Clear Secure, Inc. (YOU) Business

ITEM 1. BUSINESS

Overview

Clear Secure, Inc. (the “Company” or “CLEAR”) is a secure identity company making experiences safer and easier - both digitally and physically. We make everyday experiences frictionless by connecting your identity to all the things that make you, YOU - transforming the way you live, work, and travel. CLEAR has been delivering secure, frictionless experiences in airports for over 15 years, achieving exceptional user delight and trust with CLEAR+, our consumer travel subscription service. CLEAR+ enables access to predictable and fast experiences through dedicated entry lanes in airport security checkpoints nationwide. Additionally, our CLEAR Travel portfolio includes TSA PreCheck® Enrollment Provided by CLEAR, premium services such as CLEAR Concierge, other travel benefits such as expedited passport services, our free CLEAR app which helps travelers plan their trip Home to Gate, and other mobile-first identity solutions such as CLEAR ID. Our CLEAR Travel portfolio extends CLEAR’s value proposition beyond the airport lane and supports our strategy to expand use cases, increase engagement and address new customer segments such as international travelers. CLEAR1 is our business to business (“B2B”) multi-layered identity verification solution. We combine biometric, document and device signals with verified data sources to ensure users are who they claim to be. Our B2B partners can select which verification layers to deploy, based on their specific security requirements, risk tolerance and user experience goals. We partner with a breadth of organizations, with a particular focus on Healthcare, Workforce and Governmental organizations where high fidelity identity security is paramount to their operational success. Our scaled Member base and comprehensive secure identity platform underpin our CLEAR Travel and CLEAR1 businesses, maximizing security and minimizing friction for consumers and our enterprise partners.

Our Business

Since 2010 we have been expanding our network, investing in our technology platform, strengthening our operations and developing our team members to consistently deliver increased value to Members and partners, resulting in the growth and trust of CLEAR.

We have built an extensive physical footprint with a nationwide network of airports and partners to offer Members frictionless, trusted experiences as they move and transact throughout the day in both physical and digital environments. As of December 31, 2025, our expansive network of partners and use cases provide our 38 million Total CLEAR Members with access to 166 CLEAR+ Lanes across 60 airports nationwide, 61 airports and 340 retail locations with TSA PreCheck® Enrollment Provided by CLEAR, 9 sports and entertainment venues with priority Lanes and a growing list of B2B CLEAR1 partners. The continued expansion of our capabilities enable our partners to integrate CLEAR1 solutions and give our Members new places and new ways to use CLEAR.

At CLEAR, we are obsessed with the Member experience. Our physical and digital network, technology platform, operational expertise and 3,708 Ambassadors and field managers across our airport partners have helped us build a trusted brand and a passionate Member base. Our Members know to expect a frictionless, predictable, and secure experience when they see the CLEAR brand. Similarly, our partners trust CLEAR to enable them to deliver the same frictionless and secure experiences to their own customers.

Our business model is powered by network effects and characterized by efficient Member acquisition and maintaining strong retention rates. Our largest CLEAR+ Member acquisition channel is in-airport (representing 66%, 64%, and 65% of Member acquisitions for the years ended December 31, 2025, 2024 and 2023, respectively), where our prominent branding and expansive physical footprint allow prospective Members to engage with CLEAR’s brand, Ambassadors and technology firsthand. Our passionate Member base further drives word-of-mouth marketing and strong retention rates. As we add partners, products and locations, our platform becomes more valuable to our Members. In turn, as we grow membership, our platform is more valuable to our existing and prospective partners. In addition, we have grown Total CLEAR Members 31% year over year to 38.0 million, further increasing the scale and value of our secure identity platform to current and prospective CLEAR1 partners.

The CLEAR Network

Our platform is multi-faceted and a powerful network of networks. Our Member base includes CLEAR+ Members and CLEAR Platform Members.

CLEAR+ Members pay for our annual CLEAR+ consumer travel subscription service. We started in airports and witnessed accelerating Member growth in both new markets and existing markets as our network expanded. The ability to

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use CLEAR in more locations and in more ways increases our utility to our Members. In 2025, we expanded CLEAR+ and related offerings to serve international travelers from 42 countries, broadening the addressable market for our platform and increasing the relevance of CLEAR+ for a global traveler base.

