Global Privacy/Data Protection Policy


Effective: March 17, 2021
Last Revised: March 17, 2021




This Privacy/Data Protection Policy (“Privacy Policy”) is designed to help you (the “User”) understand how ClearLynx LLC (“ClearLynx”, “we”, “our” or “us”) collects and uses the information, including personal data, that you share when you use and any related mobile app ( the “Site”), as well as the information, software or services made available to you (collectively, “Services”). Except where otherwise expressly indicated in this Privacy Policy or on the Site, this Privacy Policy applies only to information collected on the Site and through the Services worldwide. It also describes the choices available to you regarding our use of your Personal Data and how you can access and update this information.


By using or accessing the Site or Services, and/or communicating with a ClearLynx agent via the Site, mail, email or telephone you are accepting the practices described in this Privacy Policy. If required, we will ask you to give us your consent for processing your personal data. You are responsible for submitting accurate information to the Site. If you prefer that we not collect your Personal Data, please do not provide it to us. When you submit your personal data and other information on the Site, you hereby consent to the collection, use and disclosure of such information as set forth in the Privacy Policy.


Depending on the context of personal information you provide, ClearLynx may be the data controller ("controller") or data processor ("processor") of your Personal Data under this policy. ClearLynx is a US-based trading platform and thus is a processor of Personal Data sent to us to provide to the Services or collected through the Services on behalf of or at the direction of Customers (“Customers”) and, such as names or contact information of fuel brokers worldwide. Please read the section titled “ClearLynx as a Data Processor” thoroughly for more information. You will also find detailed information below on how you can modify and erase your personal data on our platform, in particular if you are an EEA and UK-based individual.


Users Outside of the United States


The Site is hosted in the United States and is governed by United States law. If you are outside the United States when you visit the Site or engage in communications with a ClearLynx agent via mail, e-mail or telephone, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our central database is operated. As you are contracting for the Services with ClearLynx LLC, which is a US company, any information you provide to us, or that we collect through your use of the Services and that is necessary to provide you with the Services, will be stored, processed, and transferred within the United States or worldwide in a Cloud. Please be aware that the United States and jurisdictions other than the one in which you are located may have a different standard of data protection laws compared to your own jurisdiction.


Information We Collect


We collect the information that you share with us, including:


1.    Personal Data


“Personal Data” is information that can personally identify you or the persons that you refer to us, such as brokers. We maintain one or more databases in the United States to store your Personal Data and may retain it as reasonably required to fulfill the purposes identified herein. Personal Data that we collect depends on how you use the Site. For example, if you register to use or use any of the Services or if you wish to contact us, we may collect your name, email address, company, job title, phone or mobile number, IP address and the email addresses that you provide to us. Customers who register to use a Service may be required to provide us with company billing information, such as contact information and payment information, and with information regarding specified Customer personnel, such as name, title, department name and contact information for billing personnel. We may require clients to provide us with the number or names of personnel or vessels authorized to use a Service. If you use the Site and/or Services through a mobile device, ClearLynx may access in specific cases information regarding the type of device you use, operating system version, the device identifier (or “UDID”), device settings, geo-location data, your IP addresses, and associated services from your mobile device.


NOTE: Your credit card data is not transmitted through nor stored on our systems. All of ClearLynx’s credit card processing is handled securely by our third-party payment processors.


2.    General Information


When you visit the Site, we may collect various categories of general non-personal information (“General Information”). General Information includes browser information, operating system information, and the date, time, length of stay and specific pages accessed during your visits to the Site. General Information may be Personal Data. We do this to improve services we offer you, and for purposes of our analytics.


The Services use of information received, and the Services transfer of information to any third party or any other app, from Google APIs will adhere to Google’s Limited Use Requirements.



Cookies & Other Online Identification Tools


We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.



How We Use Personal Information


Except as specified in this Privacy Policy, ClearLynx does not sell, trade or disclose your Personal Data to third parties without your informed prior consent.


