Privacy Policy

Last Revised: October 1, 2024

Clearwater Benefits Administrators LLC, and its subsidiaries and affiliates (collectively, “Clearwater,” “we,” “our,” and “us”) are responsible for this website www.clearwaterhealth.com (the “Website”). We are committed to respecting the privacy of our Website visitors.

This Privacy Policy describes our practices related to personal information collected through the Website. Please read this Privacy Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. By accessing or using any component of our Website or any part of the Services (defined below), you agree to all terms and conditions of this Privacy Policy and the changes thereto. If you do not agree, do not use, or access the Services.

If you do choose to visit our Website, you can learn more about who we are, what we do, and career opportunities we have (the “Services”).

To make starting your career path easier, from our Website, you can look at available opportunities as our Website allows you to access job opportunities by working with Greenhouse, which allows you to apply to open positions with Clearwater directly through that third-party website. For information about how the greenhouse collects, uses, and shares your information, please review Greenhouse’s Privacy Policy. As such, Clearwater’s online job application and recruiting systems are used for recruiting, to allow individuals to apply for employment with Clearwater, and to ensure that Clearwater complies with applicable legal and regulatory requirements in receiving employment applications. These systems are intended for visitors to review, and possibly apply for, Clearwater employment opportunities. Do not use Clearwater’s online job application and recruiting systems for any other purpose. Posted positions are only available to be performed within the United States. Clearwater only accepts applications from individuals who are at least 18 years of age. If you are under the age of 18, do not provide Clearwater with your personal information for purposes of applying for a job unless you are directed otherwise.

Information collected directly from you: A visitor to our Website may be asked to provide personal information to receive a response from Clearwater. The personal information that you may be requested to provide includes your name, email address and any information that you choose to provide. The collection of information will be transparent to you—you will be asked for it and will have the opportunity to decide whether or not to provide it. If you choose not to provide any of the personal information requested, Clearwater may be unable to complete the transaction you have requested.

Information you provide when applying for a job: To review postings on Clearwater’s job online application systems, communicate with Clearwater about job openings, and apply for a job with Clearwater, you will be asked to provide your personal information. With variation in certain countries, where some of these data elements may not be requested or may be requested once your employment is confirmed or starts, the personal information that you may be asked to provide includes:

• Name
• Contact information, including home address, home telephone, and email address
• Date of Birth
• Government identification document or number, including a drivers’ license
• Work history
• Education
• Resume or CV and/or a cover letter, including any information you provide in those documents
• Citizenship and/or permanent legal residence
• Eligibility to work, including documentation of immigration status
• Interest in employment opportunities
• Job specific questions that relate to the fitness of a candidate for a particular job
• References (if you provide information regarding other individuals, you must obtain their consent before providing the data to Clearwater)
• Information that we may be required by law to ask to ensure you can work for a defense contractor
• Information necessary for Clearwater to confirm that your employment would not create a conflict of interest or otherwise violate applicable law or regulation
• Information that you may voluntarily choose to provide about your ethnicity, gender, sexual orientation, veteran status, and disability
• Information you provide to create username, password, security questions and answers used to validate your identity when you return to the Website
• Where you learned about the job opening
• Any other information that you may choose to provide as part of your application
•  Information provided by third party sites, if you apply for a job opening through a third-party site

For certain jobs and in certain locations, you may be asked to have a medical examination, hearing or vision checks, drug testing, a background check, or a criminal history check. These will only be performed with your consent, but in certain circumstances, your offer of employment may be contingent on your successful completion of one or more of these checks.

Clearwater does not perform criminal history checks where prohibited from doing so by law. Clearwater may confirm the information provided in your application, such as your references, driving license and record, education and job history, without seeking your additional consent.

