Last updated: June 10, 2025

 

This Privacy Notice describes how Cleerly, Inc. (“Cleerly,” “us,” or “we”) collects, uses, and shares your personal information when you visit our website at https://cleerlyhealth.com, or its affiliated and successor sites (the “Site”). For the additional privacy practices that apply to our customers who use our Cleerly analysis services (the “Application” and collectively with the Site, the “Services”) as healthcare providers, imaging centers, or healthcare referral partners (“Customers”), please go to the section of this Privacy Notice entitled “Privacy Notice Supplement for Our Customers”.

This Privacy Notice does not apply to protected health information we process on behalf of our Customers, nor does it apply to consumer health data subject to Cleerly’s Consumer Health Privacy Policy.

In this Privacy Notice, we use the term “Personal Information” to refer to information we gather that could be used to identify you and any information we gather concerning your use of the Services. We also collect non-personal information, which is information that does not reveal your specific identity or from which your identity has been redacted, through your use of our Services.

We may modify or update this Privacy Notice from time to time. If we make changes, we will notify you by revising the date at the top of the notice and, in some cases, we may provide you with additional notice as required by applicable law (such as adding a statement to our website homepage). Changes to this Privacy Notice are effective from the date on which they are posted. We encourage you to review the Privacy Notice whenever you access the Site, use our Services or otherwise interact with us to stay informed about our privacy practices.

Our Services are intended for access and use by users that reside within the U.S. and its Territories. If you are not a resident of the U.S. or its Territories, you should not attempt to access or use our Services. If you do not agree with our policies and practices, you should not access or use our Services. By accessing or using our Services, you agree to this Privacy Notice.

Information We Collect

How we collect and store information depends on your relationship and interactions with us. The categories of Personal Information that we may collect about you include the following:

• Identifiers, such as your name, telephone number, email address, unique personal identifiers such as IP addresses and device identifiers, and other similar identifiers;
• Demographics, such as your gender, race, ethnic background;
• Internet or other network activity information, such as browser type, language, operating system, mobile device information like device and application identifiers, and pages visited;
• Geolocation data, such as precise location;
• Health and health insurance information, such as medical information you may provide when you contact us or information you may upload or provide to us regarding your medical insurance coverage, if you are interested in Cleerly’s services and partnership with third parties;
• Professional information, such as employer, salary, job title, experience, skill, or expertise;
• Inferences regarding preferences or other characteristics.

Certain demographic data, geolocation data, and health information may be considered sensitive data under applicable state comprehensive privacy laws.

How We Use Your Information

We use the Personal Information we collect to:

• Provide, maintain and improve the Services;
• Respond to your comments, questions, and customer service requests;
• Send you information regarding our Services, including updates and newsletters (see Your Rights and Options Regarding Your Personal Information below for information about how to opt out of these communications at any time);
• Send you technical notices, updates, security alerts, and support and administrative messages;
• Consider your application for employment if you have applied for a job with us;
• Monitor and analyze trends, usage, and activities in connection with the Services;
• Debug to identify and repair errors that impair existing intended functionality;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and protect the rights and property of Cleerly and others;
• As we deem necessary to protect the rights and safety of us, you, or others;
• Comply with laws, regulations, and legal processes; and
• In connection with research and development activities.

We may de-identify data so that it cannot reasonably be re-identified by us or by another person, and we may use this de-identified data for any reason permitted by applicable law. If we de-identify information that was originally based on Personal Information, we maintain and use that information in de-identified form and will not attempt to re-identify the data, except as otherwise permitted under applicable law.

Information Sharing

We may share your personal information in the following limited circumstances:

• With service providers, business partners and corporate affiliates as needed to provide the Services and operate our business, who process it for us, based on our instructions, and in accordance with this notice. These providers, partners and affiliates provide us with business services including data hosting and warehousing, data analysis, information technology customer support, and insurance reimbursement appeal services;
• With law enforcement, a court, a regulator, a government authority or other third party where we believe it is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party;
• To enforce any applicable terms of use or service, and to ensure the safety and security of the Services;
• In connection with an asset sale, merger, bankruptcy, or other business transaction;
• With any other party with your consent or at your direction.

