THIS POLICY APPLIES TO UK & EU USERS ONLY. PLEASE NAVIGATE TO THE FOOTER AND CHOOSE TERMS & CONDITIONS FOR NON-UK/EU USERS IF APPLICABLE.
1. Introduction
ClarityCheck ("we," "us," "our," or the "Company") is committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR) for EU and UK users. This Privacy Policy describes how we collect, use, retain (including by temporary caching where enabled), store, and disclose personal data when you access or use the ClarityCheck.com website and all its subdomains (collectively, the "Site") and our lookup services and related tools (the “Services”).
2. Information Collection Practices
2.1 Types of Information Collected
We collect the following types of information:
a) User Information: Information you provide when you use our Site, including:
Contact Data (name, surname, email address)
Payment Data (PayPal account, Credit Card information)
b) Search Query Information: Information you provide as part of your search query (e.g., phone numbers, email addresses) to generate reports.
c) Publicly Available Information: Information we collect in real-time from various public databases, websites, and other publicly accessible sources to create our reports.
d) Stored Report Information (Reports History): Where you choose to use our “Reports History” / “Cached Reports” feature, we temporarily store the report output associated with your account so you can re-open it without re-running the same search. Cached Reports may contain personal data (e.g., names, addresses, phone numbers, email addresses, and social profiles) to the extent included in the report output. Cached Reports are not publicly displayed, indexed, or searchable, and are accessible only to the authenticated account that generated them.
e) Usage/Technical Data: We collect standard technical and usage data (e.g., device identifiers, browser type, IP address, timestamps, and log data) as necessary to operate, secure, and improve the Services. We do not use stored report output to build a public directory of individuals or for advertising targeting.
2.2 Sources of Information
We obtain the categories of information listed above from the following sources:
a) Directly from our clients as part of the registration process (for User Information only).
b) Information collected in real-time from public websites, databases, and other publicly accessible sources using OSINT techniques.
c) Information obtained through real-time HLR Lookups for mobile phone number queries.
2.3 Reverse Image Search Processing
If you choose to use ClarityCheck's reverse image search feature, you may upload an image for the sole purpose of performing the requested search. Before an image is uploaded, users must confirm that they are at least 18 years old, own the image, appear in the image, or otherwise have the legal right and necessary permissions to submit it for processing.
To perform the requested search, ClarityCheck may temporarily process the uploaded image, including creating cropped, resized, or other temporary derivative files that are reasonably necessary to compare image similarity, generate search results, and display the requested report. These temporary processing files are used solely for operational purposes and are retained only for the applicable retention period described in this Privacy Policy.
ClarityCheck does not create or maintain a proprietary facial-image index or database of biometric profiles. Images uploaded solely for reverse image searches are not used for advertising, promotional purposes, or AI model training unless you separately provide your express consent.
Before uploading an image to use the reverse image search feature, users must confirm that they are at least 18 years old and that they own the image, appear in the image, or otherwise possess the legal right, authority, and any necessary permissions to submit the image for the requested search. By proceeding, users also consent to the processing of the uploaded image as described in this Privacy Policy and agree to the applicable Terms & Conditions.
3. Legal Basis for Processing
a) User Account Information: We process account and billing/transaction information as necessary to perform our contract with you (i.e., to provide the Services you request) and to comply with applicable legal obligations (e.g., accounting and fraud prevention). Where required, we may also rely on consent for specific optional processing activities.
b) Search Query Information: The legal basis for processing search query information is the performance of our service as a search engine, which you request when you place an order to search for information.
c) Publicly Available Information: We process publicly available information based on our legitimate interest in providing a comprehensive search service to our customers.
d) Stored Report Information (Reports History): We process and temporarily store stored report output based on our legitimate interests in providing an improved user experience (allowing you to re-open a previously generated report without re-running the same search), and/or as necessary to perform our contract with you where the feature is enabled as part of the Services you request. This feature is optional, purpose-limited, and time-limited as described below.
e) Cookies/Similar Technologies: Where required by law, we rely on your consent for non-essential cookies and similar technologies.
f) Email Open and Click Tracking: We use tracking pixels and tracked links in our emails to measure engagement. For recipients in jurisdictions that require prior consent for such tracking — including France (in line with CNIL guidance) and Italy — we rely on your consent, and we do not track your email opens or clicks unless you have opted in. For recipients elsewhere, we rely on our legitimate interest in measuring and improving our communications. You may grant or withdraw consent at any time (see the "Email Communications and Tracking" section).
4. Use of Information
We use the collected information to:
a) User Account Information: The legal basis for processing your account information is your consent, which you provide when you create an account and agree to our privacy policy and terms and conditions.
b) Search Query Information: The legal basis for processing search query information is the performance of our service as a search engine, which you request when you place an order to search for information.
c) Publicly Available Information: We process publicly available information based on our legitimate interest in providing a comprehensive search service to our customers.
5. Email Communications and Tracking
Technologies used. We use tracking pixels (also called web beacons) and unique tracked links in the emails we send you (such as newsletters and product updates) to understand engagement with our communications. This is provided through our email service provider, Customer.io, acting as our processor.
Data collected. Where tracking is active, we may record whether and when you opened an email, your approximate location (derived from your IP address), and which links you clicked.
Consent and your choices. Where prior consent is required — including recipients in France and Italy — email open and click tracking is off by default and is enabled only if you opt in. You can grant or withdraw your consent at any time using the "Manage Tracking Preferences" link in the footer of our emails; your choice applies to future emails. You can also limit open tracking by disabling automatic image loading in your email client (note this does not prevent link-click tracking). Managing tracking preferences does not unsubscribe you from our emails.
