Privacy Policy


Last Updated: June 26, 2023

Your privacy is important to Clara Technologies Inc. (“Clara,” “we” or “us”). This Clara Technologies Inc. Privacy Policy (“Privacy Policy”) describes how Clara may collect, use, store, disclose, and process your personal information, through your access to or use of Clara products and services, including those at https://rentwithclara.com, related websites, mobile software applications, and other offerings (collectively, the “Services”). By using these Services, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Services. Clara may change this Privacy Policy from time to time by posting changes at this URL and may send notification emails. Your continued use of the Services following the posting of such changes will be deemed your acceptance of those changes.

Clara encourages you to read this Privacy Policy in its entirety, but here are a few key points of our privacy practices:

Privacy Policy Applicability

This Privacy Policy applies when you access the Services or share information with Clara, as indicated below. By using the Services, you consent to this Privacy Policy, which may be updated by us at any time. If you do not consent to this Privacy Policy for any reason, please do not use the Services or share your information with us. Please note that this Privacy Policy applies only to the Services, and not to any other third party website linked to or from it, or any third party website in which Clara content or functionality is embedded. We do not control the privacy policies or practices of others. In addition to what is provided in this Privacy Policy, certain terms related to personal information and the Services are provided in our Terms of Service, provided at https://rentwithclara.com/terms, including with respect to consumer reports and written instructions for Clara to collect such information.

Information We Collect from You

In general, we receive and collect all information you provide via the Services, including through website input fields (including advertisements), mobile application, phone, email (including email campaigns), web chat, or in other ways. This includes personal information that can identify or relates to you, including but not limited to:
- your first and last name; 
- telephone number; 
- IP address;geolocation information;
- postal and billing address; 
- email address;
- and other leasing application information provided by you.

If you are a prospective renter, we may also collect information regarding: 
- credit score, overall creditworthiness and consumer reports; 
- criminal history;
- eviction history;
- former addresses and rental history; 
- date of birth; employment history; 
- salary and income history and information (including self-reported income data such as pay stubs);
- driver’s license and/or identification card images and information;
- Social Security number;
- and images and files you may upload to your account. 

If you are a landlord or property manager or owner, we may also collect: 
- your company name(s), address, and other corporate information;
- your title;
- business email address and phone number;
- property details within a particular listing; and payment information.

You have the choice on what information to share and the services you want to engage. You can choose not to provide information to us, but in general some information about you is required in order for you to access certain functionality of the Services, such as those mentioned above or for tracking your preferences, subscribing to a newsletter, or initiating other such actions.

Information We Collect from Third Parties

We also may periodically obtain information about you from affiliated entities, partners and other independent third-party sources and plugins and will add it to our database of information. For example, we may receive information about your interaction with advertisements on third party websites and social media platforms, including updated postal addresses and demographic information. 

We may use cookies, log files, web beacons, device identifiers, advertising identifiers and similar tracking technologies, including those from third-party service providers like Google Analytics and other cloud-based tools, to automatically collect your preferences, performance data, and information about your web usage when you visit the Services. For example, we may collect your IP address, device and Internet service provider information, Web browser details and the address of any referring website. This may include collecting geolocation signals from your IP address or device settings to determine your location so that we may operate and personalize the Services for you, including to provide more relevant ads and search results.  We may also collect information about your online activity, such as pages viewed and interactions with other users. The Services are not designed to recognize or respond to “do not track” signals received from browsers. You can control the information collected by such tracking technologies or be alerted when cookies are sent by adjusting the settings on your Internet browser or devices, but such adjustments may affect or disable certain functionality of the Services. You can learn more about Google Analytics and your options for opting out of interest-based Google ads at https://adssettings.google.com.  You can learn more about targeted ads and your ability to opt out of receiving interest-based ads at optout.aboutads.info and www.networkadvertising.org/choices.

We may also collect information from the following:

- Financial Institutions and Intermediaries: Clara uses Plaid Inc. (“Plaid”) as an intermediary to gather your data from financial institutions. By using the Services, you grant Clara and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy. Clara may also collect information from financial institutions in connection with its pro vision of the Services to you.

