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Climb Marketing
Privacy Policy

Climb Marketing/Privacy Policy

Effective Date: March 22, 2021

Climb Marketing believes in your right to privacy when using the Internet or our products and services, and protecting your personal information is our priority. As such, Climb Marketing and its affiliates (“Climb Marketing”) have created this Privacy Policy in order to demonstrate our firm commitment to privacy. This Privacy Policy describes how Climb Marketing collects, uses, discloses, transfers, stores, retains or otherwise processes your information when you (whether in your individual or business capacity) access or use, in any manner, any content, products, services provided by Climb Marketing or related activities (collectively “Services”), including but not limited to:

climbmarketing.com

We refer to the above website and related websites as “Site”, unless such related website contains a separate privacy policy. When we refer to “we,” “us,” or “our,” we mean Climb Marketing, or the specific division, subsidiary, or affiliate that operates a site, provides its content, or processes information received through it. When we refer to “you” or “your,” we mean the person accessing the site. If the person accessing the site does so on behalf of, or for the purposes of, another person, including a business or other organization, “you” or “your” also means that other person, including a business organization.

This Privacy Policy applies to your use of our Services and Site, and covers information collected in connection with your access to and use of our Services and Site. Please read this Privacy Policy carefully. By continuing to interact with our Services, you are consenting to the practices and terms described in this Privacy Policy.

Our Privacy Policy Includes:

GENERAL DISCLOSURES

Each of the sites are hosted in the United States and their intended use is Business to Business. If you are visiting this Site from outside of the United States, please note that by providing your information it is being transferred to, stored or processed in the United States and other countries, where our data center and servers are located and operated. This section sets forth the general Privacy Policy for the United States and other jurisdictions not otherwise specifically covered by the International Privacy Policy below. If you are in Canada or the European Economic Area please see the provisions under our International Privacy Policy. If you are outside the United States and do not wish to allow the transfer of your personal data to the United States, you should not use these sites and opt-out of the collection of cookies. View our Cookies Cookies Policy.

Business information. This Site and our Services are not intended for use by consumers or by individuals in their private capacity. We collect your business contact information, such as your full name and your business name, email address, telephone number, address, and other work-related information you provide to us in the course of providing our Services to you or your organization.

We take your privacy and the protection of your personal information seriously. We will only store, process and disclose your personal information in accordance with applicable law. We will make it clear when we collect personal information and will explain what we intend to do with it. We do our best to protect your privacy through the appropriate use of information security measures.

WHAT INFORMATION WE COLLECT

1. Information You Provide To Us Directly
Climb Marketing may collect different information from or about you depending on the manner in which you use our Site or Services. The following examples are provided to help you better understand the information we may collect through your use of the Site or in the course of us providing our Services.

We may collect, use, store and transfer different kinds of personal information about you, which we have grouped together as follows:

As an example of how we collect any information you provide to us directly, in order to use certain features of our Site, such as requesting a demonstration, you are required to provide your name and business contact information, and in that case, we will collect and store any information you provided to us, such as name, business email, phone, company name, and job title.

2. Information Received Through Third-Party Platforms
You may access our Site through third-party platforms, such as Facebook. If you use our Site on or through a third-party platform, including via any mobile and/or other Internet connected devices (“Wireless Devices”), or click on third-party links, the collection, use, and disclosure of your information and your use of the Site will also be subject to the privacy policies and other terms of such third-parties or third-party platforms. You should review such privacy policies, terms and other agreements.

3. Collection of Technical Information And Usage Data
When you access our Site, we automatically collect certain information. This information may include without limitation: (a) technical information about your computer or Wireless Device, such as your IP address, geolocation information, device type, operating system type and version, unique device ID, browser, browser language, domain and other systems information or platform types (collectively “Technical Information”); and (b) usage statistics about your interaction with our Site, including pages accessed, referring website address(es) time spent on pages, pages visited, search queries, click data, date and time and other information regarding your use of our Site (collectively “Usage Data”).