CLEAR Platform Members include Members who enrolled through our mobile app, our partners’ customers who have enrolled through our CLEAR1 solutions, and formerly paying CLEAR+ Members. Platform Members can use CLEAR anywhere in our network outside of CLEAR+ service for free, while our CLEAR1 partners pay to use our technology solutions. Typically, new platform Members are driven to enroll by one of our CLEAR1 partners who integrate with CLEAR to enable frictionless experiences for their customers. Platform Members also may enroll directly with CLEAR to access our expanding portfolio of use cases.

We believe there is a significant opportunity to expand our reach. We expect to expand CLEAR+ through airport network expansion, increased market penetration in existing markets, partnerships, new products and services, and our digital marketing efforts. We also expect to continue adding new airport and retail locations offering TSA PreCheck® provided by CLEAR. Additionally, we have a robust pipeline of new CLEAR1 partners who increasingly recognize the need to deliver a seamless and secure experience to their customers.

As CLEAR has evolved into a multi-product secure identity platform serving both consumer and enterprise use cases, management uses certain key performance indicators to evaluate the scale, engagement, and monetization of the CLEAR network across CLEAR+, CLEAR1, and other emerging identity use cases.

Total CLEAR Members is used to measure the overall reach of the CLEAR platform and the growth of our enrolled Member base across both paid and unpaid channels. This metric reflects enrollment driven by CLEAR+, CLEAR1 partner integrations, digital identity adoption, and international traveler use cases, and provides insight into the expanding utility and extensibility of the CLEAR network.

Active CLEAR+ Members is used to assess the monetization of our consumer aviation subscription offering and the demand for predictable, frictionless travel experiences. This metric helps management evaluate the portion of the Member base that contributes revenue.

Definitions of these metrics and additional discussion of period-to-period changes are included in Item 7 — Management’s Discussion and Analysis of Financial Condition and Results of Operations, “Key Performance Indicators”.

Our Offerings

Secure Identity Platform

Our secure identity platform is multi-layered consisting of both our front-end (including enrollment, verification and linking) and our robust, secure and scalable back-end to deliver a multilayered proofing stack for identity. To interact with our platform, first time users go through our fast, secure, and easy enrollment process. Once a Member is enrolled, each subsequent use of the platform to verify their identity is only a few simple steps. Our ‘enroll once, use everywhere’ approach benefits the entire CLEAR ecosystem by removing friction for Members and increasing conversion for partners.

CLEAR confirms identity on an opt-in basis using document authentication (e.g., driver’s license, passport), best-in-class biometric capture technology, liveness detection and other anti-spoofing technologies, biometric matching, source corroboration, and other proprietary technologies to link an individual’s identity with their biometrics (e.g., face). Members can enroll in CLEAR in the manner which is most convenient for them: in-person enrollment Pods in airports, or their own personal mobile device. Our platform is versatile, can be used across different verticals and can be customized for specific applications or use cases. Our architecture is designed to be scalable without compromising Member experience or information security.

We have a deep organizational commitment to preserving our Members’ privacy and ensuring Members have control of their personal information. This commitment has been core to our Member pledge since our founding over 15 years ago. We have a comprehensive information security program and a robust cybersecurity posture that uses industry best practices with administrative, technical and physical safeguards to protect against anticipated threats or hazards to the security, confidentiality or integrity of our platform’s systems and information. Our information security core tenets include the application of encryption at rest and in transit, firewalls, multi-factor authentication, specific role-based access control, physical and personnel security (including training), intrusion detection and data loss prevention. We have a commitment to Members being in control of their own information and we do not sell our Members’ data.

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We have been certified at the highest level of security by our government regulators. The Department of Homeland Security (“DHS”) has certified our information security program under their purview at a FISMA High Rating (the highest designation according to the Federal Information Security Modernization Act).