No mobile information (phone numbers) will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Your Options Regarding Your Personal Information

You may unsubscribe from receiving promotional emails and newsletters from us by following the instructions in those emails. If you unsubscribe, we may still send you non-promotional emails, such as those about our ongoing business relations.

We do not currently respond to “do not track” signals from browsers. If you block cookies, certain features on our Site may not work.

If you live in certain jurisdictions, you may have a number of legal rights with respect to your information. Please see the “Additional Disclosures for Nebraska and Texas Residents” section below.

Retention of Personal Information

We generally retain records as long as necessary, and as required for our business operations, for archival purposes, and/or to satisfy legal requirements. When determining the appropriate retention period for Personal Information, we take into account various criteria, such as the amount, nature, and sensitivity of the Personal Information; potential risk of harm from unauthorized use or disclosure; purposes for which we process your Personal Information; whether we can achieve those purposes through other means; and business operations and legal requirements.

Analytics and Advertising Services Provided by Others

We work with third parties who provide us with analytics and advertising services, including Google Analytics and Showpad, to collect information about your usage and to help us understand how users interact with the Services, serve advertisements on our behalf across the internet, and measure the performance of those advertisements. These companies may use cookies and similar technologies to collect information about your interactions with the Services and other websites and applications. For more information about how Google uses information from sites or apps that use Google Analytics, click here. For more information about how Showpad uses information from sites or apps accessed by Showpad, click here.

Children’s Privacy

Our Services are not intended or targeted at children under 16 years of age, and we do not knowingly or intentionally collect Personal Information from or about children under 16. If you are under 16, do not use or provide any information to our Services. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete it. If you believe that we have collected Personal Information about a child under 16, please contact us using the contact information at the end of this notice so that we may delete the information.

Additional Disclosures for Nebraska and Texas Residents

This section applies to the personal information of residents of Nebraska and Texas and supplements the other sections of this Privacy Notice.

For information on the categories of Personal Information that we may process, the purposes for which we process that Personal Information, and how we disclose that Personal Information, please refer to the sections above.

We may disclose your Personal Information to third parties for the business purposes outlined above. We also may “sell” or “share” your Personal Information for targeted advertising, as defined by applicable law, with third parties for those business purposes. In the preceding twelve (12) months, we may have sold or shared your Personal Information, or disclosed it for a business purpose, to the following categories of third parties:

Category	Categories of Third Parties to Whom We Disclosed Personal Information for Business Purposes	Categories of Third Parties to Whom We Sold or Shared Personal Information
Identifiers		N/A
Demographics		N/A
Internet or other similar network activity		Advertising and analytics partners
Geolocation data		[Advertising and analytics partners]
Health and health insurance information		N/A
Professional information		N/A
Inferences		Advertising and analytics partners

 

We have no actual knowledge that we sell the personal information of minors under 16 years of age.

Privacy Rights

If you are a Nebraska or Texas resident, subject to certain limitations, you may have the following rights concerning your Personal Information:

• Right to Know. You may have the right to request that we confirm whether we process your Personal Information and that we provide you access to such Personal Information.
• Data Portability. You may have the right to request that we provide a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format.
• Right to Deletion. You may have the right to request that we delete any of the Personal Information we have collected or maintain about you.
• Right to Correction. You may have the right to correct inaccuracies in your Personal Information.
• Right to Opt-out of Sales of Personal Information and Targeted Advertising. You may have a right to opt-out of the sale of your Personal Information, including cross-context behavioral advertising, and to opt-in again at your election.

Exercising Your Rights Under Applicable Law

You, or an authorized agent, may exercise your rights by submitting a request to info@cleerlyhealth.com. We respond to and process requests promptly and within the timeframes required by applicable law. Please note that all requests are subject to proper prior verification before processing, as required by applicable law. You may also have the right to appeal a refusal to take action on your request by emailing us at info@cleerlyhealth.com with the subject line “Appeal of Rights Request Decision.”