We may process your Personal Data in connection with the following purposes:

1.     to enable you to customize your experience of the Site and Services;

2.     to enable you to access and use the Site and associated applications and platforms;

3.     to provide you with information and services that you request or subscribe such as the ClearLynx newsletter (unless you opt out);

4.     for internal record keeping and administrative purposes;

5.     for research and development purposes to evaluate and enhance the Services;

6.     for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;

7.     to comply with our legal obligations and resolve any disputes that we may have;

8.     to consider your employment application;

9.     if you are the member of a ClearLynx team (employee), to provide your team manager with information about the data associated with your use of the Site, Services and your email account.


10.  to enforce ClearLynx’s agreements with you;

11.  to provide you with important administrative information regarding the Site and Services, such as changes to this Privacy Policy, our Terms of Use and our other policies; and

12.  to prevent fraud and other prohibited or illegal activities;

13.  to deal with your queries, complaints or concerns.


Disclosure of the Information That We Collect


Unless you have consented or as otherwise described in this Privacy Policy, we will not disclose your Personal Data except for:



Third Party Software Providers

With your prior approval, we may share same of your information with our a third party development team through our platform or via email who may provide software services that integrate with the ClearLynx Services. The sharing of this information is necessary for providing our services to you. ClearLynx does not control our business partners’ use of the information and their use of the information would be in accordance with their own privacy policies. However, we will oblige them to follow this Privacy Policy before they are allowed to access your personal information with them.  If you do not want your information shared with these software providers, you can choose not to use the applicable integration.


Fulfillment of Services

ClearLynx may retain other companies and individuals to perform functions consistent with our Privacy Policy on our behalf. Examples include customer support specialists, web hosting companies, fulfillment companies (e.g., companies that fill product orders or coordinate mailings), data analysis firms, IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors, payment systems operators, and email service providers. Such third parties may be provided with access to Personal Data needed to perform their functions, but may not use such information for any other purpose;


Compliance with Law and Fraud Protection

We may disclose any information, including, without limitation, Personal Data and other personal information, we deem necessary, in our sole discretion and without your prior permission, to comply with any applicable law such as to comply with a subpoena, regulation, binding orders of a data protection agency, legal process or governmental request. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. ClearLynx reserves the right to disclose your Personal Data if we believe you have or are violating our Terms of Use or in order to protect or defend ClearLynx’s rights or property, even without a subpoena, warrant or other court order;


Sale or Transfer of Information

In the event of a sale, merger, liquidation, dissolution or sale or transfer of substantially all of the assets of ClearLynx or the Site, Personal Data and/or other information collected through the Site or the Services may be sold, assigned or transferred to the party acquiring all or substantially all of the equity and/or assets of ClearLynx, the Site and/or Services. In the unlikely event of an insolvency, bankruptcy or receivership, your information also may be transferred as a business asset. By using the Site and Services and submitting your information to us, you consent to the sale and transfer of your information as described in this paragraph. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Data, as well as any choices you may have regarding your Personal Data; and


The Site and/or Services may allow you to connect with other websites, products, or services that we do not control. If you visit or use such services, we recommend that you review and understand their privacy practices before sharing your information with those services.


ClearLynx does not store, process or transmit any of your credit card data but relies entirely on third parties to handle these functions. You must comply with such third party’s terms made available to you.



ClearLynx is a SaaS using cloud-outsourced business service providers for its platform. To support delivery of our Services, ClearLynx may engage and use data processors with access to certain Personal Data (each, a "Subprocessor"). 


All our processors and sub-processors are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our processors and sub-processors to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.



Subprocessing Activities


Amazon Web Services, Inc.

