Privacy Policy

Last Updated June 5, 2024

Your privacy is important to us at Clarity Financial, Inc. (“Clarity,” “we,” “us,” or “our”), and we are committed to protecting, preserving, and respecting your privacy rights.  This online privacy policy (the “Policy”) describes how we collect, process, use, and disclose the personal information we gather about you through our websites, https://clarityapp.com/ and https://clarityschools.com/ (the “Sites”), as well as any mobile platform or application, or when you interact with us as a customer or otherwise (the “Services”).  

For purposes of this Policy, personal information is any information that relates to an identified person or information which, together with other information, may identify a person.  It includes information that qualifies as personal information, personal data, or similar terms under applicable data privacy laws.  It does not include data excluded or exempted from those laws or regulations, nor does it apply to aggregated, de-identified, or anonymized information.  Nothing in this Policy will constitute an admission or evidence that any particular data privacy or information security law or regulation applies to Clarity generally or in any specific context.  

Our Services allow families to apply for individualized financial aid, execute enrollment contracts with educational institutions, and make payments to those institutions.  This Policy governs how we process personal information we collect on our own behalf.  However, while performing the Services, we may also process some personal information as a service provider of those third parties.  This Policy does not apply in those circumstances, and you should consult those third parties’ privacy policies and other terms.

You Consent to This Policy

You should read this Policy carefully.  By accessing, browsing, or otherwise using the Services, you confirm that you have read, understood, and agreed with this Policy.  If you do not agree to this Policy, you may not use the Services.

This Policy applies regardless of how the Services are accessed and will cover any technologies or devices by which we make the Services available to you.

We may provide you with additional privacy notices where we believe it is appropriate to do so. It is important that you read this Policy together with any other privacy notice or fair processing notice we may provide on specific occasions, so that you are fully aware of how and why we are using your data.  This Policy supplements these other notices and is not intended to override them.

If you have any questions or concerns about our personal information policies or practices, you can contact us in the methods described in the “Contact Us” section below.

The Information We Collect

We collect information you voluntarily provide directly to us, information that we collect automatically when you interact with the Services, and information collected from third parties.  The categories of personal information that we collect and the purposes for which we collect that information are described below. 

Categories of Personal Information We Collect

The following list describes the categories of personal information we collect. 

• Account Information.  If you create an account with us, we collect information such as your name, username, gender, date of birth, phone number, email address, current and previous physical addresses, information regarding your potential financial aid options, tuition amounts,  and other information regarding your use of the Services. We may also collect identity verification information such as your Social Security Number, other identity documents, and tax-related information. Depending on the Service you are using, we may also collect information about the student, including name, grade, and school.  We may collect this information from parents, student-applicants, and non-applicant dependents. We collect this information for the purposes of account management, advertising and marketing, analytics and research, customer service, providing the Services, and website security and maintenance.
• Analytics Information.  We collect certain analytics information automatically as you navigate our Services.  This includes cookies, tracking pixels, tags or similar tools, which may collect information about your browser, device, geolocation, and interactions with the Services, Sites, or emails.  For more information, please view the “How Do We Use “Cookies” and Other Tracking Technologies?” section below.  We collect this information for the purposes of account management, advertising and marketing, analytics and research, customer service, providing the Services, and website security and maintenance. 
• Contact Information includes customer name, postal address, telephone numbers, e-mail addresses, and comments. We collect this information when you provide it directly to us such as signing up for newsletters, requesting information about Clarity services, creating an account, or filling out a form.  We collect this information for the purposes of advertising and marketing, analytics and research, and customer service. 
• Financial Information includes name, address, phone number, bank account information, debit or credit card information, payment and participation history, information relating to payment history on healthcare bills, or other payment processing information.  We collect this information for the purposes of customer service, order fulfillment, and administering the Services.
• Responses to Surveys, Questionnaires, and Narrative Responses includes information you provide to us when you respond to marketing materials, promotions, or other surveys. This also includes any information you provide in addition to other application materials as a narrative description of the items. We collect this information for the purposes of advertising and marketing, analytics and research, and customer service. 
• User-Generated Content.  If you post, upload, comment, or otherwise submit content on the Services, we may collect certain information about you such as your name and email address and products you may have purchased.  Be aware that as a default, any information you post on the Services, including without limitation reviews, comments, and text, may be available to and searchable by all users of the Services.  We collect this information for the purposes of advertising and marketing, and analytics and research.