CLEAR+

CLEAR+ is our consumer travel subscription service, which enables access to predictable and fast experiences through dedicated entry Lanes in airport security checkpoints across the nation as well as access to our broader network. With CLEAR+, Members use our biometric technology to verify their identity and travel credentials. Our team of hospitality and security focused Ambassadors help bring our technology to life by delivering a frictionless journey alongside excellent service in our Lanes. CLEAR+ currently retails for $209 per year per Member and is billed upfront. We offer trials in-airport and online, as well as promotional pricing through select partners and channels, including Delta Air Lines, United Airlines, Alaska Airlines and Hawaiian Airlines frequent fliers. We also offer a family plan for up to three Members at an additional $125 per year per Member. Through our partnership with American Express, eligible card members receive statement credits for all or a portion of their CLEAR Plus membership. We initially entered into our partnership with American Express in 2019. In February 2026, we executed a multi-year renewal of the partnership with American Express. We also offer discounted military and government pricing, and children under 18 can use CLEAR+ for free with an adult Member.

In 2024, we launched our Lane of the Future - including our new EnVe (“enrollment and verification”) hardware - to offer a face-first verification experience that is approximately 5x faster than legacy pods. The EnVe Pods are powered by our NextGen Identity+, the highest fidelity identity at scale, and feature our most advanced camera and enhanced display. Building on this foundation, in 2025 we also began rolling out eGates, which integrate our proprietary hardware and software to enable Members to verify their identity in approximately five seconds and proceed directly into physical screening. Early deployments of eGates have driven improvements in throughput and Member experience metrics, and we expect to continue expanding eGates across our network into 2026.

TSA PreCheck® Enrollment Provided by CLEAR

In February 2025, we launched TSA PreCheck® Enrollment Provided by CLEAR, which as of December 31, 2025 was available in 61 airports and 340 retail locations nationwide. We expect to scale this offering to additional locations across our airport network and in other partner retail locations on a rolling basis, subject to TSA approval. CLEAR also provides online renewal services. The TSA PreCheck® Enrollment Provided by CLEAR program represents a growing source of revenue. We believe that there is a significant opportunity for us to process TSA PreCheck® membership renewals and that we can add a large number of new TSA PreCheck® customers on behalf of TSA. After a new TSA PreCheck® customer is enrolled or renewed, we offer the customer an opportunity to enroll in CLEAR+ on an opt-in basis. We believe CLEAR+ and TSA PreCheck® are highly complementary services and this channel is relevant to showcase not only the TSA PreCheck® value proposition, but also the power of the combined products and the extension of a holistic travel journey. The partnership does not extend to performing physical security screening, which continues to be operated by the TSA.

CLEAR Concierge and Perks

CLEAR Concierge is a premium, personalized on-demand service, where a dedicated Ambassador meets you curbside and guides you all the way to your gate. Now live at 27 airports, CLEAR Concierge enhances the CLEAR+ value proposition for high-frequency and premium travelers, as well as travelers requiring additional assistance such as families and senior citizens, by offering an end-to-end, frictionless travel experience and creating opportunities for deeper Member engagement and incremental revenue.

We also offer additional CLEAR Perks, which are a suite of added benefits that help CLEAR+ Members get an even more seamless experience, Home to Gate. Through CLEAR Perks, we partner with other brands and service providers to tailor additional offers for CLEAR+ Members to help them win the day of travel.

CLEAR1

CLEAR1 is our B2B offering that extends our secure identity platform to partners to create frictionless experiences for their customers. Our software development kits and application programming interfaces enable our partners to quickly and seamlessly integrate directly with our platform. This structure allows us to facilitate safer, faster and more

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frictionless experiences for our partners’ customers, while enabling our partners to continue to control and manage the direct relationship with their customer under their own brand.

Our CLEAR1 secure identity platform can power a wide range of use cases such as customer check-in, account opening, KYC, age verification and a suite of workforce products like employee onboarding, continuous verification, critical access control, and account recovery. As we continue to grow our partners and use cases, we see the increasing need for secure identity verification for partners to achieve business goals and create a more frictionless experience for their customers.

CLEAR1 contract structures vary by use case, but are typically multi-year agreements that drive revenue through transaction fees (charged per use or per user) in addition to an annual platform fee. In addition, they may also include one-time implementation fees, licensing fees or incremental transaction fees.