- Credit Bureaus and Other Third Parties: We may request and receive your credit reports and credit scores from credit bureaus. As explained in our
Terms of Service, you understand that you are providing written instructions in accordance with the Fair Credit Reporting Act and other applicable law for Clara or its affiliated companies to request and receive copies of consumer reports, scores and other information about you from third parties, including, but not limited to, CRS Checks LLC (which utilizes CIC’s services) and TransUnion. Other third parties may provide additional information, such as employment, income, vehicle or driver information, or other information based on your credit profile, that allows us to customize product offerings and better evaluate applicants. For more information on CRS Group Inc.’s privacy practices, please visit https://criminal-records-search.com/privacy-page.asp. CIC’s privacy practices, please visit https://www.cicreports.com/legal-and-privacy-policy/. For more information on TransUnion’s privacy practice, please visit https://www.transunion.com/privacy/transunion.

- Service Providers to Verify and Supplement Your Information: We may rely on third parties to help us verify your identity, employment and income information, to confirm the accuracy of other information you may provide us, and otherwise to supplement your information. For example, we may use service providers to validate your mailing address or phone numbers. 

How We Use Your Information

We process your personal information with your consent or as needed to provide you Services. We may also use your personal information to comply with legal obligations, operate our business, protect the vital interests of you, our customers, or the public, or for other legitimate interests of Clara as described in this Privacy Policy.

More specifically, we may use your personal information to: 
- Optimize and improve the Services - We continually try to improve the Services based on the information and feedback we receive from you, including by optimizing the content on the Services.
- Personalize the user experience - We may use your information to measure engagement with the Services, and to understand how you and our other users interact with and use the Services and other resources we provide.
- Improve customer service - Your information helps us to more effectively develop the Services and respond to your support needs.
- Process transactions - We may use the information you provide about yourself to fulfill your requests and product orders. We do not share this information with outside parties except to the extent necessary to provide the Services, fulfill orders, and related activities.
- To send periodic communications - The contact information you provide through our contact forms or otherwise via the Services will be used to send information and updates pertaining to the Services. Such information may also be used to respond to your inquiries or other requests. You can stop receiving promotional messages from Clara by following the “unsubscribe” instructions provided in such communications or by contacting us via the contact information below. You may still receive Services-related communications, including account verification, transactional communications, changes or updates to features of the Services, and technical and security notices. 

How We Share Your Information

We share your information with our partners, service providers, contractors, agents and third party vendors as needed to fulfill Services. Please note that our partners may contact you as necessary to obtain additional information about you, facilitate any use of the Services, fulfill orders, or respond to a request you submit.

Third-party vendors who provide product, services or functions on our behalf may include business analytics companies, customer service vendors, communications service vendors, marketing vendors, delivery, parcel, and transportation vendors, and security vendors. We may also authorize third-party vendors to collect information on our behalf, including as necessary to operate features of the Services, facilitate the delivery of orders, or provide online advertising tailored to your interests. Third-party vendors have access to and may collect personal information only as needed to perform their functions, may only use personal information consistent with this Privacy Policy and other appropriate confidentiality and security measures, and are not permitted to share or use the information for any other purpose.

As a prospective renter, we may also share your information with property owners, property managers, landlords and other property professionals who manage a property listing to which you have opted to apply via the Services. 

We also may share your information:

- In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us.
- When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, interests, or safety of our company or the Services, our customers, or others; or in connection with our Terms of Service and other agreements.
- In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.With credit bureaus, collection agencies, loan service providers, lawyers, government agencies, agents, and other companies in connection with our provision of the Services, including issues related to credit, debt collection, or fraud.

Other than as set out above, we will attempt to notify you when your personal information will be shared with third parties.

Personal Information You Post in Public Areas. When you post a message in a Clara forum, chat room, review, or customer feedback, the information you post may be accessible to other users of the Services and the public. If you post personal information anywhere on the Services that is accessible to other users or the public, you are advised that such personal information can be read, collected, used, or disseminated by others and could be used to send you unsolicited information or for other purposes. Accordingly, you assume full responsibility for posting such information and agree that Clara is not responsible in any way for personal information you choose to post in these public areas.

