California Privacy Notice

1. Scope of This Notice

This California Privacy Notice ("Notice") supplements our general Privacy Policy and provides additional information for California residents as required by the California Consumer Privacy Act of 2018 ("CCPA") as amended by the California Privacy Rights Act of 2020 ("CPRA").

This Notice applies to California residents who use Clearly and describes your rights under California privacy law.

2. Categories of Personal Information We Collect

In the preceding 12 months, we have collected the following categories of personal information:

3. Sources of Personal Information

We collect personal information from the following sources:

• Directly from you: Information you provide when creating an account, entering financial data, or contacting us
• Automatically: Information collected through cookies, analytics, and similar technologies when you use our Service
• Third-party authentication providers: Basic profile information when you sign in using Google or other providers

4. Business Purposes for Collection

We collect and use personal information for the following business purposes:

• Providing and maintaining our budgeting Service
• Processing your requests and transactions
• Creating and managing your account
• Communicating with you about our Service
• Improving and developing our Service
• Ensuring security and preventing fraud
• Complying with legal obligations
• Debugging and repairing errors
• Internal research and analytics

5. Disclosure of Personal Information

In the preceding 12 months, we have disclosed the following categories of personal information for business purposes:

• Identifiers: To service providers for hosting, authentication, and analytics
• Internet/Network Activity: To analytics providers to improve our Service

We disclose personal information to service providers who assist us in operating our Service, subject to contractual obligations to protect the data.

6. Sale and Sharing of Personal Information

7. Sensitive Personal Information

We may collect the following categories of sensitive personal information:

• Account login credentials: Email and password for your Clearly account
• Financial information: Budget data, income, expenses, and savings goals that you manually enter

We use sensitive personal information only for the purposes necessary to provide our Service, as permitted under the CCPA/CPRA. We do not use or disclose sensitive personal information for purposes beyond what is necessary to provide the Service.

8. Your California Privacy Rights

As a California resident, you have the following rights under the CCPA/CPRA:

Right to Know

You have the right to request information about the categories and specific pieces of personal information we have collected about you, the sources of that information, the purposes for collecting it, and the categories of third parties with whom we share it.

Right to Delete

You have the right to request that we delete the personal information we have collected from you, subject to certain exceptions (such as compliance with legal obligations or completing transactions).

Right to Correct

You have the right to request that we correct inaccurate personal information we maintain about you.

Right to Opt-Out of Sale/Sharing

You have the right to opt-out of the sale or sharing of your personal information. However, as noted above, we do not sell or share your personal information for cross-context behavioral advertising.

Right to Limit Use of Sensitive Personal Information

You have the right to limit our use of sensitive personal information to purposes necessary to provide the Service. We only use sensitive personal information for such necessary purposes.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. We will not:

• Deny you goods or services
• Charge you different prices or rates
• Provide you a different level or quality of service
• Suggest that you may receive a different price or quality of service

9. How to Exercise Your Rights

To exercise your California privacy rights, you may submit a request through any of the following methods:

• Email us at privacy@clearly.money
• Use the account settings in the app to delete your account and data

Verification

To protect your privacy, we will verify your identity before fulfilling your request. We may ask you to:

• Confirm your email address by responding to a verification email
• Provide information that matches what we have on file

Authorized Agents

You may designate an authorized agent to submit requests on your behalf. We may require the authorized agent to provide proof of authorization and may still require you to verify your identity directly.

Response Timing

We will respond to verifiable requests within 45 days. If we need more time (up to 90 days total), we will notify you of the reason and extension period.

10. Retention of Personal Information

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. See ourPrivacy Policyfor detailed retention periods.

11. Financial Incentives

We do not offer financial incentives or price differences in exchange for the retention or sale of personal information.

12. Changes to This Notice

We may update this California Privacy Notice from time to time. We will notify you of any material changes by posting the new Notice on this page and updating the "Last Updated" date.

13. Contact Us

If you have any questions about this California Privacy Notice or wish to exercise your rights, please contact us:

• Email: privacy@clearly.money
• Subject Line: "California Privacy Request"