If you are the authorized agent of an individual making a request, you may have to take additional steps to verify your identity and demonstrate that you can exercise the individual’s rights on their behalf.

 

Third Party Websites and Links

This Privacy Notice does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including our Customers, the manufacturer of your mobile device, and any other third party mobile application or website to which the Services may contain a link, including third party services or platforms. We do not control such third parties and are not responsible for the content of their platforms, their privacy policies, or their use of your information. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy. We encourage you to review the Notice of Privacy Practices of your healthcare provider or health plan and the privacy policies of each website and application you visit and use. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of Personal Information by third parties.

Information Security and Storage

We take reasonable steps to safeguard your personal information. We implement certain technical and organizational measures to protect the personal information we process. These measures are aimed at protecting the integrity and confidentiality of personal information. However, no method of transmitting or storing data is completely secure, and we cannot guarantee security for data collected over the Internet or any other public network.

Contact Us

If you have questions or concerns regarding the way in which your personal information has been used, please contact us at info@cleerlyhealth.com

Privacy Notice Supplement for Our Customers

Cleerly offers a web-based software application intended for use by trained medical professionals in viewing and analyzing cardiac computed tomography (“CT”) data, obtained using any CT scanner, for (i) measuring and visualizing coronary arteries and determining the presence and extent of coronary plaques and stenosis and/or (ii) estimating the likely presence or absence of ischemia in patients who have undergone Coronary Computed Tomography Angiography for assisting evaluation of coronary artery disease (“CAD”) or suspected CAD. As used in this Privacy Policy Supplement for Customers, “Customer” or “you” means the provider of cardiovascular health services or imaging services that has entered into a Master Services Agreement with Cleerly and/or accepted the Cleerly Labs Software and Services Terms & Conditions (“Terms & Conditions”).

Before any accounts can be fully activated, Customers must agree to the Master Services Agreement and/or Terms & Conditions and register each Authorized User within Customer’s organization. “Authorized Users” means users affiliated with Customer who are authorized to access Cleerly’s Application.

Information We Collect

By registering for and accessing our Application, you are consenting to our collection, maintenance, use, disclosure, and processing of information about you and the Authorized Users in the organization you represent. In order to provide the Application, we collect, use, disclose, and maintain information that includes the Personal Information of Authorized Users. We will only use, disclose, process and maintain this Personal Information according to our Master Services Agreement, Terms & Conditions, this Privacy Notice or as required by law.

We collect several types of information from and about you and your Registered Users through the use of our Services, specifically Personal Information by which you or your Authorized Users may be personally identified, including but not limited to, name, e-mail address, IP address, device information, browser statistics, timestamps of activity, systems and performance tracking information.

How We May Use and Disclose Personal Information of Customers

We will use the Personal Information that is provided through the registration process to verify the credentials that were provided about each Authorized User to confirm that the information that was provided is accurate, correct, and up-to-date. Cleerly will also use Customer information to provide the Service; to send administrative information, including information regarding our Services; and provide you with related customer service; as necessary or appropriate under applicable law or to comply with legal processes; to respond to requests from government authorities; to enforce our terms of service; to protect our operations or those of any of our affiliates; to protect our rights, privacy, safety or property, or that of our affiliates, you or others; or to allow us to investigate a security incident or breach of our IT systems and to pursue available remedies or limit the damages that we may sustain.

We may share Customer Personal Information with service providers that we collaborate with or hire to perform services on our behalf and in accordance with our instructions. We may also use your and your Authorized Users’ Personal Information along with de-identified or aggregated patient information to perform analytics and to gather insights that will help improve the user experience. We may also share your connection and site usage details (such as the equipment you use to access our data and access records) with service providers to improve the Services.

If you have any concerns, you may contact us at info@cleerlyhealth.com.