If you access a Clearwater online job application system on a mobile device, the Website will collect information necessary to communicate with your device and provide any customization that you may request. This information may include your device identification or number, your carrier, and your location. In addition, Clearwater monitors user traffic patterns on its job application Website, including a user’s domain name, browser type, date and time of access, and pages viewed. Our web servers collect the domain names but not the e-mail addresses of visitors. This information is collected in order to measure the number of visitors to our websites and to determine which areas of the website users find useful based upon the amount of traffic to particular areas. Clearwater uses this information to enhance users’ experience and to better prepare content based on the user interests. For certain positions, you may be required to provide additional information prior to hiring for Clearwater to establish that you have or are eligible to obtain a security clearance and/or global trade authorization. For the most part, Clearwater will obtain your personal information directly from you when you complete an application online and during the application process, such as during an interview. Clearwater may also collect personal information indirectly, such as from prior employers, references you provide, recruitment agencies, public records sources and other third parties as part of a background check, to the extent permitted by applicable law.

Information collected through our Website: Clearwater monitors user traffic patterns throughout the website according to a user’s domain name, browser type, date and time of access, and pages viewed.

If you access a Clearwater online job application system on a mobile device, the Website will collect information necessary to communicate with your device and provide any customization that you may request. This information may include your device identification or number, your carrier, and your location.

This information is collected in order to measure the number of visitors to the Website and to determine which areas users find useful based upon the traffic to particular areas. Clearwater uses this information to enhance visitors’ experience and to better prepare future content based on the interests of visitors.

Your mobile provider may have a conflicting privacy position that captures personal information when you visit our Website. Clearwater is not responsible for and does not control how other parties may collect your information when you access our Website.

How Clearwater Uses Cookies or Other Tracking Technologies?

Clearwater uses cookies on this website. Cookies are small text files sent to and stored on users’ computers that allow websites to recognize repeat users, facilitate users’ access to websites and allow websites to compile aggregate data that will allow content improvements. Cookies do not damage users’ computers or files. If you do not want cookies to be accessible by this or any other Clearwater website, you should adjust the settings on your browser program to deny or disable the use of cookies. The cookies that Clearwater uses on this site do not identify you. The cookies simply provide Clearwater with aggregate, anonymous analytics about the number of people visiting particular pages on this Website.

The Website may also use web beacons. A web beacon is usually a pixel on a website that can be used to track whether a user has visited a particular website to deliver targeted advertising. Web beacons are used in combination with cookies, which means that, if you turn off your browser’s cookies, the web beacons will not be able to track your activity. The web beacon will still account for a website visit, but your unique information will not be recorded.

How Does Clearwater Use the Personal Information it Collects?

Clearwater may use your personal information for the following purposes, as well as for any other purpose to which you consent or is required by law:

• conduct basic business operations, such as communicate with customers and business planning;
• provide investor services;
• provide the information, item or service you have requested;
• communicate with you about products, services and events relating to Clearwater, to the extent that you have requested such communications and with the opportunity to opt-out;
• improve our products, services and websites;
• verify your identity to ensure security for one of the other purposes listed here;
• respond to a legitimate legal request from law enforcement authorities or other government regulators;
• investigate suspected or actual illegal activity;
• support the sale or transfer of all or a portion of our business or assets (including through bankruptcy);
• allow you to apply for employment with Clearwater and evaluate your application, including without limitation arranging for and conducting phone/video conference screening, interviews and other applicable assessments;
• invite you to apply for and consider you for other opportunities that may be or become available;
• contact you with regard to an application or opportunity or communicate changes;
• validate reference checks, conduct criminal history and background checks as appropriate;
• facilitate your hiring and administer your employment, if you are hired;
• comply with legal and regulatory requirements involving job applications, which may include providing reports to government agencies;
• provide you with opportunities to offer feedback on your experience;
• conduct analysis on applicant trends to understand and improve Clearwater recruitment practices, including for diversity, equity, and inclusion analysis;
• verify your identity and ensure security for one of the other purposes identified herein;
• ensure or enhance the security of Clearwater’s hiring platforms and electronic systems;
• protect against fraud; and/or
• to share with Clearwater’s contracted vendors for purposes of hiring; and/or conduct investigations to ensure compliance with, and comply with, legal obligations.

Your personal information will be used with your consent or to fulfill a legal obligation, and, in locations that permit it, for a legitimate interest.