Cloud Service Provider

United States


Mail Service Provider

United States


Credit Card Service Provider

United States


Marketing Email Provider

United States


Controlling Your Personal Information/ Newsletters


If you tell us that you do not want us to use your Personal Data to contact you, ClearLynx will comply with the applicable law. In particular, ClearLynx has a newsletter service that provides you with information on fuel trends and other useful related information on a regular basis. These newsletters contain a link so that you can opt out of the service at any time with immediate effect. As an alternative,, you may instruct ClearLynx to stop sending you emails, newsletters, or other information by submitting a request to ClearLynx may, however, continue to use your Personal Data to contact you to service your account in conjunction with your use of the ClearLynx Service. In such cases we will stop doing so upon request to which will also require you to discontinue use of the ClearLynx Services. Please note that if you use more than one name or e-mail address when communicating with ClearLynx or using the Site, you may continue to receive communications from ClearLynx to any name and/or email address not specified in your opt-out request. We will also provide an individual opt-out or opt-in choice before we share your data with third parties other than (as specified in this Privacy Policy), or before we use it for a purpose other than (as specified in this Privacy Policy). To limit the use and disclosure of your Personal Data, please submit a written request to


Withdrawal of Consent


Where you have provided your consent to us for use of your personal data or for other processing of your personal data, you can withdraw your consent at any time by submitting a request to Please consult our cookies policy for information about withdrawing your consent for cookies. If you have consented to receive marketing communications from us via email you can change your mind and withdraw that consent. You can opt-out by clicking on the Unsubscribe link at the bottom of the email you've received or by submitting a request to


Access, Modification, and Deletion Requests


Under applicable law, certain individuals have access to the Personal Data about them that ClearLynx holds and are able to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the Privacy Principles. If you would like to modify or delete your Personal Data, please submit a request to with clear instructions about what you would like modified or deleted. We will respond to your request within 30 days after a complete request is received.


If ClearLynx processes your personal information on behalf of or at the direction of one of our Customers, you should first look to that Customer for assistance regarding the modification, deletion, or correction of your personal information as described in the section titled "ClearLynx as a Data Processor" of this Privacy Policy. In exceptional cases, ClearLynx may be a data controller when we provide you directly with our pricing information on a subscription basis (market assessment on pricing).


We will retain your information for as long as your account is active or as needed to provide you Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


Collection and Use of Third-Party Personal Information


You may also provide Personal Data about other people, such as their email address. If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.




ClearLynx has implemented technical, administrative and physical security measures to protect your information from unauthorized access and use. While ClearLynx strives to protect your information, no data transmission over the Internet is 100% secure and, consequently, we cannot ensure the security of any information.


Where we have given you or where you have chosen a password which enables you to access certain parts of our Services, you are responsible for keeping this password confidential.


The Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.


Our Site Is Not For Use By Minors


We do not knowingly collect information from minors (individuals below 18 years). To use the Site and Services, you must be the age of legal majority in your place of residence. By using the Site and Services, you hereby represent that you are at least the age of legal majority in your place of residence. We do not use an application or other mechanism to determine the age of users of the Site and Services.


Third Party Links


We may provide links to third-party web sites that we do not own or control. We are not responsible for the information collection practices of any website that we do not own or control. We encourage you to review and understand the privacy practices of third-party websites before providing any information to or through them.


Customers and Customers from the EEA/UK/Switzerland (“Europe”)


ClearLynx has no establishment in Europe and does not intentionally offer its Services to individuals in Europe (Art. 3 GDPR).


However, ClearLynx  also realizes that all EEA, Switzerland and UK-based individuals (“Data Subjects”), irrespective of their nationality, have certain individual rights under the GDPR and the Swiss or UK Data Protection Act and strives to provide an adequate level of data protection for their data (“Personal Data”). If ClearLynx processes your personal data on behalf of or at the direction of one of our Customers, you should first look to that Customer as the data controller for assistance as described in the section "ClearLynx as a Data Processor" of this Privacy Policy.


Your rights under the GDPR and the UK Data Protection Act:


1.    The right to be informed about the collection and use of their Personal Data.


2.    The right of access to find out that is stored about you. Data Subjects have the right to obtain confirmation as to whether or not his or her Personal Data is being processed and, where that is the case, to have access to the personal data and the following information: purposes of the processing, categories of Personal Data processed, categories of recipients, data retention term or criteria used to determine that period, rights to rectify or delete personal data or restriction of processing of personal data, the right to lodge a complaint with a supervisory authority, any available information of the source of Personal Data where the Personal Data was not collected from the individual, and information on automated decision-making, including profiling, if any.