This Technical Information and Usage Data, which may be linked to your personal information, is collected through the use of server logs and tracking technologies, including: (i) cookies, which are small pieces of code that websites send to your computer or Wireless Device to uniquely identify your browser or mobile device or to store information in your browser setting; and (ii) web beacons, which are small objects that allow us to measure the actions of visitors using our Site. For more detailed information regarding how we use cookies and other technology, please review the additional information in our Cookies Policy.

HOW WE USE YOUR INFORMATION

We may use information about you for a number of purposes, including:

1. Providing, Improving and Developing Our Services

2. Communicating With You About Our Services

3. Protecting Our Services and Maintaining A Trusted Environment

4. Advertising and Marketing

5. Other Uses

WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION

1. When And How We May Share/Disclose Your Information With Third-Parties
We may share your information with third-party companies that perform services on our behalf, including for payment processing, order fulfillment, data analysis, marketing services, advertising services (including but not limited to retargeted advertising), e-mail and hosting services, and customer services and support or as otherwise described in this Privacy Policy:

These third-party service providers may access your personal information and may only use it as directed by us for the purpose of our requested service.

We require all third-parties to respect the security of your personal data. We do not allow our third-party service providers to use your personal information for their own purposes and they are only permitted to process your personal information in accordance with our instructions.

2. Corporate Transactions
We may share your personal information with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of Climb Marketing’s business or assets to such business entity (including due to a sale in connection with a bankruptcy). We will require any such purchaser, assignee or other successor business entity to honor the terms of this privacy statement.

3. Disclosure of Information for Legal Purposes
We may disclose personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating any agreement with Climb Marketing, or may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of our site(s), or anyone else that could be harmed by such activities. We may disclose information in response to a subpoena, search warrant, in connection with judicial proceedings, or pursuant to court orders, legal process or other law enforcement measures. We may disclose or access personal information when we believe in good faith that the law requires it, to establish our legal rights or to defend against legal claims, and for administrative and other purposes that we deem necessary to maintain, service and improve our products and Services.

4. Analytics and Data Enrichment Services
We use third-party analytics such as Google Analytics to help us understand your usage of our Site and to improve our Services.

5. Aggregated or De-identified Information
We may disclose or use aggregated or de-identified information for any purpose. Aggregated Data may be derived from your personal information but does not directly or indirectly reveal your identity.

COOKIES POLICY

Like many online platforms, Climb Marketing and its analytics vendors use server logs and automated data collection tools, such as browser cookies, pixel tags, scripts and web beacons. These tools are used for analytics purposes to enable us to understand how users interact with the Site and Services. Climb Marketing and its analytics vendors may tie the information gathered by these means to the identity of users.

Cookies are small text files placed on a computer or device while browsing the Internet. Cookies are used to collect, store and share bits of information about user activities. We use both session cookies and persistent cookies.

Session cookies are used to identify a particular visit to our Site and collect information about your interaction with the Site. These cookies expire after a short time or when the user closes their web browser after using the Site. We use these cookies to identify a user during a single browsing session, such as when you log into the Site. This helps us improve the Site and Services as well as improve your browsing experience.

A persistent cookie will remain on a user’s device for a set period of time specified in the cookie. We uses these cookies to identify and recognize a specific user over a longer period of time. They allow us to:

Examples of persistent cookies include: (i) preferences cookies to remember information about a user’s browser and settings preferences, such as preferred language – preference cookies make a user’s experience more functional and customized, (ii) authentication and security cookies to enable a user to log in or stay logged in to access the Site and Services, to protect user accounts against fraudulent log-ins by others and to help detect and protect against abuse or unauthorized usage of user accounts and (iii) functional cookies to make the experience of using the Site and Services better, like remembering the sound volume level selected by the user.

We use tracking technology to: (i) determine if a certain page was visited or whether an email we send was opened or clicked on by a user; and (ii) to customize the experience of individual users by recommending specific content.

We also use clear gifs in HTML-based emails sent to our users to track which emails are opened and clicked on by recipients. We may use the information we obtain from the cookie in the administration of the Site, to improve the usability of the Site and for marketing purposes. We may also use that information to recognize your computer when you visit our Site, and to personalize our Site for you.

Cookies and information captured through our Site are stored for a certain retention period, however you can eliminate these cookies any time before the expiration date. Below is our Table of Cookies.