How Does Clearwater Disclose or Otherwise Share Your Personal Information with Third Parties?

Clearwater will not sell or otherwise share your personal information outside the CLEARWATER family of companies, except to:

• Allow service providers Clearwater has retained to perform services on our behalf. In those cases, Clearwater will only share the information with service providers for the purposes outlined above. The categories of service providers with which Clearwater may share your personal information include: HR information applications, such as Greenhouse; background check service providers (to the extent applicable and with your consent); and any other service providers that may be necessary to manage your employment. These service providers are contractually restricted from using or disclosing the information except when it is necessary to perform services on our behalf or to comply with legal requirements.
• Allow our suppliers to review applicant profiles and information that has been provided to determine applicability for job opportunities. All of our suppliers are contractually restricted from using or disclosing the information except for job application and hiring purposes.
• Comply with legal obligations, including but not limited to complying with tax and regulatory obligations, sharing data with labor/trade unions and works councils, and responding to a court proceeding or a legitimate legal request from law enforcement authorities or other government regulators.
• Investigate suspected or actual policy, ethics, or compliance violations or illegal activity.
• Prevent physical harm and protect employee safety.
• Support the sale or transfer of all or a portion of our business or assets (including through bankruptcy).

Clearwater may also use other service providers, but any service provider utilized will be for the purposes identified in this Privacy Policy and will provide services under a contract as mentioned above. It is possible that one of our service providers may interact directly with you during your application process, such as to schedule an interview or conduct a first round screening interview.

Your personal information may also be maintained and processed by our service providers in countries other than the one in which it was collected, such as the United States, member states of the European Union, Canada and other jurisdictions.

CLEARWATER does not use the personal information collected on the Website to contact you except in response to a direct inquiry or if you apply for a job.

Where Clearwater Stores Your Personal Information?

Clearwater is U.S. company with operations only in the U.S. As such, your personal information will be stored in the U.S.

How Long Does Clearwater Retain Personal Information?

For non-applicant / employee data, Clearwater will retain personal information as long as needed to comply with its contractual and legal obligations. If the personal information is not subject to contractual or legal obligations, Clearwater will retain the data for as long as is required for the original purpose for which it was collected.

For all applicant / employee data, Clearwater is required to retain your application information for a minimum of three years. That period of time may be extended where required by law, policy, administrative or judicial activity and audit obligations. If you apply for a job in the US but you reside outside the US, please be aware that this retention requirement applies to you as well and we will be unable to grant deletion requests for US job applications within this retention period. Otherwise, Clearwater will retain your information as follows:

• Profile information: For information that you enter as part of your profile in the Clearwater online job applicant tools, we retain that information for three years from last activity. If you want to maintain your account, be sure to update it periodically.
• Unsuccessful applications: For unsuccessful candidates, Clearwater will retain your application information for a period of time as defined by applicable, local law. If there is no applicable local law, Clearwater retains personal information for a reasonable period of time.
• Successful applications: For successful candidates, Clearwater retains your information so that it is able to employ you. The information from your application is used for employment purposes and handled according to internal employment policies.

In all instances, retention requirements and purging of personal information may be impacted by law or regulation, court, administrative or arbitration proceeding, or an audit requirement. In each of these instances, applicable obligations may require Clearwater to retain data in specific circumstances for longer than indicated in this notice. Beyond the retention periods and for applicants who have requested deletion, Clearwater may retain anonymous data for statistical purposes to understand and improve its recruitment practices.

What You Need to Know About Third-Party Links On the Website?

In some instances, Clearwater may provide links to non- Clearwater controlled websites and social media plug-ins, including Facebook, Instagram, Threats, X, YouTube, and others, which Clearwater will make reasonable efforts to identify as such. Clearwater does not control such third-party websites, and cannot be responsible for the content or the privacy practices employed by other websites.

How Clearwater Protects Your Personal Information?

CLEARWATER has implemented technical, administrative and physical measures to safeguard any personal information that we may collect.