Legal basis. Consent for recipients where required, and legitimate interest for other recipients (see Section 3).
6. Data Storage and Retention
ClarityCheck generally retrieves report data in real time to generate results and does not maintain a public “people-search” database of EU/UK/CH residents. However, we do store certain data in the following limited ways:
a) Account Information: We retain account information for as long as your account is active and as needed thereafter for legitimate business purposes and legal compliance. You may request deletion of your account via our Help Center
b) Cached Reports (Reports History): If you use the Reports History / Cached Reports feature, we temporarily store the report output associated with your account for a limited period of time. Cached Reports are retained for no longer than 120 days (as shown in the product interface) and are then automatically deleted from our active systems within a commercially reasonable timeframe, subject to limited exceptions for security, fraud prevention, backups, and legal compliance. If you use the reverse image lookup feature, uploaded images together with related temporary processing files and report-cache assets generated to perform the requested search are retained for no longer than seven (7) days (as shown in the product interface) and are then automatically deleted from our active systems within a commercially reasonable timeframe, subject to the same limited exceptions.
c) User Controls: Where the Reports History feature is available, you may delete individual Cached Reports or clear your report history at any time through the Services. Deleted Cached Reports will be removed from your account and scheduled for deletion from our active systems within a commercially reasonable timeframe, subject to limited exceptions for security, fraud prevention, backups, legal compliance, and other applicable legal obligations.
d) Access Controls: Cached Reports are accessible only to the account that generated them and are not shared with other users unless and until we introduce an explicit “share” feature with additional disclosures and safeguards.
e) Security Logs: We may retain certain technical, security, and audit logs for limited periods as necessary to operate, secure, and protect the Services.
7. RIGHT TO ERASURE AND DELISTING FROM SEARCH RESULTS (RIGHT TO BE FORGOTTEN)
ClarityCheck respects your rights under the UK GDPR and EU GDPR, including the right to request suppression or removal of information from future search results displayed through the ClarityCheck platform where required by applicable law. ClarityCheck does not maintain a proprietary facial-image index or database of biometric profiles. Depending on the feature used, search results may be generated in real time from publicly available and licensed sources or may be temporarily available through cached report results associated with your account. Where applicable, we may suppress, block, delist, or otherwise prevent the future display of relevant information within the ClarityCheck platform in accordance with applicable law.
How to exercise your Right to Erasure from our search results:
a) Submit a Request: Contact us via our Help Centre (link available in the footer) or email our Privacy Officer directly with a "Right to Erasure Request."
b) Verification: We may ask you to provide specific links, screenshots, or reasonable identification to verify that the search results in question relate to you.
c) Processing: Upon receiving a valid request and where required by applicable law, we will take reasonable technical measures to suppress, block, delist, or otherwise prevent the future display of the relevant information within the ClarityCheck platform. Where applicable, this may include removing information from future search results, restricting access to cached report results, or applying suppression records. We cannot remove or modify information maintained by third-party websites or data providers.
d) Cached Reports: If your data is part of an existing Cached Report (Reports History) generated by another user, we will take reasonable technical steps to purge or anonymize your specific data from our active caches.
Important Note: Removing your information from ClarityCheck's search index does not remove it from the original third-party websites or the internet at large. We strongly advise you to also contact the original source websites if you wish to have your data permanently deleted from the web.
8. Data Minimization
We only collect and process data that is necessary for providing our service. This includes your name, surname, email, and payment details, which are stored securely in a PCI-DSS compliant vault.
9. Your Rights Under GDPR
As an EU or UK user, you have the following rights:
a) The right to access your personal data
b) The right to rectify inaccurate personal data
c) The right to erase your personal data
d) The right to restrict processing of your personal data
e) The right to data portability
f) The right to object to processing of your personal data
g) Rights related to automated decision-making and profiling
10. Cross-border Data Transfers
We store our data in the United States. The EU-U.S. Data Privacy Framework provides safeguards for transferring personal data from the EU to the US. We use standard contractual clauses for international data transfers.
11. Automated Decision-Making and Profiling
We may use automated decision-making and profiling based on the cookie policy and consent you have given to us.
12. Data Security
We maintain reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, and disclosure. These safeguards include, where appropriate, access controls, encryption, authentication mechanisms, monitoring, and other security measures appropriate to the nature of the information we process. We do not store your passwords and use magic links to authenticate your account. Payment information is processed and stored by PCI DSS compliant payment providers using appropriate security safeguards. While we strive to protect personal information, no method of transmission over the Internet or electronic storage can be guaranteed to be completely secure, and we cannot guarantee absolute security.
13. Security Incident Notification
ClarityCheck maintains administrative, technical, and organizational procedures designed to identify, investigate, contain, and respond to security incidents involving personal information. Where we determine that a security incident requires notification under applicable law, we will notify affected individuals, supervisory authorities, regulators, and other relevant parties in the manner and within the timeframes required by applicable law. Not every security incident requires notification, and the form, timing, and recipients of any notification will depend on the nature of the incident and applicable legal requirements.
14. Children's Data
Based on our terms and conditions, we do not provide our service to people under 18 years old.
15. Data Protection Officer (DPO)
You can contact our Data Protection Officer at [email protected].
16. Cookies
For more information, please refer to our separate Cookie Policy, which can be found in the footer of this website.
17. Changes to Privacy Policy
ClarityCheck may amend this Privacy Policy from time to time. We will notify you of significant changes by posting a prominent notice on our website or sending you an email notification.
18. Contact Information
If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us via our Help Center (see link in the footer) or our Privacy Officer at:
Email: [email protected]
Mailing address: 2093 Philadelphia Pike #7776, Claymont, DE 19703, USA