How to Restrict Cookies
You can adjust the settings in your browser in order to restrict or block cookies that are set by the Services (or any other site on the Internet). Your browser may include information on how to adjust your settings. Alternatively, you may visit www.allaboutcookies.org to obtain comprehensive general information about cookies and how to adjust the cookie settings on various browsers. This site also explains how to delete cookies from your computer.

You can control and delete these cookies through your browser settings through the following:

You can also use the following cookie management and disposal tool from Google Analytics by downloading and installing the browser plug-in from the following link: https://tools.google.com/dlpage/gaoptout.

Please be aware that restricting cookies may impact the functionality of the Services. Most browsers allow you to refuse to accept cookies. Additional general information about cookies, including how to be notified about the placement of new cookies and how to disable cookies, can be found at https://www.allaboutcookies.org.

Do Not Track
Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking across websites. Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, so we do not take any action in response to this signal. We do not have a mechanism in place to respond to DNT signals. Instead, in addition to publicly available third-party tools, we offer you the choices described in this Privacy Policy to manage the collection and use of information about you.

We do track some activity across websites (including your search terms, the website you visited before you visited or used the Services and other clickstream data) and we may continue to collect information in the manner described in this Privacy Policy from web browsers that have enabled DNT signals or similar mechanisms.

THIRD-PARTY ADVERTISING AND ANALYTICS

We may use third-party service providers to provide site metrics and other analytics services. These third-parties may use cookies, web beacons, and other technologies to collect information, such as your IP address, identifiers associated with your device, other applications on your device, the browsers you use to access our Site and Services, webpages viewed, time spent on webpages, links clicked, and conversion information (e.g., transactions entered into). This information may be used by Climb Marketing and third-party service providers on behalf of Climb Marketing to analyze and track usage of our Site and Services, to determine the popularity of certain content and to better understand how you use our Site and Services. The third-party service providers that we engage are bound by confidentiality obligations and other restrictions with respect to their use and collection of your information.

This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons or other tracking technologies, which are covered by such third-parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third-parties to learn about their privacy practices.

LINKING SITES

The Site may contain links to other third-party websites. We are not responsible for the privacy practices or the content of such websites, including any websites that may indicate a special relationship or partnership with us (such as co-branded pages or “powered by” or “in cooperation with” relationships). We do not share information we gather with other websites or any other entities or individuals unless such sharing is disclosed to you in advance through this Privacy Policy. These linked third-party websites, however, may collect personal information from you that is not subject to our control. To ensure protection of your privacy, always review the privacy policy of the websites you may visit by linking from the Site. Please note that this Privacy Policy applies only to our Site as indicated above, and not to other companies’ or organizations’ websites to which we link.

For instance, information collected through Google Analytics is shared with Google and its partners who may combine it with other information you provided to them or they collected from your use of their services. This information is stored and handled by Google according to its privacy practices.

Social Media
We may collect information from other sources, such as social media platforms that may share information about how you interact with our social media content. We do not control how your personal information is collected, stored or used by such third-party websites or to whom it is disclosed. You should review the privacy policies and settings on any social media site that you subscribe to so that you understand the information they collect and may be sharing. If you do not want your social media websites to share information about you, you must contact that website and determine whether it gives you the opportunity to opt-out of sharing such information. Climb Marketing is not responsible for how these third-party websites may use information collected from or about you.

Further, our Site may include social media features, such as links to Climb Marketing’s pages or profiles on social media platforms. Our integration of these features may allow third-party social media platforms to collect certain information, such as your IP address and which page(s) you are visiting when using our Site and Services, and to set a cookie to enable that feature to function properly. Your interactions with these features are governed by the privacy policy of the respective social media platform.

HOW LONG WE RETAIN YOUR INFORMATION

We generally retain your information as long as reasonably necessary to provide you Services or to comply with applicable law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal requirements. We may retain copies of information about you and any transactions or Services you have used for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce other applicable agreements or policies or to take any other actions consistent with applicable law.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research, marketing or statistical purposes, in which case we may use this information indefinitely without further notice to you. This allows the specific information collected (name, email, address, phone number, etc.) to become anonymous, but allows Climb Marketing to keep the transaction or engagement data. For example, Climb Marketing will not be able to tell if John Smith registered for an event, but we will be able to tell that a person registered for an event and maintain headcount and transactional history. This will allow Climb Marketing to maintain a level of information that helps us develop and improve our Site and Services.

