Privacy Policy

Clearport | Effective Date: March 11, 2026 | Last Updated: March 11, 2026

Cleaport LLC (“Clearport,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website at clearportpartners.com (the “Site”), inquire about or engage our services, or communicate with us. Please read this policy carefully. If you disagree with its terms, please discontinue use of the Site.

This policy is intended for a U.S. audience. If you are located in the European Union or California, please see the additional disclosures in Sections 10 and 11 below.

1. Information We Collect

We collect information in three ways: directly from you, automatically through your use of the Site, and from third-party sources.

Information You Provide Directly

Contact and inquiry data: name, email address, phone number, company name, and job title when you submit a contact form, request a consultation, or reach out by email
Business information: details about your company, current or prospective airport concession operations, and deal context you share in the course of our advisory engagement
Correspondence: emails, notes, and communications exchanged with Clearport

Information Collected Automatically

When you visit the Site, we and our service providers automatically collect:

Usage data: pages viewed, time spent, referring URLs, and clickstream data
Device and browser data: IP address, browser type and version, operating system, and device identifiers
Cookie and tracking data: see Section 4 (Cookies and Tracking Technologies) for full details

Information from Third-Party Sources

Business intelligence data: we use Apollo.io and similar B2B data platforms to research companies and individuals in connection with our advisory work. This may include publicly available professional information such as job title, employer, and business contact details
Publicly available sources: airport authority announcements, press releases, regulatory filings, and industry publications

2. How We Use Your Information

We use the information we collect for the following purposes:

Providing and improving our services: to respond to inquiries, deliver advisory services, manage client engagements, and improve the quality of our work
Business development: to identify and evaluate prospective clients, brands, and operators relevant to airport concession opportunities
Communications: to send service-related updates, respond to your questions, and, where you have opted in, share relevant industry insights or firm updates
Site analytics: to understand how visitors use the Site, diagnose technical issues, and improve site performance
Visitor intelligence: to identify companies that visit our Site (see Section 4) for the purpose of targeted business outreach
Legal and compliance: to comply with applicable law, enforce our agreements, and protect the rights and safety of Clearport and others

3. Legal Basis for Processing (Where Applicable)

For individuals in jurisdictions that require a legal basis for processing personal data (including the EU/EEA under GDPR), we rely on the following bases:

Legitimate interests: business development, B2B marketing, visitor intelligence, and improving our services — balanced against your rights and reasonable expectations in a B2B context
Contract performance: fulfilling advisory engagements and client agreements
Legal obligation: where processing is required by applicable law
Consent: where you have expressly consented, such as subscribing to communications

4. Cookies and Tracking Technologies

Our Site uses cookies and similar tracking technologies. Some of these are essential to site functionality; others are used for analytics and visitor identification.

Apollo.io Website Tracker

We use Apollo.io’s website tracking script, which attempts to de-anonymize Site visitors by matching IP address and browser data against Apollo’s B2B contact database. This allows us to identify the company (and in some cases the individual) visiting our Site, which we use solely for B2B business development purposes. Apollo may collect:

IP address and approximate geographic location
Browser type, operating system, and device identifiers
Pages viewed and time of visit

Apollo’s privacy practices are governed by the Apollo.io Privacy Policy. We encourage you to review it.

Other Tracking

Analytics: we may use standard web analytics tools to understand Site traffic and usage patterns
Functional cookies: used to maintain basic Site functionality

Your Choices

Most browsers allow you to control or block cookies through your browser settings. Blocking cookies may affect certain Site functionality. You may also opt out of interest-based advertising through the Digital Advertising Alliance or the Network Advertising Initiative.

5. How We Share Your Information

Clearport does not sell your personal information. We share information only in the following limited circumstances:

Service providers: third-party vendors who assist us in operating the Site and conducting our business (e.g., CRM platforms, email providers, analytics tools, data enrichment services), subject to appropriate data processing terms
Professional advisors: attorneys, accountants, and other advisors under professional confidentiality obligations
Business transfers: in connection with a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction
Legal requirements: if required by law, subpoena, or other legal process, or to protect the rights, property, or safety of Clearport or others
With your consent: for any other purpose with your express permission

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this policy, unless a longer retention period is required by law. Specifically:

Client engagement data is retained for the duration of the engagement and for a reasonable period thereafter for legal and business record purposes (typically 7 years)
Prospect and outreach data is retained while the business relationship remains active or relevant, and reviewed periodically for accuracy
Site analytics data is retained in accordance with the retention policies of our analytics providers

When information is no longer needed, we take reasonable steps to securely delete or de-identify it.

7. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect your information from unauthorized access, disclosure, alteration, and destruction. These include encrypted communications (TLS/HTTPS), access controls, and use of reputable, security-certified third-party platforms.

No method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. If you believe your information has been compromised, please contact us immediately at info@clearportpartners.com.8. Third-Party Websites and Services

Our Site may contain links to third-party websites or reference third-party services (such as airport authority portals, industry publications, or operator platforms). This Privacy Policy does not apply to those sites or services. We encourage you to review the privacy policies of any third-party sites you visit.

9. Children’s Privacy

Our Site and services are intended for business professionals and are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently received personal information from a person under 18, we will promptly delete it.

10. Additional Disclosures for California Residents (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with additional rights regarding your personal information.

Categories of Personal Information Collected

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

Identifiers (name, email, IP address, company name)
Professional or employment-related information
Internet or other network activity (Site usage data)
Geolocation data (approximate, derived from IP address)

Your California Rights

Right to Know: request disclosure of the categories and specific pieces of personal information we have collected about you
Right to Delete: request deletion of your personal information, subject to certain exceptions
Right to Correct: request correction of inaccurate personal information
Right to Opt-Out of Sale/Sharing: we do not sell or share your personal information for cross-context behavioral advertising
Right to Non-Discrimination: we will not discriminate against you for exercising your CCPA rights

To submit a request, contact us at info@clearportpartners.com. We will respond within 45 days as required by law.

11. Additional Disclosures for EEA and UK Residents (GDPR/UK GDPR)

If you are located in the European Economic Area or the United Kingdom, you have the following rights under applicable data protection law:

Access: obtain confirmation of whether we process your data and request a copy
Rectification: request correction of inaccurate or incomplete data
Erasure: request deletion of your personal data in certain circumstances
Restriction: request that we limit our processing in certain circumstances
Portability: receive your data in a structured, machine-readable format
Objection: object to processing based on legitimate interests, including direct marketing
Withdraw consent: where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing

To exercise these rights, contact us at info@clearportpartners.com. You also have the right to lodge a complaint with your local supervisory authority.

Note: As a U.S.-based B2B advisory firm, our Site traffic is primarily from U.S. business professionals. We do not have a European establishment and do not systematically target EU/UK individuals. If you are an EU/UK resident who has engaged with Clearport, we will honor your rights under applicable law.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will update the “Last Updated” date at the top of this document. For material changes, we will provide additional notice (such as a notice on our Site or by email to clients). Your continued use of the Site after the effective date of any update constitutes your acceptance of the revised policy.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Clearport Partners LLC
Attn: Privacy
Email: info@clearportpartners.com
Website: clearportpartners.com

This document is provided for informational purposes. It does not constitute legal advice. Clearport Partners recommends consulting qualified legal counsel to ensure this policy complies with all applicable laws and accurately reflects your specific data practices before publishing.