Aggregated Information.  We may publish, share, distribute, or disclose personal information that has been aggregated with information from other users or otherwise de-identified in a manner that does not allow such data about you to be separated from the aggregate data and identified as originating from you, to third parties, including Clara partners, sponsors, and advertisers. Such information may help Clara identify and analyze training, demographic, and psychographic trends and information, and report to third parties how many people saw, visited, or clicked on certain content, areas of the Services, ads, or other materials. We may also use such data for research purposes.

How We Store and Secure Your Information

Personal information collected by Clara may be stored and processed in your region, in the United States, and in any other country where Clara or its affiliates, subsidiaries, or service providers operate facilities. Clara will retain your information as long as necessary for the purposes outlined in this Privacy Policy and for a commercially reasonable time thereafter for backup, archival, fraud prevention or detection or audit purposes, or as otherwise required by law.

Clara takes technological and organizational measures to protect your personal information against loss, theft, and unauthorized access, use, disclosure or modification. For example:
- we transmit data over secured communication channels using SSL Login credentials,
- all personal information is stored by trusted third party providers (e.g., AWS),
- all systems used to provide the Services are password protected, and
- all Services usage is restricted on a per-user basis on the principle of least privilege.

We rely on AWS’ security programs to protect personal information while stored in their respective controlled facilities. For more information on AWS’ security practices and processes, please see
https://aws.amazon.com/security/.

Clara complies with applicable data protection laws, including applicable security breach notification requirements.

Accessing and Updating Your Information

To the extent provided by the law of your jurisdiction, you may (i) have the right to access certain personal information we maintain about you and request details about how we process it, (ii) request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes, (iii) request that we update or correct inaccuracies in that information, (iv) object to our use of your personal information, (v) ask us to block or delete your personal information from our database, and (vi) request to download the information you have shared on the Services. You may make these requests and any other inquiries about this Privacy Policy by emailing
support@rentwithclara.com. Any such requests are subject to the protection of other individuals’ rights and applicable law. Additionally, to help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.

Data Retention

Clara retains personal information for the duration of your relationship with Clara, for the purposes indicated herein, or for other such period as may be permitted or required by law. If you cancel your account or stop using the Services, we may continue to retain your personal information for compliance purposes or as required by property owners, property managers, landlords and other property professionals for their compliance and business purposes. 

Renters, Properties, External Websites and other Third Parties

Except as otherwise expressly included herein, this Privacy Policy addresses only the use and disclosure of information we collect from you via the Services. If you disclose your information to others, whether they are landlords, other renters, properties or other websites, different rules may apply to their use or disclosure of the information you disclose to them. We do not control the privacy policies of third parties. We encourage you to review third parties’ privacy notices before you disclose your personal information to others.

The Services have links to other websites that may collect personal information about you if you access or use them. We are not responsible for the privacy practices or the content of those linked websites.

Additional Privacy Information

Data Transfer. Our databases are currently located in the United States. Clara makes no claim that its Services are appropriate or lawful for use or access outside the United States. If you access the Services from outside the United States, you are consenting to the transfer of your personal information from your location to the United States. You are solely responsible for complying with all local laws, rules and regulations regarding online conduct and access to the Services. By sending us your information, you further consent to its storage within the United States.

Collection of Data from Children. The Services are not directed to children, and you may not use the Services or provide any personal information to Clara if you are under the age of 13 or if you are not old enough to consent to the processing of your personal information in your country.

Your California Privacy Rights. California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please e-mail us or write to us at the addresses below.

