Disclaimer and Disclosure

Unless otherwise noted, all information, data, and other material, including ratings or scores (all such information, “Content”) contained in this publication and other reports, materials, or websites of Clear Rating, LLC or its affiliates (collectively, “Clear Rating”) is the exclusive property of Clear Rating,  and may not be duplicated, copied, reproduced, or otherwise used in any form except with the prior written permission of Clear Rating. The Content shall not be used for any unlawful or unauthorized purposes. Some or allthe Content is derived from third-party sources believed by Clear Rating to be accurate and reliable, but it is each reader’s responsibility to evaluate the accuracy, completeness, and usefulness of any opinions, statements, or other Content contained in this publication. NEITHER CLEAR RATING NOR ANY PERSON ASSOCIATED WITH CLEAR RATING MAKES ANY WARRANTY OR REPRESENTATION WITH RESPECT TO THE COMPLETENESS, RELIABILITY, QUALITY, OR ACCURACY, OF THE CONTENT. TO THE FULLEST EXTENT PROVIDED BY LAW, CLEAR RAING HEREBY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, STATUTORY, OR OTHERWISE, INCLUDING BUT NOT LIMITED TO ANY WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT, AND FITNESS FOR A PARTICULAR PURPOSE. THE FOREGOING DOES NOT AFFECT ANY WARRANTIES THAT CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.Without limitation of the foregoing, Clear Rating (as well as its managers, officers, members, employees, representatives, or agents) does not guarantee the accuracy, adequacy, completeness, timeliness, or availability of any Content, and Clear Rating is not responsible for any errors or omissions (negligent or otherwise), regardless of the cause of such error or omission, or for the results obtained from the use of the Content. In no event shall Clear Rating (or its managers, officers, members, employees, representatives, or agents) be liable for any direct, indirect, special, incidental, or consequential damages, costs, expenses, legal fees, or losses (including, without limitation, lost income or lost profit and opportunity costs) in connection with any use of the Content (including, without limitation, any opinions or other information expressly or implicitly expressed or contained in this publication, even if notified of the possibility of such damages. Any opinions and views in the Content reflect the current views or opinions of the authors and may change without notice, and Clear Rating does not undertake to revise or update the Content in any way. Further, any opinions and views expressed by CSA participants do not reflect the policies or positions of Clear Rating or any other person, organization, or company. The Content contained in this publication is distributed with the understanding that Clear Rating, the authors, publishers, and distributors are not rendering legal, financial, accounting, or professional advice or opinions on specific facts or matters and accordingly assume no liability whatsoever in connection with its use. The Content contained in this publication constitutes neither a solicitation, nor a recommendation, nor an offer to buy or sell investment instruments or other services(including, without limitation, legal, financial, accounting, or any professional services), or to engage in any other kind of transaction. The Content is not directed to persons in any jurisdiction where the provision of such Content would run counter to local laws and regulations. Clear Rating maintains certain activities of its business units separate from each other in order (among other reasons) to preserve the independence and objectivity of such respective activities. As a result, certain business units of Clear Rating may have access to information that is not available or made available to accessible to other Clear Rating business units. Clear Rating has established policies and procedures to maintain the confidentiality of certain non-public information received (or which could be received) in connection with each analytical process.

Copyright © 2023 Clear Rating, LLC. All rights reserved. Clear Rating is a registered trademark of Clear Rating, LCC

California Privacy Notice

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Clear Rating and other affiliates and subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice. To the extent of a conflict between the terms of the general Privacy Policy and this California Privacy Notice, this Notice will control with respect to California residents.

Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last 12 months:

Identifiers (including name, real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers).
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (including name, signature, physical characteristics or description, address, telephone number, education, employment, employment history).
Internet or other similar network activity (information regarding a user’s interaction with a website, application, or advertisement).
Professional or employment-related information (current or past job history or performance evaluations).
Inferences drawn from other personal information (profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes).

Subject to applicable law, we may retain your information for as long as needed to provide you products or services that you have requested, comply with our legal obligations, resolve disputes, and enforce our agreements. We may not remove your personal information when there is a legal storage requirement, such as accounting rules or when there are other legal grounds to keep the data, such as an ongoing contractual relationship.

Data Sources
We collect information through various categories of sources. For example, we collect and obtain information:
You provide, such as when you register for one of our events, contact us, respond to a survey, apply for employment, or sign up for emails or marketing information.
From affiliated companies.
Using cookies and automatic collection methods.

Your Rights and Options Regarding Your Information

Access and Correction
You have the right to access and correct your personal information. If you want to review or correct your personal information, you can send us an email at the address noted in the Contact Information section in the general Privacy Policy. California Residents’ Right of Access, Data Portability, and Deletion.

California residents have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If you are a California resident, to exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at (713) 823-2900
Writing to Clear Rating, 720 N Post Oak Road, Suite 400, Houston, TX 77024. Attn: Privacy Policy
Emailing us at office@clearrating.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

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

Your California Privacy Rights
Under California law, a California resident with whom we have an established relationship has the right to request certain information with respect to the types of personal information we have shared with third parties for their direct marketing purposes (if any) and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. In response to a written request, we are permitted to provide a cost-free means to opt out of such sharing.Since we do not provide your personal information to third parties for their direct marketing purposes, it is not necessary for us to establish this procedure.