Other Ways We May Collect, Use, or Share the Information

We may also reserve the right to collect, use, or share personal information for the following purposes:

• To Provide the Services.  We will use your personal information to provide the Services, including to administer communications solutions and generate content, to improve operations and offerings, and for security purposes.
• To Present the Sites.  We will use personal information to present our Sites and its contents in a suitable and effective manner for you and your device.
• For Legal Purposes.  We reserve the right to cooperate with local, provincial, state, federal and international officials in any investigation requiring either personal information or reports about lawful or unlawful user activity on the Sites.  We also reserve the right to share your personal information to establish, exercise, or defend our legal and property rights, including providing information to others for the purposes of fraud prevention.  We may also share your personal information with any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information. 
• Business Transactions or Mergers.  We reserve the right to share your personal information to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction.  Additionally, if we are entering into a corporate transaction with a third party, we may receive personal information in connection with the diligence.  If we close a transaction, the third party may transfer personal information, which we would use as described in this Policy.
• Bankruptcy or Insolvency.  In the event of bankruptcy, insolvency, or dissolution proceedings, we may share your personal information with third parties as part of the sale or reorganization process. 
• Improving Our Services.  We use your information to improve our Services, which may include processing the information as part of machine learning and artificial intelligence developments. 
• Service Providers.  We use service providers to perform various functions on our behalf.  Such service providers will be under contractual obligations to safeguard your personal information and only process it in accordance with our instructions, or as otherwise permitted by applicable laws.  We may also receive personal information from service providers. ‍
• Business Partners and Affiliates. We may collect personal information from and share personal information with our business partners and affiliates, including legal advisors and financial advisors. We may combine that information with other information we collect about you, but we will always use the information as described in this Policy. We may also share information with our affiliates, subsidiaries, joint ventures or other companies under common control.

How Do We Use “Cookies” and Other Tracking Technologies?

We may send one or more cookies to your computer or other device.  We may also use other similar technologies, such as web beacons, when you visit our Services.  These technologies can collect data regarding your operating system, browser type, device type, screen resolution, IP address, and other technical information, as well as navigation events and session information as you interact with our Services.  This information allows us to operate the Services and understand how you use the Services.

What Are Cookies?

Cookies are small files created by websites, including our Services, that reside on your computer’s hard drive and that store information about your use of a particular website.  When you access our Services, we use cookies and other tracking technologies to:

• Estimate our audience size and usage patterns;
• Store information about your preferences, allowing us to customize our Services according to your individual needs;
• Contact you to provide you with information or services that you request from us;
• Advertise new content, events, and services that relate to your interests;
• Provide you with more personalized content that is most relevant to your interest areas; and
• Recognize when you return to our Services.

We set some cookies ourselves and others are set by third parties.  You can manage your cookies preference as described in the “Managing Your Cookies” section below.

What Types of Cookies Do We Use and Why?

The following chart lists the different types of cookies that we and our service providers use on the Services, examples of who serves those cookies and links to the privacy notices and opt-out information of those cookie servers.  Because the specific cookies we use may vary over time, as well as differ by the specific page you are browsing, the below chart is illustrative only.

• Essential: These cookies are required for the operation of the Services and enable you to move around the Services and use its features.  Disabling these cookies can negatively impact the performance of Services.
• Functionality: These cookies are used to recognize you when you return to the Services.  This enables us to personalize content for you and remember your preferences.  These cookies also enable your interactions with the Services such as emailing us and customer support chat.
• Analytics, Performance, and Research: These cookies, beacons, and pixels allow us to analyze activities on the Services.  They can be used to improve the functioning of the Services.  For example, these cookies recognize and count the number of visitors and see how they move around the Services.  Analytics cookies also help us measure the performance of our advertising campaigns to help us improve them and optimize the content on the Services for those who engage with our advertising. 