Moreover, if you are a California resident, we are not required to, but have opted to provide this notice under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), to explain how we collect, use and share your personal information, and the rights and choices we offer California residents regarding our handling of your personal information, which the CCPA currently defines as “information that identifies, relates to, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”

1. Personal Information Collection, Use, and Disclosure: We describe the sources through which we collect personal information and the types of personal information collected in the “Information We Collect From You” section in this Privacy Policy and in the below table. We describe the third party sources from which we may collect certain of your personal information and the types of personal information collected in the “Information We Collect From Third Parties” section in this Privacy Policy and in the below table. We describe the purposes for which we use and share this information in the “How We Use Your Information” section in this Privacy Policy and in the below table. Information about how long we retain your personal information can be found in the “Data Retention” section in this Privacy Policy. 

2. California Privacy Rights: To the extent provided for by law and subject to applicable exceptions, California residents have the following privacy rights in relation to the personal information we collect:

1. Right to request access to information about categories of personal information Clara hascollected about you, specific pieces of personal information Clara has collected about you,categories of sources from which the personal information is collected, business or commercialpurpose for collecting personal information, and categories of third parties with whom thebusiness shares personal information. 2. Right to request deletion of any personal information collected about you by us. 3. Right to opt-out of the sale of personal information or the sharing or personal information forcross-context behavioral advertising purposes. Please note that we do not sell personalinformation we collect from you nor do we share it for cross-context behavioral advertisingpurposes, in accordance with the applicable definitions in the CCPA and its supplemental regulations. 4. Right against discrimination because you exercised the rights available to you. 5. Right to protection against waiver of rights. 6. Right to correct any inaccurate personal information. 7. Right to restrict sensitive personal information processing.

You can request to exercise the rights described above as set forth in the “How to Contact Us” section in thisPrivacy Policy. You may request to exercise these rights by yourself or via an authorized agent who meets the agency requirements of CCPA. Once you request to exercise your rights, you agree to receive communication from us seeking information from you in order to verify your identity as the consumer from whom we have collected the personal information and such other information as reasonably required to enable us to fulfill your request in our discretion. We will not fulfill any request unless you have provided sufficient information for us to reasonably verify that you are the consumer from whom we collected personal information, as well as sufficient details necessary to help us handle the request. Clara is not currently required to comply with CCPA and may or may not honor any requests to exercise rights under the CCPA in its sole discretion.

Note: The Services do not respond to browser “Do Not Track” (DNT) signals and operates as described in thisPrivacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.

How to Contact Us. You can e-mail us at support@rentwithclara.com. Depending on where you are located, you may also have a right to complain to your local data protection regulator.

Click to download a copy of this Privacy Policy

Category of Personal Information Categories of Sources from which such Personal Information is Collected Business of Commercial Purpose(s) for which such Personal Information is Collected, used and/or Shared Categories of Third Parties or Services Providers with whom we share such Personal Information
Identifiers: may include first and last name, postal address, telephone number, IP address, email address, social security number, driver’s license, passport and identification card images and information or other similar identifiers You

Credit bureaus and credit reporting agencies

Third-party providers of consumer data for customer verification

Service providers

Current or former employers, landlords, property managers and property owners

Other users of the Services (e.g. roommates, guarantors, etc.)
Account services

Security and fraud detection

Debugging

Improvement of the Services

Advertising and promotional services

Legal obligations

Merger, acquisition, bankruptcy or other organizational matter

Commercial or economic interests

Verification services and functions in connection with the provision of the Services
Credit bureaus and credit reporting agencies

Advertising networks

Internet service providers

Data analytics providers

Service providers

Landlords, property managers and property owners who are users of the Services
Personal Information Described in the California Customer Records Statute (Cal. Civ. Code §1798.80(e)): may include name, signature, social security number, physical characteristics or description, address, telephone number, driver’s license or identification card number, education, employment, employment history, financial information, or other similar information You

Credit bureaus and credit reporting agencies

Third-party providers of consumer data for customer verification

Service providers

Other users of the Services (e.g. roommates, guarantors, etc.)
Account services

Security and fraud detection

Debugging

Improvement of the Services

Advertising and promotional services

Legal obligations

Audits

Merger, acquisition, bankruptcy or other organizational matter

Commercial or economic interests

Verification services and functions in connection with the provision of the Services
Credit bureaus and credit reporting agencies

Advertising networks

Internet service providers

Data analytics providers

Service providers (including third party payment providers)

