Privacy Policy

Last updated: April 20, 2026

1. Overview

Clear Fracture Holdings LLC and subsidiaries (“Clear Fracture”, “us”, “our” or “we”) are committed to complying with data protection legislation, including the General Data Protection Regulation (EU Regulation 2016/679) and the California Consumer Privacy Act.

This Privacy Policy (“Policy”) provides detailed information about the data collected, how it's used, and your rights regarding that data.

The company processes some personal data in day-to-day business. In certain circumstances, data may be shared with third parties (pursuant to court order, merger, or with business partners and service providers). Clear Fracture takes privacy and security seriously and has implemented safeguards.

2. Privacy Policy

2.1 Introduction

Clear Fracture values privacy and remains committed to protecting it. This Policy details information types collected, how information is used, secured, and disclosed.

The Policy applies only to Clear Fracture — not to third-party sites or applications linking to or accessible through our website. Clear Fracture is not responsible for third-party privacy policies or practices.

By accessing or using any Clear Fracture site, service, or product (including email communications), you consent to this Policy. The Policy may change over time, affecting data usage. Review periodically for updates.

2.2 Use and Security of Data

2.2.1 Information You Provide

Clear Fracture may request or you may provide information, including personal information that identifies you: name, employer, email address, telephone number, and correspondence records.

2.2.2 Information from Website Forms

Information provided when contacting Clear Fracture through our website, including problem reports.

2.2.3 Usage Details, IP Addresses, and Cookies

When visiting our website, Clear Fracture may automatically collect information about computing equipment, browsing actions using cookies and web beacons. This includes connectivity details, IP address, browser information, location data, logs, and website activity.

2.2.4 Email Marketing

Current, previous, or prospective customers may receive emails regarding products and services. Processing includes beacon placement indicating email opens. The company does this to determine if emails are received and valued, improving content and services. Location or device information is never tracked in this processing.

2.2.5 General Business-Related Information

Clear Fracture may receive other personal information about you in ordinary business course.

Information Use:

  1. Present websites, products, and services
  2. Improve products and services
  3. Provide requested product/service information
  4. Provide notices about products, services, changes, new offerings, website changes, promotions, and events
  5. Improve and maintain website, product, and service security
  6. Sell third-party products/services believed to interest you (with opt-out opportunity)
  7. Process transaction-related information, including purchases
  8. Ordinary business operations: human resources, recruiting, investments, research, and outreach

2.2.6 Legal Basis for Processing

Clear Fracture processes personal data only with legal basis, including:

  1. You provided consent for specific purposes
  2. Processing necessary to perform contract or take pre-contract steps
  3. Legal obligation compliance
  4. Vital interests protection for you or another person
  5. Public interest task execution
  6. Legitimate interests (without unduly affecting your rights or freedoms)

For special category information processing:

  1. Information is publicly available
  2. Processing necessary to establish, exercise, or defend legal claims
  3. Substantial public interest processing
  4. Explicit consent provided (where legally permitted)

2.3 Disclosing Your Information to Others

Clear Fracture will not rent or sell information. However, we may disclose collected information:

  1. To successor in interest from merger, acquisition, or asset transfer
  2. To subsidiaries, affiliates, agents, contractors, service providers, and third parties
  3. Comply with court orders, legal processes, or legitimate government/regulatory requests
  4. Enforce terms, conditions, and agreements
  5. Protect company rights, property, security

2.4 International Transfer of Your Information

Clear Fracture may transfer or access personal information from offices, subsidiaries, and affiliates in various business locations, including the United States, EEA, and non-EEA countries. For transfers outside the EEA, safeguards ensure compliance with applicable laws.

2.5 Integrity and Extent of Collection

Clear Fracture collects and stores personal information only as necessary for identified purposes.

2.6 Your Rights and How to Exercise Them

You may have rights to:

  1. Object to personal data processing
  2. Request personal data erasure
  3. Request processing restriction
  4. Withdraw consent

2.7 How to Exercise Your Rights

Send email to privacy@clearfracture.ai

2.8 California Consumer Privacy Act

Pursuant to the CCPA, Clear Fracture certifies not selling California residents' personal information. Covered individuals may request disclosures or deletion. Submit requests to privacy@clearfracture.ai with “CCPA Request” in subject line.

2.9 Security

Clear Fracture implements extensive security measures. We cannot guarantee internet transmission security.

2.10 Data Retention

Data retained only as long as necessary for collection purposes and compliance.

2.11 Changes to This Policy

May amend Policy; changes published on website.

2.12 Children Under the Age of 13

Website, products, and services are not intended for anyone under 13.

2.13 Data Protection Officer

Contact: privacy@clearfracture.ai

2.14 Contact Information

Email: privacy@clearfracture.ai
Mail: Clear Fracture, Attn: Data Protection Officer, 1934 Old Gallows Road STE 350, Vienna, Virginia 22182