Mobile App

We also engage with our Members via the flagship CLEAR mobile app. The app has several features, including:

•Enroll in CLEAR and manage your membership — enrolling as a CLEAR Member is a quick and easy process that can be handled directly through the CLEAR app via facial biometric recognition technology and validating a government-issued identification. This one-time enrollment can be completed in minutes and gives Members access to our platform offerings.

•Home to Gate — Members can have a predictable day-of-travel experience by accessing helpful information to assist their journey from the time they leave their home until they board the plane. Home to Gate integrates flight departure times, traffic data, security screening, gate number and terminal walking times to their exact gate. Additional services can be easily integrated into this platform.

•e-Passport –- CLEAR+ Members can add, store, and update their passport information directly into the CLEAR app, enabling them to get an even faster CLEAR+ experience without having to go to an enrollment center or scan government-issued identification physically at security, as well as a secure place to store and update their passport remotely and conveniently.

•CLEAR ID — a free, mobile digital ID that allow any traveler to verify their identity at more than 250 TSA checkpoints directly from their phones using the CLEAR Mobile App, allowing them to keep their physical ID in their bag. CLEAR ID extends our secure identity platform into mobile-first and reinforces our “enroll once, use everywhere” approach across the CLEAR network.

•Fast Access — Members enjoy touchless access to select partner services and venues.

Our Member Acquisition and Retention Strategy

We have focused our Member acquisition strategy around delivering exceptional experiences to build brand trust as well as driving network effects by adding new partners, products, uses and locations to increase our value proposition.

Our largest CLEAR+ Member acquisition channel is our highly efficient in-airport channel, where our prominent branding and expansive physical footprint allows prospective Members to engage with CLEAR’s brand, Ambassadors and technology firsthand. Our passionate Member base drives word-of-mouth marketing and strong retention rates. To ensure best-in-class Member service we monitor real-time Member feedback and quickly take action on data-driven insights. As we add new airport and non-airport locations, use cases, and partners, the power of network effects makes CLEAR+ more valuable to our Members, further driving new Member acquisition and retention. We also entered into strategic distribution partnerships with partners such as Delta Air Lines, United Airlines, Hawaiian Airlines, Alaska Airlines and American Express that promote our services to their customers on a discounted or subsidized basis which allows us to efficiently scale membership in CLEAR+.

CLEAR also offers services that are free to Members, both directly and under agreements with our CLEAR1 B2B partners who typically pay us based on the number of Members or transaction volume. New platform Members are largely driven to our platform by one of our partners who integrate with CLEAR to enable frictionless experiences for their customers. As we grow Members, this further enhances the value of our network, and makes us a more valuable CLEAR1 partner. We believe that as we continue to grow platform Members, this will grow the long-term economic value of our platform by increasing total engagement, expanding our margins and maximizing our revenue.

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Our Competitive Advantages

Trusted and Extensible Brand with Passionate Member Base

From our founding, we have been obsessed with the CLEAR Member experience. We have been expanding our network, investing in our technology platform, strengthening our operations and developing our people to consistently deliver increased value to Members and partners, resulting in our trusted and valued brand. Our passionate Member base drives word-of-mouth marketing and strong retention rates.

Operational Expertise at Scale

Operating and scaling our own consumer-facing service, CLEAR+, over the past 15 years has given us experience and capabilities that are hard to replicate, and an environment for innovation that benefits all of our partners. We have significant expertise implementing and seamlessly operating our platform’s combination of hardware, biometric technology and physical human interactions across 401 regulated or complex environments, such as airports and retail locations. We also manage a large Ambassador and field manager part-time and full-time workforce of approximately 3,708 employees who are deployed across our expansive network of locations to implement our platform and continue to build our brand reputation.