Landlords, property managers and property owners who are users of the Services
Characteristics of Protected Classification under California or Federal Law: may include age, race, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression childbirth, and related medical conditions), sexual orientation, veteran or military status You

Credit bureaus and credit reporting agencies

Third-party providers of consumer data for customer verification

Service providers
Account services

Legal obligations

Audits

Commercial or economic interests

Verification services and functions in connection with the provision of the Services
Credit bureaus and credit reporting agencies

Advertising networks

Internet service providers

Data analytics providers

Service providers

Landlords, property managers and property owners who are users of the Services
Commercial Information: may include records of products or services used or purchased, listing information regarding properties listed on the Services, or other purchasing or consuming histories or tendencies. You

Third party payment providers

Third party providers of listing and/or real estate data

Data analytics providers

Service providers
Account services

Legal obligations

Advertising and marketing services

Security and fraud detection

Commercial/economic interests
Service providers (including third party payment providers)

Data analytics providers
Biometric Information: we do not collect this information N/A N/A N/A

 

Internet or Other Electronic Network Activity Information: may include browser type, search history and information regarding your interaction with the Services or any advertisement, information collected automatically through cookies and similar technology, device type, domain names, and access time/logs. You

Credit bureaus and credit reporting agencies

Third party data providers

Data analytics providers

Internet service providers

Operating systems and platforms

Social networks

Service providers
Account services

Legal obligations

Advertising and marketing services

Security and fraud detection

Commercial/economic interests
Third party data providers

Data analytics providers

Internet service providers

Operating systems and platforms

Social networks

Service providers
Geolocation Data: may include physical location or movements, or IP addresses You

Data analytics providers

Internet service providers

Operating systems and platforms

Service providers
Account services

Legal obligations

Security and fraud detection

Commercial/economic interests

Improvement of the Services
Third party data providers

Data analytics providers

Internet service providers

Operating systems and platforms

Service providers
Sensory Data: may include audio, electronic, visual, thermal, olfactory or similar information You

Service providers
Account services

Security and fraud detection

Debugging

Improvement of the Services

Advertising and promotional services

Legal obligations

Audits

Commercial or economic interests
Service providers
Professional or employment-related information: may include current or past employment history or performance You

Credit bureaus and credit reporting agencies

Third party data or service providers
Security and fraud detection

Debugging

Improvement of the Services

Legal obligations

Commercial or economic interests

Verification services and functions in connection with the provision of the Services
Third party data providers

Service providers

Landlords, property managers and property owners who are users of the Services

 

Non-public education information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. §1232g, 34 C.F.R. Part 99): This may include education records directly related to a student maintained by an educational institution or party acting on its behalf, such as report cards, transcripts, class lists, student schedules, student identification codes, student financial information, and student disciplinary records. You Security and fraud detection

Debugging

Improvement of the Services

Legal obligations

Commercial or economic interests

Verification services and functions in connection with the provision of the Services
Third party data providers

Service providers

Landlords, property managers and property owners who are users of the Services
Inferences drawn from other personal information: may include information, data, assumptions or conclusions derived from facts, evidence or another source of information or data reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities or aptitudes. You

Credit bureaus and credit reporting agencies

Third party data or service providers

Service providers
Account services

Security and fraud detection

Debugging

Improvement of the Services

Advertising and promotional services

Legal obligations

Audits

Commercial or economic interests

Merger, acquisition, bankruptcy or other organizational matter
Credit bureaus and credit reporting agencies

Advertising networks

Internet service providers

Data analytics providers

Service providers
Sensitive Personal Information: may include social security number, date of birth, driver’s license, passport, identification card and other government-issued ID You

Credit bureaus and credit reporting agencies

Third-party providers of consumer data for customer verification

Service providers

Current or former employers, landlords, property managers and property owners
Account services

Security and fraud detection

Debugging

Legal obligations

Commercial or economic interests

Verification services and functions in connection with the provision of the Services
Credit bureaus and credit reporting agencies

Service providers

Landlords, property managers and property owners who are users of the Services