MARKETING AND PROMOTIONAL COMMUNICATIONS

You may opt-out of receiving or unsubscribe from marketing and promotional messages from Climb Marketing, if those messages are powered by Climb Marketing, by following the instructions in those messages. If you decide to opt-out, you will still receive non-promotional communications relevant to your use of our Services.

CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) COMPLIANCE AND RELATED INFORMATION

The Children’s Online Privacy and Protection Act (COPPA) regulates online collection of information from persons under the age of 13. It is our policy to refrain from knowingly collecting or maintaining personal information relating to any person under the age of 18. If you are under the age of 18, please do not supply any personal information through the Site. If you are under the age of 18 and have already provided personal information through the Site, please have your parent or guardian contact us immediately using the information provided under Contact Us so that we can remove such information from our system.

SECURITY

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, no online or computer environment is 100% secure, and we cannot guarantee absolute security of the transmission or storage of your information. We hold information about you both at our own premises and with the assistance of third-party service providers. Further public disclosure here of our security measures could aid those who might attempt to circumvent those security measures. If you have additional questions regarding security, please feel free to contact us directly using the information provided under Contact Us.

To ensure that our employees comply with our privacy policies, we have developed a training program that provides all employees with the tools and knowledge to protect your personal information in all aspects of their work. Any employee who violates our privacy policies is subject to disciplinary action, including possible termination and civil and/or criminal prosecution.

CALIFORNIA PRIVACY RIGHTS

California law permits residents of California to request certain details about our disclosure of your personal information by us to third-parties for direct marketing purposes during the immediate preceding calendar year. If you are a California resident and would like to request this information, please contact us using the information provided under Contact Us.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be revised from time to time as we add new features and Services, as laws change and as industry privacy and security best practices evolve. We display an effective date on this Privacy Policy at the top of this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any material change to this Privacy Policy regarding use or disclosure of personal information, we will provide notice on the Site. Changes will apply to information collected after the change is effective. Please check this Privacy Policy periodically for changes. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice. Your use of the Site constitutes acceptance of the provisions of this Privacy Policy and your continued usage after such changes are posted constitutes acceptance of each revised Privacy Policy. If you do not agree to the terms of this Privacy Policy or any revised Privacy Policy, please exit the Site immediately. If you have any questions about this Privacy Policy, the practices of the Site or your dealings with the Site, you can contact us by using the information provided under Contact Us.

CONTACT US

Please contact us with any complaints, questions or concerns regarding this Privacy Policy.

Climb Marketing
200 E. Liberty St.
P.O. Box 8376
Ann Arbor, MI 48107
privacy [at] climbmarketing.com

If you have any questions or concerns regarding our Privacy Policy, or if you believe our Privacy Policy or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with us using the contact information listed above, and we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution.

