1. Introduction
Clearway Advisory ("we," "us," or "our") is committed to protecting the privacy and confidentiality of our clients, investors, and business owners. This Privacy Policy outlines how we collect, use, protect, and disclose your information when you use our website, marketplace, and advisory services.
This policy and its supplement apply to information we collect:
- On this Website.
- In email, text, and other electronic messages between you and this Website.
- Through any mobile and desktop applications you may download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
- When you voluntarily provide information in order to fulfill a request.
2. Information We Collect
We collect information that identifies, relates to, or could reasonably be linked to you ("Personal Information"), including information by which you may be contacted online or offline. This includes:
To perform some of our services, we may request and access information regarding your business that might otherwise be considered sensitive. We handle such information in line with this Privacy Policy and the safeguards described in our data security practices.
- Identifiers: Name, email address, phone number, and physical address.
- Financial Data:Tax returns, P&Ls, balance sheets, and bank statements (collected via our "Secure Financial Vault").
- Business Details: Legal business names, operational history, and asset details for listings.
- EB-5 Documentation: Source of funds evidence and immigration-related identifiers.
- Technical Data: IP addresses, browser type, and interaction data via cookies to improve your experience.
3. Information You Provide to Us
For some services, you may be asked for information, and we may access business information that could reasonably be treated as sensitive, in order to perform our services.
The information we collect on or through our Website may include:
- Information that you provide by filling in forms on our Website. This includes inquiries on forms or listing forms, and your responses to surveys that we might ask you to complete for research purposes.
- Your search queries on the Website.
4. Information Provided Voluntarily for Use of Services
We collect information that you voluntarily provide to us in order to fulfill a request, such as to use our services and Website, request support from our support team, write to us by email, complete a contact form, or communicate with us in any way. This information includes your name and surname, company name, physical address, email address, and certain types of business information about your business, such as client payment information, revenue, analytics information regarding your website, customer churn, customer lifetime, and other metrics and data, as well as any other information you provide to us regarding your business.
5. How We Use Your Information
We use the data we collect to:
- To present our Website and its contents to you.
- To facilitate marketplace listings and activity for buyers and sellers.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your account, including expiration and renewal notices.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Website or any products or services we offer or provide through it.
- To allow you to participate in interactive features on our Website.
- In any other way we describe when you provide the information.
- For any other purpose with your consent.
- With your consent, we will use your information to contact you about our own and third parties' goods and services that may be of interest to you. You may opt out at any time by emailing us at info@clearwayadvisory.com.
- To perform valuations and verification of business listings.
- To process EB-5 visa advisory requests and implementation.
- To generate automated legal documents (NDAs, SOWs, Listing Agreements) via third-party partners such as RabbitSign.
- To comply with Illinois state laws and federal regulations regarding financial transactions.
6. Data Security & The "Secure Vault"
We implement "Institutional Grade" security measures to protect your sensitive financial documents:
Encryption
All financial documents are stored in private, end-to-end encrypted.
Access Control
Your documents are never public. Only a Clearway Advisor can access them
Minimization
We only collect the data strictly necessary to perform our advisory duties.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
7. Sharing of Information
We do not sell your personal information. We only share data under the following conditions:
- With Your Consent: Sharing your business prospectus with a verified buyer after they have signed a binding NDA.
- Service Providers: Sharing data with secure partners solely to perform services on our behalf.
- Legal Necessity: If required by law, subpoena, or to protect the safety and integrity of our marketplace.
8. Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual or otherwise fall under the definition of "Personal Information," "Personal Data," or any other similar definition under any regulation, without restriction.
We may disclose personal information that we collect or you provide as described in this Privacy Policy:
- To our subsidiaries and affiliates so that we can provide our services to you.
- To contractors, service providers, and other third parties we use to support our business so that we can provide our services to you.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Clearway Advisory's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Clearway Advisory about our Website users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
9. Your Rights (Illinois & Beyond)
Under the Illinois Personal Information Protection Act (PIPA) and evolving 2026 privacy standards, you have the right to:
- Access: Request a copy of the personal data we hold about you.
- Correction: Request that we update or correct inaccurate information.
- Deletion: Request the removal of your data (subject to legal retention requirements).
- Opt-Out: Decline cookies or marketing communications at any time.
10. Deletion
If you choose to have all your information removed, we will delete, de-identify, or anonymize your personal data so it no longer identifies you, subject to the exceptions described below.
Here are some examples of situations where we are legally allowed or required to keep some of your personal data:
- If there is an unresolved issue relating to your interaction with Clearway Advisory, such as an outstanding credit or unresolved claim or dispute.
- For our legal, tax, audit, and accounting obligations.
- For our legitimate business interests, such as fraud prevention or to maintain security.
11. Third-Party Use of Cookies
Some content or applications on the Website are served by third parties, including content providers and application providers (for example, Google Analytics and HubSpot). These third parties use cookies to collect information about you when you use our Website. The information they collect may be associated with your personal information, or they may collect information, including personal information, about your online activities over time and across different websites and other online services.
12. Third-Party Links
Our marketplace may contain links to third-party sites (or partner listings). We are not responsible for the privacy practices of these external platforms.