Platform Originated in High Security Aviation Environment

We started in aviation security, a highly regulated environment requiring a robust physical and information security posture. By building our platform in this context, we invested in, and were held accountable for, industry leading security, scalability and reliability. Our comprehensive information security program uses industry best practices with administrative, technical and physical safeguards to protect against anticipated threats or hazards to the security, confidentiality or integrity of CLEAR systems and information. We are certified as Qualified Anti-Terrorism Technology under the Support Anti-Terrorism by Fostering Effective Technologies Act of 2002 (“SAFETY Act”) and FISMA High Rating compliant which governs requirements for protecting sensitive data by the DHS. We continue to operate in aviation security today, and we use the same foundational platform across all our use cases, which is then customized for our owned and operated businesses, such as CLEAR+, and for the CLEAR1 experiences offered through our partners. As such, we bring our high standards of security, scalability, and reliability to every environment in which Members engage with CLEAR.

Innovative and Scalable Platform

We believe that the significant investments we have made in our technology platform are a key differentiator for our business. Our approximately 211 person technology team leads platform innovation inside CLEAR. We have spent more than 15 years to create our scalable and secure back-end and our easy-to-use consumer front-end. The flexibility of our platform allows us to apply our technology to new and innovative sectors quickly and effectively. We built a horizontal platform experience that can be embedded into a partner's native ecosystem so the partner can leverage our verification and enrollment technology. This web experience allows partners to use CLEAR's technology to verify their customers identities and provide frictionless experiences like check-in, identity verification, account opening/KYC, age verification, and a suite of workforce products like employee onboarding, continuous verification, critical access control, and account recovery.

Powerful Network Effects

The power of network effects on our business became evident as we added additional locations and our membership growth accelerated. Given the lengthy airport sales cycle and scarcity of airport real estate, it took us seven years to build a critical mass of airports to attract the first million Members. Once we achieved scale, the power of national network effects began to take hold. As the likelihood that a domestic traveler would have access to a CLEAR+ Lane increased, the value proposition of our CLEAR+ offering increased substantially. Alongside the growth in CLEAR+, our strategy expanded to extend our platform’s capabilities through additional CLEAR Travel offerings and with CLEAR1. Our investment in our platform and products and the expanding scale of our Membership have accelerated the addition of new partners that are enabling our membership growth and increasing verifications.

Our Growth Strategies

Key elements of our growth strategy include:

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•Grow CLEAR+ Members and grow revenue per CLEAR+ Member: We see growth opportunities in our CLEAR+ Member base and opportunities to increase the revenue per CLEAR+ Member through pricing and ancillary revenue initiatives. We believe we can continue to open CLEAR Lanes in new airports and new CLEAR Lanes in our existing airports. As of December 31, 2025, our airport coverage is approximately 79% of 2025 TSA checkpoint volume. 6% and 5% of all TSA checkpoint volume went through a CLEAR lane in 2025 and 2024, respectively. We are also expanding CLEAR+ in the United States to better serve international travelers from over 40 countries, broadening the addressable market for CLEAR+ membership. We also believe there are opportunities to continue to develop new features to improve the Member experience experience to further grow CLEAR+ Members.

•Scale TSA PreCheck® enrollment program: We believe our TSA PreCheck® enrollment will drive significant growth for TSA’s program and an incremental revenue opportunity to CLEAR as we manage renewal processing and new enrollments for TSA PreCheck® subscriptions. TSA PreCheck® also offers a significant top-of-funnel opportunity to acquire new CLEAR+ Members as we offer a CLEAR/TSA PreCheck® bundled product for customers who are new to both CLEAR and to TSA PreCheck®.

•Expand our partnerships and distribution channels: We intend to continue to pursue commercial partners as a means to broaden our distribution channel reach and accelerate Member growth. These partnerships and channels are likely to include new airlines, credit card partners, digital marketplaces, retail enterprises and various CLEAR1 partners in target verticals.

•Expand into new verticals and products: We anticipate continuing to add new products within the Travel vertical. We have also made significant progress expanding from Travel into select new verticals through CLEAR1. We plan to continue investing to increase the growth of our platform, Member base and our network locations where our Members can use and our partners can integrate with CLEAR. We believe we have a proven platform business with numerous natural adjacencies and as our Member base and product portfolio grows, we believe we will have the opportunity to grow into new verticals.