 How Clearwater Protects Information it Collects?

Clearwater has implemented technical, administrative and physical measures to safeguard any information that we may collect.

What Are Your Rights Regarding Your Information It Collects?

It is Clearwater’s position that it does not collect any personal information about you when you use the Website. To the extent it does or that an applicable court or supervisory authority determines that it does, you may have the following data subject rights:

Residents of California and Colorado:

California Shine the Light Law: California residents may annually request and obtain information that is shared with other businesses for their own direct marketing use within the prior calendar year. Clearwater does not share your personal information with other businesses for their own direct marketing use.

California Consumer Privacy Act: California residents have the right to:

• request details about the personal information that we have about you, including the categories of information, the purpose for which we use it, with whom we share it, and specific information about what personal information we have about you;
• request that your data be deleted;
• correct your data; and
• direct Clearwater not to sell or share your data, but, since Clearwater does not sell or share personal information, this does not apply.

If you are a California resident not covered by the exclusions mentioned above and you would like to exercise your rights, you should contact Clearwater by emailing us at jobs@cleatrwatersavings.com. Please provide your name, a way for Clearwater to contact you (such as an email address or telephone number) so that we can respond to your request, information about the nature of your relationship with us (for example, are you a visitor to our website or a shareowner), and details about the action that you would like us to take. Based on your request, we will investigate to determine if we have any of your personal information. If we do have your personal information (other than that provided in your request), we will seek to verify your identity based on the personal information that we already have; the data we will request will depend on the nature of the personal information we have about you. Once we verify your identity, we will provide you with a response, indicating how we will satisfy your request or why we cannot comply with your request.

For all requests, we will provide a response within 45 days, and let you know if longer is needed. If we do not take any action on the request, we will let you know why, and it is usually because we cannot verify your identity or we have verified your identity but identified that you are not and have not been a California or Colorado resident in the relevant time period.

For Colorado residents, you can appeal this decision/non-action. You may also contact the Colorado Attorney General if you have concerns about the result of the appeal.

Do Not Track.

Currently this Website does not respond to Do Not Track signals. 

Residents of the United States: Clearwater does not collect Social Security Numbers through the Website. Clearwater does, however, collect Social Security Numbers where required by law, such as tax and payroll purposes for its employees. When BFA collects and/or uses Social Security Numbers, Clearwater will take proper care by protecting confidentiality, limiting collection, ensuring access on a need-to-know basis, implementing appropriate technical safeguards and ensuring proper disposal.

To access or change your information on one of Clearwater online job application systems, you can log into your profile and make any corrections or deletions required. Clearwater takes reasonable efforts intended to ensure that your personal information remains accurate, complete and current. Clearwater may, from time to time, ask you to confirm the accuracy of your personal information or provide updated or additional information.

Clearwater’s Policy on the Personal Information of Minors.

This Website is intended for visitors who are at least 18 years of age and the minimum age for legal consent in their jurisdiction of residence. Clearwater does not knowingly solicit information from, or market products or services to, children. If you believe that Clearwater has collected information about a minor please contact us immediately through the Contact Clearwater section below. If you do not meet the age requirements set out above, please do not enter your personal information on this or any other Clearwater website.

Clearwater Changes to this Privacy Policy.

As Clearwater expands and improves the Website, we may need to update this Privacy Policy. If we make any significant changes to the Privacy Policy, we will post a notice on our Website or contact you to inform you when required by law. By continuing to interact with us after the modified version of Privacy Policy has been posted, you are accepting the changes to the Privacy Policy, subject to any additional requirements that may apply. We encourage you to review this Privacy Policy on a regular basis for any changes. The date of the latest version will be identified at the top of the Privacy Policy.

Contact Clearwater

If you have any comments, questions or suggestions, please email jobs@clearwatersavings.com or send via mail to 14425 Falcon Head Blvd, Building E, Ste 100, Austin, TX 78738.  If you wish to access, correct or update your personal information, or if you have questions about Clearwater’s privacy practices in general or a complaint, please email jobs@clearwatersavings.com.