log files or web log files, mobile device software development kits, and tracking technologies like browser cookies to analyze certain types of technical information. Some cookies the Service places on your computer are linked to your user ID number. When you respond to communications we send you, we may use automated technology to understand how you interact with the contacts. You can usually remove or reject browser cookies through the settings on your browser or device. Currently, we do not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions. We may also use local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store more significant amounts of data on your device outside your browser in connection with specific applications. We may also use web beacons, also known as pixel tags or clear GIFs, to demonstrate that a webpage or email was accessed or opened or that certain content was viewed or clicked.

 

HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and business operations.  We may use your personal information to:

  • Provide, operate and improve the Service and our business;
  • Establish and maintain your user profile on the Service;
  • Facilitate your invitations to friends whom you want to invite to join the Service;
  • Facilitate features of the Service, such as by providing chat or messaging functionality
  • Enable security features of the Service, such as by sending you security codes via email or SMS and remembering devices from which you have previously logged in;
  • Communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages.
  • Connect you with specific U.S. state and local government organizations within your state, county, or city.
  • Understand your needs and interests, personalize your experience with the Service and our communications, and;
  • Provide support for the Service, and respond to your requests, questions, and feedback.

 

Research and development. We may use your personal information for research and development purposes to analyze and improve the Service and our business.  As part of these activities, we may create aggregated, de-identified, and anonymized data from the personal information we collect.  We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you.  We may use this aggregated, de-identified, or otherwise anonymized data and share it with third parties for our lawful business purposes to analyze and improve the Service and promote our business.

Marketing. We may collect and use your personal information for marketing purposes. We may send you direct marketing communications.  You may opt out of our marketing communications as described in the Opt-out of marketing section below.

Compliance and protection.  We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal processes, such as responding to subpoenas or requests from government authorities.
  • protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims).
  • Audit our internal processes for compliance with legal and contractual requirements or our internal policies.
  • enforce the terms and conditions that govern the Service; and
  • Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

With your consent.  In some cases, we may ask for your consent to collect, use, or share your personal information, such as when required by law.

To create aggregated, de-identified, and anonymized data.  We may create aggregated, de-identified, and anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified, and anonymized data and share it with third parties for our lawful business purposes to analyze and improve the Service and promote our business. We may also share de-identified information with public interest organizations, healthcare organizations, and researchers. We will prohibit these organizations from attempting to re-identify the information we share with them to the extent practical.

Use of Cookies and Similar Technologies

Cookies and similar technologies. In addition to the other uses included in this section, we may use the cookies and similar technologies described above for the following purposes:

Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site and whether you are logged in when you visit password-protected areas of the Service.

Functionality. To enhance the performance and functionality of our services.

Analytics. To help us understand user activity on the Service, including which pages are most and least visited, how visitors move around the Service and user interactions with our emails. For example, we may use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

 

How We Share Your Personal Information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

  • We may share your personal information with third parties where you have instructed us or provided your consent. With your Consent, we may share your personal information with U.S. local, state, and federal government organizations and public health organizations for the purposes we have set out in this Privacy Policy relating to public health efforts. For example, a government or public health organization may request your checkup data or your test results if you have tested positive for communicable diseases (e.g., COVID-19) to assist with case interview efforts. We may also share your personal information with other third parties relating to public health intervention and response efforts, such as your university or employer if you have authorized us to do so.
  • If you log into the Service with or otherwise link your Clear Health Passaccount to a third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

 

Other Disclosures

We may share personal information with third-party service providers that perform services on our behalf, including lab services, quality assurance testing; facilitating the creation of accounts, optimizing the platform performance, providing technical support; and provide other related services.  We may also share your personal information with professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

We may share personal information with the government, law enforcement officials, or private parties as required by law, when we believe such disclosure is necessary or appropriate (a) to comply with legal obligations, law enforcement requests, or legal directives such as a court order or subpoena; (b) enforce the terms and conditions that govern the platform; (c) protect our rights, privacy, safety or property, and that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

We may share your personal information with acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) such as a merger, consolidation, acquisition, spinoff, reorganization, or sale of assets or in the event of bankruptcy. We will notify you of any change in ownership that affects your personal information so that you may decide whether to keep your account active or delete your account.

We make commercially reasonable efforts to verify that the parties with whom we share personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as defined in their privacy policies.

Please note that we do not sell personal information.

Protection of Your

We may make features available on the Service, or link, that allow you to share information with third parties. Please be careful when sharing your personal information with third parties, and only share sensitive personal information with those whom you trust. We have no control over the use of your data by third parties with whom you choose to share your information.

 

RETENTION OF YOUR INFORMATION

We generally retain personal information to fulfill the purposes for which we collected it, including to satisfy any legal, accounting, or reporting requirements, establish or defend legal claims, or prevent fraud.  To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your data and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing. You may also delete your personal information and deactivate your account, as described below under Your Choices.