TABLE OF COOKIES

Cookie Name Service Description Expiration
__cfduid Hubspot This cookie ensures that all Hubspot features and functionality are added to the site correctly. 1 year and 1 day
_ga Google Analytics This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session, and campaign data for the site’s analytics reports. 2 years
_gat Google Analytics This cookie is used to throttle the request rate – limiting the collection of data on high traffic sites. 10 minutes
_gid Google Analytics Like _ga, this cookie is used to site users. 24 hours
__hstc Hubspot This cookie is used for website analytics. 2 years
__hssc Hubspot This cookie is used for website analytics. 30 minutes
__hssrc Hubspot This cookie is used for website analytics. Session
hubspotutk Hubspot This cookie is used for user authentication. 1 year
wordpress_test_cookie WordPress Used on sites built with WordPress. Tests whether or not the browser has cookies enabled Session
BizoID LinkedIn LinkedIn Ad analytics 1 month
lang LinkedIn Determines language preferences N/A
lidc LinkedIn Used for routing 24 hours
_lipt LinkedIn 1 month
li_oatml LinkedIn 1 month
UserMatchHistory LinkedIn 1 month
liap LinkedIn 4 months
sdsc LinkedIn N/A
bcookie LinkedIn Browser ID cookie 2 years
_guid LinkedIn 4 months
__cfduid Cloudflare Cookie assoiated with sites using CloudFlare, used to speed up page load times. According to CloudFlare it is used to override any security restrictions based on the IP address the visitor is coming from. It does not contain any user identification information. 1 year
cookieconsent_status Climb Marketing Used to determine ackowledgement of Climb Marketing’s website cookie policy 1 year
_fbp Facebook Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers 15 months
__hluid Hubspot In-app usage tracking 1 year
_hjid Hotjar Hotjar cookie that is set when the customer first lands on a page with the Hotjar script. It is used to persist the Hotjar User ID, unique to that site on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID. 1 year
_hjRecordingLastActivity Hotjar This should be found in Session storage (as opposed to cookies). This gets updated when a visitor recording starts and when data is sent through the WebSocket (the visitor performs an action that Hotjar records). Session
__cfduid Hotjar Cookie assoiated with sites using CloudFlare, used to speed up page load times. According to CloudFlare it is used to override any security restrictions based on the IP address the visitor is coming from. It does not contain any user identification information. 1 year
_hjTLDTest Hotjar When the Hotjar script executes we try to determine the most generic cookie path we should use, instead of the page hostname. This is done so that cookies can be shared across subdomains (where applicable). To determine this, we try to store the _hjTLDTest cookie for different URL substring alternatives until it fails. After this check, the cookie is removed. Session
_hjUserAttributesHash Hotjar User Attributes sent through the Hotjar Identify API are cached for the duration of the session in order to know when an attribute has changed and needs to be updated. Session
_hjCachedUserAttributes Hotjar This cookie stores User Attributes which are sent through the Hotjar Identify API, whenever the user is not in the sample. These attributes will only be saved if the user interacts with a Hotjar Feedback tool. Session
_hjLocalStorageTest Hotjar This cookie is used to check if the Hotjar Tracking Script can use local storage. If it can, a value of 1 is set in this cookie. The data stored in_hjLocalStorageTest has no expiration time, but it is deleted almost immediately after it is created.. Under 100ms
_hjIncludedInPageviewSample Hotjar This cookie is set to let Hotjar know whether that visitor is included in the data sampling defined by your site’s pageview limit. 30 minutes
_hjIncludedInSessionSample Hotjar This cookie is set to let Hotjar know whether that visitor is included in the data sampling defined by your site’s daily session limit. 30 minutes
_hjAbsoluteSessionInProgress Hotjar This cookie is used to detect the first pageview session of a user. This is a True/False flag set by the cookie.. 30 minutes
_hjFirstSeen Hotjar User Attributes sent through the Hotjar Identify API are cached for the duration of the session in order to know when an attribute has changed and needs to be updated. Session
_hjViewportId Hotjar This stores information about the user viewport such as size and dimensions.. Session
_hjRecordingEnabled Hotjar This is added when a Recording starts and is read when the recording module is initialized to see if the user is already in a recording in a particular session. Session

INTERNATIONAL PRIVACY POLICY

Both the above general Privacy Policy and this International Privacy Policy (the “International Policy”) apply to those visiting the Site or using our Services from Canada or the European Economic Area except that, for such persons (and only for such persons), where the provisions of the general Privacy Policy and the International Policy cannot be construed consistently, the International Policy will govern.

The Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the European Union General Data Protection Regulation (“GDPR”) impose requirements regarding the collection, use, and disclosure of personal data in relation to our commercial activities, as does private-sector privacy legislation in their local jurisdictions, provinces and territories.

THIS INTERNATIONAL POLICY APPLIES TO ALL PERSONAL DATA ABOUT YOU THAT WE COLLECT, HOLD, USE AND DISCLOSE, REGARDLESS OF THE WAY IN WHICH WE COLLECT IT (I.E. WHETHER THROUGH A SITE OR OTHERWISE).