We do not use analytical tools in a manner that discloses to third parties that a specific person viewed specific video materials.

How Long Do Cookies Stay on My Device?

Some cookies operate from the time you visit the Services until the end of that particular browsing session.  These cookies, which are called “session cookies,” expire and are automatically deleted when you close your Internet browser.

Some cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser.  These cookies are called “persistent cookies” and the length of time they will remain on your device will vary from cookie to cookie.  Persistent cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the Services, how your use of the Services may change over time, and the effectiveness of advertising efforts.

Managing Your Cookies

It may be possible to block cookies by changing your Internet browser settings to refuse all or some cookies.  If you choose to block all cookies (including essential cookies), you may not be able to access all or parts of the Services.

You can find out more about cookies and how to manage them by visiting https://ico.org.uk/for-the-public/online/cookies/

Do the Sites Respond to “Do Not Track” Signals?

At this time, our Sites do not respond differently based on a user’s Do Not Track signal.

Nevada Users’ Rights

Under Nevada law, certain Nevada consumers may opt out of the sale of certain personally identifiable information for monetary consideration. 

If you are a Nevada resident who has purchased or leased goods or services from us, you may (A) submit a request to opt out of any sales, and/or (B) request changes to your “covered information” by emailing us at info@claritytuition.com.  Please note we will take reasonable steps to verify your identity and the authenticity of the request.

Advertising and Marketing Choice

We respect your rights in how your personal information is used and shared.  We may communicate with you via email, telephone, postal mail, and/or your mobile device about our products and services.  If at any time you would like to unsubscribe from receiving future emails, you can email us at: info@claritytuition.com as well as follow the instructions at the bottom of each email and we will promptly remove you from all correspondence.  Please note, however, that we may still need to contact you regarding other matters. 

How Long Is Your Personal Information Kept

We will retain your personal information until the personal information is no longer necessary to accomplish the purpose for which it was provided.  We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, an unauthorized access, as necessary to protect our legal rights, or for certain business requirements.

We will delete your personal information when it is no longer necessary for the purpose for which it was collected, or upon your request, subject to exceptions as discussed in this Policy or under applicable law, contract, or regulation. 

Where Your Personal Information Is Held

We process personal information on our servers in the United States of America, and may do so in other countries.  If you use our Services or otherwise provide us with information from outside of the United States, you expressly consent to the transfer of your data to the United States, the processing of your data in the United States, and the storage of your data in the United States.

Our Commitment to Data Security

The security of your personal information is important to us.  We take various reasonable organizational, administrative, and technical measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction.  If required by law to do so, we will notify you and/or the relevant supervisory authority in the event of a data breach.

However, we cannot and do not guarantee complete security, as it does not exist on the Internet.

Third Party Links

Clarity’s Services may contain links to third-party websites.  When we provide links, we do so only as a convenience and we are not responsible for any content of any third-party website or any links contained within.  It is important to note that this Policy only applies to Clarity’s Services.  We do not control and assume no responsibility for any personal information collected, stored, or used by any third party as a result of you visiting third-party websites.  We advise that you read the privacy notice of any third-party websites you choose to visit carefully.

Children’s Privacy

Our Services are not intended for use by children under 13 years of age, and we do not knowingly collect personal information from children under 13.  In the event that we learn that we have collected personal information from a child under age 13 without verification or parental consent, we will immediately delete that information.  If you believe that we might have collected any information from a child under 13, please contact us using the information provided in the “Contact Us” section below.

Policy Changes

This Policy may change from time to time.  We will post any changes to this Policy on this page, and you should check these terms when you use the Services.  Your continued use of the website and Services constitutes acceptance of the most current version of this Policy.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email at info@claritytuition.com or at 2810 N Church St, Suite 38740, Wilmington, DE, 19802.