3.    The right to rectification of your personal data if it is inaccurate or incomplete. Specifically, under Art. 16 GDPR, all Data Subjects can request that that data controllers correct, amend, erase, any Personal Data which is incomplete, out of date, or inaccurate. As indicated above, if ClearLynx processes your Personal Data on behalf of or at the direction of one of our Customers, you should first look to that data controller for assistance regarding the deletion of your personal information as described in the section titled "ClearLynx as a Data Processor" of this Privacy Policy.  However, ClearLynx will endeavor to inform the Data Subjects and relevant suppliers that there is an update of the Personal Data and/or ask for further information to ensure the legitimacy of the request. Only then will the Personal Data be updated.


4.    The right to erasure to enable an individual to request the deletion or removal of personal data where there is no compelling reason for its continued processing. Data Subjects can request the deletion of their Personal Data (i) if such Personal Data is no longer necessary for the purpose of the data processing, (ii) the Data Subject has withdrawn his/her consent on the processing based exclusively on such consent, (iii) the Data Subject objected to the processing, (iv) the Personal Data processing is unlawful, (v) the Personal Data must be erased to comply with a legal obligation. Where this is the case, ClearLynx will inform the controller(s) which are processing the Personal Data that the Data Subject has requested the erasure by such controllers of any links to, or copy or replication of, those Personal Data.


5.    The right to restrict processing to ‘block’ or suppress processing of personal data. Data Subjects can request from data controllers the restriction of their Personal Data (i) in the event the accuracy of the Personal Data is contested to allow ClearLynx to check such accuracy, (ii) if the Data Subject wishes to restrict the Personal Data rather than deleting it despite the fact that the processing is unlawful, (iii) if the Data Subject wishes ClearLynx  to keep the Personal Data because he/she needs it for his/her defense in the context of legal claims (iv) if the Data Subject has objected to the processing but ClearLynx conducts a verification to check whether it has legitimate grounds for such processing which may override the Data Subject's own rights. Because Clearlynx is a data processor under the GDPR, Swiss and the UK Data Protection Act, Clearlynx will inform the  relevant suppliers who are the data controllers that there is a restriction of the Personal Data.


6.    The right to data portability allowing individuals to obtain and reuse their personal data for their own purposes across different services. Data Subjects may receive their Personal Data and have the right to transmit such data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent or on a contract and the processing is carried out by automated means.


7.    The right to object to the processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling), direct marketing and/or for purposes of scientific/historical research and statistics. Data Subjects can object to the Processing of their Personal Data at any time when used for marketing purpose or profiling to send targeted advertising, or to object to the sharing of his/her Personal Data with third parties unless ClearLynx demonstrates compelling legitimate grounds for the Processing which override the interests, rights and freedoms of the Data Subject or for the establishment, exercise or defense of legal claims.


8.    Various rights in relation to automated decision making (making a decision solely by automated means without any human involvement) and profiling (automated processing of personal data to evaluate certain things about an individual).  ClearLynx will not carry out profiling activities based on automated decision making, unless legally grounded on a requirement of applicable law or the performance of a contract or the Data Subject's consent and provided that suitable safeguards are implemented to protect the Data Subjects” rights.


You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you consider that the processing of your Personal Data infringes applicable laws.


If you would like to exercise these rights, please submit a request to


ClearLynx may receive personal data from data subjects in Europe in the following instances:

·         The data subject in Europe contacts ClearLynx directly and provides the personal data voluntarily, or

·         ClearLynx obtains access to personal data of such data subjects through its business partners, who are data controllers or data processors.


Where required, ClearLynx will enter into a data processing agreement (Art. 28 GDPR) with ClearLynx being the processor or sub-processor of such data controller/processor. In these cases, the data controllers or processors remain primarily responsible for the European personal data that they send or make available to ClearLynx. To the extent that such data (sub-)processing requires a data transfer from the EEA or U.K., ClearLynx will rely on the individual’s consent (Art. 49 (1) (a) GDPR) or another applicable derogation under the GDPR for this data transfer.