•Acquisitions and corporate development opportunities: We may opportunistically pursue selective acquisitions and other corporate development opportunities to complement our existing platform capabilities and further accelerate our growth and platform adoption.

Competition

We compete for both our Members and our partners. The market in which we operate is highly fragmented and characterized by high growth, shifting user preferences, and introductions of new services and offerings. Our primary competitors are offline alternatives, including manual security checks and screening processes. These alternatives tend to be costly and involve significant manpower, time and resources. See “Risk Factors—Risks Related to Our Business, Brand and Operations—We operate in a highly competitive market, and we may be unable to compete successfully against existing and future competitors.”

Intellectual Property and Other Proprietary Rights

Our intellectual property rights are valuable and important to our business. To establish and protect our proprietary rights, we rely on a combination of patents, trademarks, copyrights, trade secrets, know-how, confidentiality provisions, non-disclosure agreements, assignment agreements, and other legal and contractual rights with employees, contractors, and other third parties to establish and protect our proprietary technology and intellectual property rights.

As of December 31, 2025, we have 114 issued United States patents (with four additional patent applications allowed) and 28 patent applications pending in the United States relating to certain aspects of our technology. We also have a limited number of patents issued and patent applications filed in other countries. Our issued patents expire between 2032 and 2042. As of December 31, 2025, we have seven U.S. registered trademarks, and three trademark applications pending in the United States. These include registrations for the CLEAR name and other brand indicia. We also have registered the domain name www.clearme.com, and similar variations.

We intend to pursue additional intellectual property protection to the extent we believe it would be beneficial and cost effective. Despite our efforts to protect our intellectual property rights, they may not be respected in the future or may be invalidated, circumvented, deemed unenforceable or otherwise challenged. Further, even if we are successful in legal proceedings, unauthorized third parties may still copy or otherwise obtain and use our technology or infringe our copyrights and trademark rights. In addition, should we expand, the laws of various foreign countries where we may expand may not protect our intellectual property rights to the same extent as laws in the United States.

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Companies engaged in related businesses or even unrelated businesses may have patents, copyrights, trademarks, trade secrets and other intellectual property rights which such companies may assert are infringed by our technology or business activities. From time to time, we face, and we expect to face in the future, allegations that we have infringed the patents, copyrights, trademarks, trade secrets and other intellectual property rights of third parties, including our competitors and non-practicing entities. Should our business continue to grow, we will likely face more claims of infringement by third parties. We may become party to patent infringement claims and other intellectual property litigation and legal proceedings, all of which can be expensive and time consuming, and if resolved adverse to the Company, could have a significant impact on our business. See “—Legal Proceedings” and “Risk Factors—Risks Related to Information Technology and Intellectual Property.”

Employees

Our organization’s core values are:

•Our Great People: From our Ambassadors, to our HQ team members, people are at the heart of all that we do.

•Obsessed with Member Experience: We are obsessed with our Member experience. We love hearing from our Members so that we can continuously improve and come back better for them every day.

•Embrace Change: Our growth requires that we embrace change. We pivot to overcome roadblocks and we are transparent on why decisions are made.

•Own It: CLEAR is an organization of doers. We own it by solving problems even if they “aren’t ours to solve” and commit to seeing them all the way through.

•Speak Up: We believe in challenging fearlessly and embracing the brutal truth. We speak up by displaying honesty to our Members, our team members, and ourselves.

•Bias for Action: We encourage our team members to have a bias for action, using data to make calculated decisions. We have confidence in our decisions and learn from our mistakes.

•Indefatigable: We tirelessly pursue our goals with passion and sometimes “no” simply means “not yet.”

As of December 31, 2025, we had 3,301 full-time employees with our largest workforces in New York, New Jersey, and Los Angeles. We compete to attract and retain diverse and highly talented individuals, particularly people with expertise in engineering, product development and marketing. Our ability to recruit and retain talent benefits from our unique workplace culture and brand - with a focus on being a meritocracy. None of our employees are covered by collective bargaining agreements, and we believe our employee relations to be strong.

