Effective Date: March 20, 2019
- General Disclosures
- What Information We Collect
- How We Use Your Information
- When and with Whom We Share Your Information
- Cookies Policy
- Third-Party Advertising and Analytics
- Linking Sites
- Social Media
- How Long We Retain Your Information
- Marketing and Promotional Communications
- Children’s Online Privacy and Protection Act Compliance
- California Privacy Rights
- Contact Us
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:
- Identity Data includes first name, last name, or similar identifier.
- Business Contact Data includes company mailing address, email address and telephone numbers.
- Transaction Data includes details about payments to and from your company and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and third-parties and your communication preferences.
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”).
HOW WE USE YOUR INFORMATION
We may use information about you for a number of purposes, including:
1. Providing, Improving and Developing Our Services
- Reviewing and analyzing user browser and wireless device technical information;
- Reviewing user activity across site(s) (for example, Climb Marketing analyzes trends, user traffic and usage information to determine the performance of content, research reports or events);
- Processing or recording payment transactions;
- Otherwise providing you with the Climb Marketing products and features you choose to use;
- Displaying your historical transaction information;
- Providing, maintaining and improving our Services;
- Developing new products and Services;
- Delivering the information and support you request;
- Improving, personalizing and facilitating your use of our Services; and
- Measuring, tracking and analyzing trends and usage in connection with your use or the performance of our Services.
2. Communicating With You About Our Services
- Responding to questions or concerns;
- Sending you information we think you may find useful or which you have requested from us about our Services and the industry we serve; and
- Conducting surveys and collecting feedback about our industry and Services.
3. Protecting Our Services and Maintaining A Trusted Environment
- Enforcing our Terms of Service or other applicable agreements or policies;
- Verifying your identity;
- Complying with any applicable laws or regulations, or in response to lawful requests for information from the government or through legal process;
- Fulfilling any other purpose disclosed to you in connection with our Services;
- Analyze trends and user traffic, track purchases and usage information; and
- Contacting you to resolve disputes and provide assistance with our Services.
4. Advertising and Marketing
- Marketing of our Services, events, research and products;
- Communicating with you about opportunities, products, services, promotions, discounts, incentives, surveys and rewards offered by us and select partners;
- If we send you marketing emails, each email will contain instructions permitting you to “opt-out” or unsubscribe of receiving future marketing or other communications; and
- If we obtain any personal information from you we will not sell it to third-parties. It may be used internally as part of promotion programs and we may only disclose non-personally identifiable compilations of information to third-parties for marketing related purposes.
- You can ask us or third-parties to stop sending you marketing messages at any time by contacting us. To learn about your choices regarding interest-based advertising and cross-device tracking, please see below.
5. Other Uses
- For any other purpose disclosed to you in connection with our Services from time to time.
WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION
1. When And How We May Share/Disclose Your Information With Third-Parties
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.
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:
- analyze the usage of the Site (e.g. what links users click on) in order to improve our offering;
- test different versions of the Site to see which particular features or content users prefer to optimize the Site;
- provide a more personalized experience to users with more relevant content and course recommendations; and
- allow users to more easily log in to use the Site and Services.
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:
- Google Chrome
- Mozilla Firefox
- Microsoft Internet Explorer
- Microsoft Edge
- Safari for iOS (iPhone and iPad)
- Chrome for Android
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
THIRD-PARTY ADVERTISING AND ANALYTICS
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.
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.
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.
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.
200 E. Liberty St.
P.O. Box 8376
Ann Arbor, MI 48107
privacy [at] climbmarketing.com
TABLE OF COOKIES
|__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 Ad analytics||1 month|
|lang||Determines language preferences||N/A|
|lidc||Used for routing||24 hours|
|bcookie||Browser ID cookie||2 years|
|__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|
|_fbp||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|
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).
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.
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:
- about your visits to and use of this Site;
- when you order or agree to purchase or avail yourself of goods or services;
- to provide you with personalized content and advertising;
- to provide product or service information (whether with regard to content, events, products, services or otherwise);
- about any transactions carried out between you and us, including information relating to digital products, surveys and other services;
- you provide to us if you correspond with us;
- if you request services or information, we may ask you for your name, age, geo-location and other demographic information, email address, street address or other business contact information (you may, however, visit the Site without providing that information); and
- if you purchase Climb Marketing’s products and services, we collect billing and credit card 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:
- Performance of a contract – We may need to collect and use your personal data to enter into a contract or to perform a contract that you or your company has with us.
- Consent – Where required by applicable laws, we will rely on your consent for collecting your personal data.
We will only process personal data for a specific purpose or for any other purposes permitted by applicable law.
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.
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.
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 firstname.lastname@example.org. 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.
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@example.com.
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.
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.
200 E. Liberty St.
P.O. Box 8376
Ann Arbor, MI 48107
privacy [at] climbmarketing.com
CHANGES TO THE INTERNATIONAL POLICY