As a matter of general practice, ClearLynx does not voluntarily provide government agencies or authorities (including law enforcement) with access to or information about ClearLynx accounts (including Customer data). If ClearLynx receives a compulsory request (whether through a subpoena, court order, search warrant, or other valid legal process) from any government agency or authority (including law enforcement) for access to or information about a ClearLynx account (including Customer data) belonging to a Customer whose primary contact information indicates the Customer is located in Europe, ClearLynx will notify the data controller via email sent to the controller’s primary contact email address of the request to allow the data controller to seek a protective order or other appropriate remedy.


ClearLynx shall not be required to comply with this obligation if it is legally prohibited from doing so, or it has a reasonable and good-faith belief that urgent access is necessary to prevent an imminent risk of serious harm to any individual, public safety, or ClearLynx’s property, our Sites, or Service.


ClearLynx as a Data Processor


The Personal Data you connect to, transmit to and store in ClearLynx are only used for the purposes of providing bunker procurement services through our platform and for the other legitimate purposes listed in this Policy. In most cases you are considered the data controller for any personal data you upload, transmit or connect - the natural person or persons to which this relates are your data subjects. We refer to this data as User Provided Data. Using ClearLynx to manage your data means that you have engaged ClearLynx as a data processor to carry out certain processing activities on your behalf. ClearLynx will be a data controller only in rare cases, e.g. when you order a pricing subscription directly from ClearLynx.


Article 28 GDPR specifies that the relationship between the controller and the processor should be made in writing (electronic form is acceptable under subsection (9) of the same Article). ClearLynx's Terms of Service and this Privacy Policy serve as your data processing agreement, setting out the instructions that you are giving to ClearLynx with regard to processing the personal data you control and establishing the rights and responsibilities of both parties. ClearLynx will only process your User Provided Data based on your written instructions as the data controller unless required by law to act without such instructions.


You or other authorized users of ClearLynx may upload and transmit User Provided Data as part of the Service that contains personal data relating to you or other individuals. We do not view or control such User Provided Data and simply process the User Provided Data on your behalf. You expressly acknowledge that you or the person uploading, connecting or transmitting the User Provided Data (as applicable) retain sole responsibility for the User Provided Data and for obtaining all relevant consents, from the individual to which any personal data contained within the User Provided Data relates, to the processing of that personal data as part of the Service, and that such Personal data is not covered by this Privacy Policy. User Provided Data is processed in the US.


User Provided Data (e.g. information on a broker, a buyer or a supplier including a trader by you) may be displayed on our public platform, stored or otherwise processed by us for performance purposes, unless you instruct us otherwise. All User Provided Data can be deleted or modified by you at any time by contacting us. ClearLynx will rely on you as the data controller   that the entry or the update is legitimate. 


ClearLynx retains the personal information we process on behalf of our Customers for as long as needed to provide the Services to our subscribers and in accordance with our Terms of Service/Customer Agreements. To the extent not deleted by our Customers, ClearLynx may also retain and use certain Personal Data for a reasonable period of time thereafter as necessary to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes, and enforce our agreements.





The invalidity or unenforceability of any provisions of this Privacy Policy in any country shall not affect the validity or enforceability of any other provision of this Privacy Policy, which shall remain in full force and effect.




We may occasionally update this Privacy Policy to reflect changes in our practices. When we post modifications to this Privacy Policy, we will revise the “Last Revised” date at the top of this web page. The modified Privacy Policy will be effective immediately upon posting on the Site. Your continued use of the Site or Services after the posting of the modified Privacy Policy constitutes your agreement to abide and be bound by it. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective and we will update the effective date accordingly. We encourage you to periodically review this page for the latest information on our privacy practices. If you object to any modification, your sole recourse is to stop using the Site and Services.


Questions About our Privacy Policy


In the event that you have questions about how we process your Personal Data, please contact us at and we will endeavor to deal with your request. This is without prejudice to your right to raise a complaint with the data protection supervisory authority in the EEA, Switzerland or U.K. in which you reside. You can also send us any request or inquiry via regular mail to:


ClearLynx LLC

PO Box 457

Bradley Beach NJ 07720