 

SECURITY OF YOUR INFORMATION

We have implemented several security measures reasonably designed to protect your personal information. It is essential that you save and maintain the security of your account, and you should immediately notify us of any unauthorized use of your account. No website, mobile application, or Internet transmission is completely secure. Therefore we cannot guarantee that unauthorized access, hacking, data loss, breaches, or other types of misuse will ever occur. Be careful where and how you share personal information—use public WiFi spots wisely and avoid clicking unfamiliar links or using foreign devices.

In the unlikely event that Health Together experiences a security breach affecting your personal information, we will notify you as required by applicable law. This notice will include information about what happened and the data involved, what steps we have taken to address the incident, and what steps you can take to protect yourself further.

 

Consent to User Communication Choices

You are accessing and Updating Your Information. If you have an account with us, you can access and edit your profile information directly within the profile page of the Service.

You are deactivating Your Account and Deleting Your Information. You may deactivate your account at any time by following the instructions within the Service settings. If you deactivate your account, we will delete all of your personal information within 45 days, except to the extent we are required to retain the information by law or record retention policies of the governmental authority on whose behalf we provided the Service to you.

You are opting Out of Push Notifications. If you opt-in to receive push notifications within our mobile applications, we may send push notifications or alerts to your mobile device from time to time. You can deactivate push notifications and alerts anytime by deleting the mobile app, changing your device settings, or changing the push notification settings within the mobile app.

You are opting Out of SMS Communications. If you opt-in to receive SMS messages by providing your phone numbers, we may send you notifications and other SMS messages from time to time. You may opt out of receiving SMS communications at any time by responding to any SMS with the single-word command “STOP.” In addition, if you have an account, you can opt-out of SMS communications by changing your settings within the Service. You may opt back into SMS communications anytime by adjusting your account settings within the Service. Please note that we may not be able to determine if you deleted or uninstalled the mobile app or blocked the number that delivers the communications. Therefore we may be unable to automatically stop you from receiving SMS communications unless you have specifically opted out of SMS communications by following the instructions above.

 

AGE REQUIREMENTS

Clear Health Pass is not intended for children under 13, and we do not knowingly collect any personal information from children under 13. However, we have certain features where we request information from a parent or guardian about their dependent(s).

If we become aware that an individual under the age of 13 has used the Service, then we will promptly delete their information unless we are prohibited by law from doing so.

 

ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

This section describes how we collect, use, and share the Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights concerning that Personal Information.  For purposes of this section, the term “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA.  In some cases, we may provide an additional privacy notice to specific categories of California residents, such as job applicants. That notice will apply instead of this section.

We collect the types of Personal Information from you as described above (How We Collect Your Personal Information). We use this Personal Information for the business purposes described above (How We Use Your Personal Information). We share personal information under How We Share Your Personal Information.

Your California privacy rights. California residents have the rights listed below under the CCPA. However, these rights are not absolute, and in some instances, we may decline your request as permitted by law. Please note that we do not sell your personal information.

Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:

  • The categories of Personal Information that we have collected.
  • The types of sources from which we collected Personal Information.
  • The business or commercial purpose for collecting and selling Personal Information.
  • The types of third parties with which we share Personal Information.
  • The types of Personal Information that we trade or disclose for a business purpose.
  • The types of third parties to whom the Personal Information was sold or disclosed for a business purpose.

Access. You can request a copy of the Personal Information we collected about you during the past 12 months.

Deletion. You can ask us to delete the Personal Information we ordered from you.

Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

Exercising your right to information, access, and deletion. You may submit requests to exercise your right to information, access, or deletion by emailing us at support@healthytogether.zendesk.comor by mailing your request to:

Twenty Labs, LLC, 382 NE 191st, St PMB 42782, Miami, Florida 33179-3899

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

We will need to verify your identity to process your information, access, and deletion requests and reserve the right to confirm your California residency.  We may require government identification, a declaration under penalty of perjury, or other information to verify your identity.

Your authorized agent may request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent under California Probate Code Sections 4000-4465.  Suppose you have not provided your agent with such a power of attorney. In that case, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity and confirm that you have given the authorized agent permission to submit the request.

 

CHANGES TO OUR PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you if we make material changes to our Privacy Policy by either posting the changes on the Service or by contacting you directly using the contact information you have on file. The notification will also state when the changes will become effective.

By continuing to use the Service after the Privacy Policy is updated, you will have agreed to the new Privacy Policy.

 

CONTACTING US

If you have any feedback, questions, comments, or concerns about this Privacy Policy or our privacy practices, please send an email to  support@clearhealthpass.zendesk.com or write to us at the following address:

Clear Health Pass Holdings, LLC

Legal

30 Wall Street, 8th Floor

New York, NY 10005