Government Regulation

Data, Privacy, and Technology

Our business is subject to U.S. federal, state and local laws and regulations. These laws and regulations pertain to matters including but not limited to, the collection and use of personal information, biometric and health information, data privacy, cybersecurity and information protection, labor and employment, intellectual property, consumer deception and unfair practices, artificial intelligence, recurring subscription payments, commercial contracting and others, and are often complex, novel and subject to varying interpretations. As a result, their application in practice may change or develop over time through judicial decisions or as new guidance or interpretations are provided by regulatory and governing bodies, such as federal, state and local administrative agencies. For example, California passed a comprehensive data privacy law, the California Consumer Privacy Act (“CCPA”), which went into effect in January 2020 and was amended by the California Privacy Rights Act (“CPRA”) which took effect on January 1, 2023. Numerous states have passed laws that impose similar requirements on businesses that provide services to their residents, including Virginia, Colorado, Texas and Oregon, and many other states are actively developing legislation in this area. State privacy laws impose a number of data protection obligations on covered businesses, including transparency and consent requirements, consumer rights procedures and obligations, limitations on data uses and new audit requirements, as well as enhanced requirements and restrictions on the use of sensitive personal information such as biometric data. Certain states have laws that specifically regulate the collection and use of biometric information, such as Illinois’s Biometric Information Privacy Act (“BIPA”) and Texas’s Capture or Use of Biometric Information Act (“CUBI”), and numerous states and municipalities are considering similar legislation. In addition, the Health Insurance Portability and Accountability Act of 1996, as amended by the Health

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Information Technology for Economic and Clinical Health Act (“HITECH”), and their respective implementing regulations (collectively, “HIPAA”) impose specific requirements relating to the privacy, security and transmission of sensitive patient health information. Among other things, HITECH makes HIPAA’s security standards directly applicable to “business associates.” See “Risk Factors—Risks Related to Regulation and Litigation—Any actual or perceived failure to comply with applicable laws relating to privacy, biometrics, artificial intelligence, health information and data protection may result in significant liability, negative publicity and erosion of trust and commercial opportunities, and increased regulation could materially adversely affect our business, results of operations and financial condition” and “—The laws and regulations that we are subject to or may become subject to are constantly evolving.”

International Operations

As we expand internationally we become subject to the regulatory regimes in other countries in which we operate, which may be equally or more complex. For example, in 2021, we acquired Whyline, Inc., our virtual queuing technology used for CLEAR Mobile, which had partnerships across international markets. In addition, in 2023, our LinkedIn partnership was extended to Members in Mexico and Canada.

In addition, as we expand in Europe we are subject to the General Data Protection Regulation (“GDPR”). GDPR took effect in May 2018 and includes operational requirements for companies that are established in the European Economic Area (“EEA”) or process personal data of individuals located in the EEA. These requirements govern the processing of personal data and include significant penalties for non-compliance. Additionally, the United Kingdom has transposed GDPR into domestic law with a United Kingdom version of GDPR (combining GDPR and the Data Protection Act of 2018) that took effect in January 2021, which exposes us to two parallel regimes, each of which authorizes similar fines and other potentially divergent enforcement actions for certain violations. In 2022, an Executive Order was signed that, together with regulations issued by the U.S. Department of Justice, implements a new data privacy framework for cross border transfers of EU personal data to the United States (the “EU-U.S. DPF”). The Company has voluntarily self-certified to the EU-U.S. DPF framework, entitling it to certain benefits under the program, as well as subjecting it to enforcement of its compliance with the EU-U.S. DPF principles under U.S. law. Other jurisdictions where we may operate in the future like Canada, Brazil and India have implemented comprehensive data protection regulations that also may diverge from or overlap with these laws. See “Risk Factors—Risks Related to Regulation and Litigation—Any actual or perceived failure to comply with applicable laws relating to privacy, biometrics, artificial intelligence, health information and data protection may result in significant liability, negative publicity and erosion of trust and commercial opportunities, and increased regulation could materially adversely affect our business, results of operations and financial condition” and “—The laws and regulations that we are subject to or may become subject to are constantly evolving.”