PERSONAL DATA

In this International Policy, personal data is as defined by applicable European Union and Canadian law. It generally means any information that may be used to identify an individual. It may include your name, age, mailing address, residential phone number, or e-mail address, personal history (including financial and credit information, donations, personal health information, billing history, personal family and relationship matters, and penal or criminal information), personal information related to corporate involvements, work experience (past and present), discipline, income and benefits, medical records, tax records, and security clearances.

Any references to personal information in the general Privacy Policy shall be read as to mean personal data with respect to individuals within Canada and the European Economic Area.

COLLECTION OF PERSONAL DATA

We collect personal data from this Site, as well as through correspondence, emails, telephone inquiries, web forms, and other means of communication. We collect such information when you visit our Site, we provide you with products or Services, and other lawful purposes.

We (and our affiliates and authorized service providers) may collect, store and use information:

We also may collect information about your computer and your visits to this Site such as your IP address, geographical location, browser type, domain names, referring website addresses, access times, length of visit and number of page views. We may use this information in the administration of this Site, to improve the Site’s usability, to provide better service, to send you newsletters, updates, marketing communications, and other information or that may be of interest to you. We also use outside services such Google Analytics to gather data about our Site visitors. We may sometimes permit our authorized service providers to have access to aggregate statistics about our customers, sales, traffic patterns, usage and related information.

We often collect personal data from you or from third-parties and as agents on behalf of third- parties, where we have obtained the requisite consent to do so or as otherwise permitted by law. Third-parties include, as examples, organizations for whom we provide services to you or on your behalf, and organizations that perform outsourcing and other services for us (such as payment processors, order fulfillment organizations, software application companies, other service organizations, and systems development and maintenance organizations).

Where we are the Data Controller with regard to that personal data you may exercise your rights as a data subject, including the right to object to the processing of your personal data as provided by applicable law and in this International Policy.

HOW WE USE PERSONAL DATA

As a general matter, we collect your personal data primarily to provide services to our customers, for administrative or management requirements, and to enhance our relationship with customers.

Climb Marketing collects and uses your personal data to operate its website(s) and deliver the services you have requested.

Climb Marketing may also use your personal data to inform you of other products or services available from Climb Marketing and its affiliates. Climb Marketing may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

Climb Marketing does not sell, rent or lease its customer lists to third-parties.

Climb Marketing may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your personal data (e-mail, name, address, telephone number) is not transferred to the third-party. Climb Marketing may share data with trusted partners to help perform statistical analysis, send you email or postal mail, or provide products, services, or customer support. All such third-parties are prohibited from using your personal data except to provide services to you, and they are required to maintain the confidentiality of your data.

Climb Marketing may keep track of the websites and pages our users visit within the Site, in order to determine what Services are the most popular. This data is used to deliver customized content and advertising within Climb Marketing to customers whose behavior indicates that they are interested in a particular subject area.

THE BASIS ON WHICH WE PROCESS YOUR PERSONAL DATA

We rely on the following legal grounds to process your personal data, namely:

We will only process personal data for a specific purpose or for any other purposes permitted by applicable law.

OBTAINING CONSENT

Except when otherwise permitted by law, we obtain the requisite consent prior to collecting and, in any case, prior to using or disclosing your personal data for any purpose. You may provide your consent to us orally, in writing, by electronic communication, or any other means reasonably capable of conveying your consent. We will obtain your express consent if we collect, use or disclose sensitive personal data in our capacity as a Data Controller. We may also share data with third-parties partners for whom you have given us consent. Your consent may also be intrinsic to the circumstances such as in the case where you have already provided personal data to us and you maintain your relationship with us or where you provide our representatives with your phone number so that we can contact you. Except when otherwise permitted by law, we will only use the data for the purpose for which it was given. From time to time, we may collect, utilize, or disclose your personal data based on your consent and as otherwise permitted by law.

When your consent is required, you may withdraw your consent at any time (unless withdrawing the consent would frustrate the performance of legal obligations) upon providing to us a 30-day notice. However, the withdrawal of your consent may adversely affect our ability to provide Services and information to you and to maintain our relationship.

THIRD-PARTIES

We remain responsible for all personal data communicated or shared with third-parties for processing. As such, we ensure that third-parties that are engaged to provide products or services on our behalf and are provided with personal data are required to observe the intent of this International Policy by having comparable levels of security protection or, when required, through contractual assurances that they will not use or disclosure the personal data for any purpose other than the purpose for which the personal data was communicated.

LIMITATIONS

We only collect the personal data necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by law.

We do not use or disclose your personal data, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law.

We do not, as a condition of providing services to you or on your behalf, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal data beyond what is reasonably required for such purposes, or to comply with our obligations under applicable law.

RETENTION OF PERSONAL DATA

We may keep a record of your personal data, including correspondence or comments, in a file specific to you. We will utilize, disclose, or retain your personal data only for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. When personal data is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal data retention policies.

ACCESS AND RIGHTS TO YOUR PERSONAL DATA

Subject to the exceptions provided by the applicable law, we will make available to you any of your personal data that we have collected, utilized or disclosed, upon your written request. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes and using an alternative format, if required. You also have rights of access, rectification, erasure, restriction, objection or portability in line applicable law and in line with the type of services being provided. Simply send your request via email to [email protected]. Please be as specific as possible in your request so that we can meet the applicable time lines.

If you are a located in the European Economic Area, you also have the right to lodge a complaint with your Supervisory Authority.

1. Response Times
We will make every reasonable effort to respond to each of your written requests not later than 30 days after receipt of such requests. When applicable, we will advise you in writing if we cannot meet your requests within this time limit. When applicable, you have the right to make a complaint to the appropriate supervisory authority with respect to this time limit.

2. Costs
We expect to be able to respond to your request without charge as a general matter. However, we reserve the right to collect a reasonable charge when you request the transcription, reproduction, or transmission of such information. We will notify you, following your request for transcription, reproduction, or transmission, of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request.

3. Identifying You in Connection with Requests
We may require that you provide to us sufficient information to identify yourself before we provide information about the existence, use, or disclosure of your personal data in our possession. Any such information shall be used only for this purpose.

OPT-OUT & UNSUBSCRIBE

We respect your privacy and give you an opportunity to opt-out of receiving or unsubscribe from certain information. Users may opt-out or unsubscribe using the instructions located in e-mails sent by Climb Marketing or by contacting us [email protected].

ACCURACY

We will use reasonable efforts to ensure that your personal data is kept as accurate, complete, and up-to-date as possible. We will not routinely update your personal data, unless such a process is necessary. In order to help us maintain and ensure that your personal data is accurate and up to date, you must inform us, without delay, of any change in the data you provided to us.

You can at any time, challenge the accuracy or completeness of the personal data we have about you, subject to the exceptions provided by applicable law. If you demonstrate that the personal data we have on you is inaccurate or incomplete, we will amend the personal data as required. Where appropriate, we will transmit the amended data to third-parties with whom we have communicated or shared your personal data.

SAFEGUARDS

Personal data is generally located at our corporate offices. We use security safeguards appropriate to the sensitivity of personal data to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances, and publishing this policy to appropriate personnel with instructions to act in accordance with its principles (for example, limiting access on a “need to know” basis), and technological measures, such as the use of passwords and/or encryption.

CONTACT US

Please direct all complaints or other inquiries regarding personal data, the general Privacy Policy, or this International Policy to us at:

Climb Marketing
200 E. Liberty St.
P.O. Box 8376
Ann Arbor, MI 48107
privacy [at] climbmarketing.com

CHANGES TO THE INTERNATIONAL POLICY

This International Policy may be revised from time to time as we add new features and Services, as laws change and as industry privacy and security best practices evolve. We display an effective date on this Privacy Policy at the top of this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any material change to this Privacy Policy regarding use or disclosure of personal information, we will provide notice on the Site. Changes will apply to information collected after the change is effective. Please check this Privacy Policy periodically for changes. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice. Your use of the Site constitutes acceptance of the provisions of this Privacy Policy and your continued usage after such changes are posted constitutes acceptance of each revised Privacy Policy. If you do not agree to the terms of this Privacy Policy or any revised Privacy Policy, please exit the Site immediately. If you have any questions about this Privacy Policy, the practices of the Site or your dealings with the Site, you can contact us by using the information provided under Contact Us.