Aviation

Our airport operations are subject to standards promulgated by the federal government related to aviation security. These standards pertain to items such as checkpoint operations, enrollment and verification processes, employee hiring and training and information technology. We operate through the Registered Traveler Program (“RT Program”) according to guidelines set forth by the federal government which in some cases are overseen directly by the federal government and in some cases are overseen indirectly through our airport or airline partners. As we have grown, our regulatory frameworks have evolved as well. For example, we are subject to various reporting requirements, audits, reviews and evaluations overseen by the TSA, a sub-agency of the DHS. The DHS has certified our information security program under their purview at a FISMA High Rating (the highest designation according to the Federal Information Security Modernization Act). In addition, the system we use for the RT Program and similar programs has been certified by the DHS as a Qualified Anti-Terrorism Technology under the SAFETY Act. The SAFETY Act provides important legal liability protections for providers of qualified anti-terrorism products and services. Under the SAFETY Act, technology providers may apply to the DHS for coverage of the products and services. If granted coverage, such providers receive certain legal protections against product liability, professional liability and certain other claims that could arise following an act of terrorism. See “Risk Factors—Risks Related to Regulation and Litigation—We must continue to meet the standards set for our airport operations by governmental stakeholders” and “—Liability protections provided by the SAFETY Act may be limited.”

The foregoing description does not include an exhaustive list of the laws and regulations governing or impacting our business. See the discussion contained in the “Risk Factors” section of this annual report for the fiscal year ended December 31, 2025 (“Annual Report on Form 10-K”) for information regarding how actions by governmental stakeholders and regulatory authorities or changes in legislation and regulation in the jurisdictions in which we operate may have a material adverse effect on our business.

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Corporate History

The Company (together with its consolidated subsidiaries, ”CLEAR,” “we,” “us,” “our”) is a holding company and its principal asset is the controlling equity interest in Alclear Holdings, LLC (“Alclear”) and its wholly owned subsidiaries. The Company, which was formed in connection with our initial public offering (“IPO”), was incorporated as a Delaware corporation on March 2, 2021, and Alclear was formed as a Delaware limited liability company on January 21, 2010. Pursuant to the terms of the Second Amended and Restated Operating Agreement dated June 7, 2023 (the “Operating Agreement”), as the sole managing member of Alclear, the Company operates and controls all of the business and affairs of Alclear, and through Alclear and its subsidiaries, conducts the Company’s business.

Available Information

Our internet address is www.clearme.com and the investor relations section of our web site is located at www.ir.clearme.com. We make available free of charge, on or through the investor relations section of our web site, this Annual Report on Form 10-K, Quarterly Reports on Form 10-Q, Current Reports on Form 8-K and amendments to those reports filed or furnished pursuant to Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as well as proxy statements, as soon as reasonably practicable after we electronically file such material with, or furnish it to the SEC. Also posted on our web site are our by-laws, our Certificate of Incorporation, and the charters for the Audit Committee, Compensation Committee and Nominating and Corporate Governance Committee of our board of directors (the “Board”). In addition, our web site includes information concerning purchases and sales of our equity securities by our executive officers and directors, as well as disclosure relating to certain non-GAAP financial measures (as defined in Regulation G) promulgated under the Securities Act of 1933, as amended (the “Securities Act”) and the Securities Exchange Act of 1934, as amended (the “Exchange Act”) that we may make public orally, telephonically, by webcast, by broadcast or by similar means from time to time. Information contained on our website is not incorporated by reference unless specifically referenced herein. We are subject to the informational requirements of the Exchange Act and therefore file periodic reports, proxy statements and other information with the SEC. In addition, the SEC maintains an internet site (http://www.sec.gov) that contains reports, proxy and information statements and other information regarding issuers that file electronically. To the extent required by the SEC's rules and regulations, we intend to post amendments to or waivers from, if any, provisions of our Code of Conduct and Ethics (to the extent applicable to our directors, principal executive officer, principal financial officer and principal accounting officer) at this location on our website. Our stockholders may also obtain these documents in paper format free of charge upon request made to our Investor Relations Department.

Our Investor Relations Department can be contacted at Clear Secure, Inc., 85 10th Avenue, New York, NY 10011, Attn: Investor Relations, e-mail: ir@clearme.com.