Introduction
Welcome to Climb Global Solutions privacy notice.
We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how Climb Global Solutions, Inc. (“Climb”, “we”, “us”, or “our”) collect, use, and disclose the information of individuals who visit our website at https://www.climbcs.com/ or other Climb websites that link to this privacy notice (collectively, the “websites”), including Climb Channel Solutions and Grey Matter. The sections of this notice for international and California visitors also apply to personal information collected through means other than the websites. This notice informs you of privacy rights you may have under applicable law.
This privacy notice is provided in a linked format so you can click through to the specific areas set out below.
- 1. Important information
- 2. The data we collect about you
- 3. How is your personal data collected?
- 4. Purposes for which we will use your personal data
- 5. Disclosures of your personal data
- 6. Digital analytics
- 7. Data security
- 8. Data retention
- 9. International visitors
- 10. California visitors
- 11. Our contact details
Important Information
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data through your use of our websites, including any data you may provide through a website when you sign up to our newsletter, apply for a credit account, purchase a product or service or take part in a competition.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
Climb is the “controller” of your personal data and acts as a “business” under certain privacy laws. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Third-party links
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy notice of every website you visit.
Effective date of the privacy notice
This notice was last updated on March 3, 2024 and historic versions can be obtained by contacting us as described in the “Our contact details” section of this Privacy Notice.
Changes to the privacy notice
If our information practices change, we will post these changes on this page. We encourage you to visit this page periodically to learn of any updates.
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together follows:
- Identity Data includes data such as first name, last name, username or similar identifier, title.
- Contact Data includes data such as billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes data such as internet protocol (IP) address, your login data, cookie identifiers, 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 our websites.
- Profile Data includes data such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our websites, products and services.
- Marketing and Communications Data includes data such as your preferences in receiving marketing from us and our third parties and your communication preferences.
We also process your personal data in order to create Aggregated Data sets for business purposes. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us data by filling in forms or by corresponding with us by post, phone, email or otherwise. For example, this includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- apply for a credit account;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion, or survey; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect data about your equipment, browsing actions and patterns. We collect such data by using cookies, server logs and other similar technologies. Please see the “Digital analytics” section below and our cookie policy for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources. For example, we may receive:
- Technical Data from analytics providers such as Google based outside the EU;
- Identity and Contact Data from publicly availably sources such as government entities like Companies House in the UK; and
- Contact Data from software publishers.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of the ways we plan to use your personal data, and the legal bases we rely on to do so when legally required. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the contact information in this Privacy Notice if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of Data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer and to pass on your information to our vendors for issuing licenses and delivering products (if delivered directly to you) | a. Identity b. Contact c. Transaction d. Profile e. Usage | a. Performance of a contract with you b. Necessary for our legitimate interests (in providing the helpdesk services) |
| To process and deliver your order including: a. Manage payments, fees and charges b. Collect and recover money owed to us | a. Identity b. Contact c. Financial d. Transaction | a. Performance of a contract with you b. Necessary for our legitimate interests (to recover debts due to us) where not covered under (a) |
| To manage our relationship with you which will include: a. Notifying you about changes to our terms or privacy notice b. Asking you to leave a review or take a survey | a. Identity b. Contact c. Profile d. Marketing and Communications | a. Performance of a contract with you b. Necessary to comply with a legal obligation c. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw or competition | a. Identity b. Contact c. Profile d. Usage e. Marketing and Communications | a. Performance of a contract with you b. Necessary to comply with a legal obligation c. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) e. Consent |
| To administer and protect our business and our websites (including complying with our legal obligations, maintaining the security of our websites, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | a. Identity b. Contact c. Technical d. Profile e. Marketing and Communications f. Usage g. Financial h. Transaction | a. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) b. Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | a. Identity b. Contact c. Profile d. Usage e. Marketing and Communications f. Transaction | a. Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) b. Consent |
| To use data analytics to improve our websites, products/services, marketing, customer relationships and experiences | a. Technical b. Usage | a. Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) b. Consent |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | a. Identity b. Contact c. Technical d. Usage e. Profile | a. Necessary for our legitimate interests (to develop our products/services and grow our business) b. Consent |
| For any other purpose, with your consent | a. Identity b. Contact c. Financial d. Transaction e. Technical f. Profile g. Usage h. Marketing and Communications | a. Consent |
Marketing
We will only contact you with marketing messages about our services or third party services if you have opted in to receive such messages or where we are otherwise permitted by law to send you such communications. If you would like to opt out of receiving marketing communications, please use the opt-out links on any marketing message sent to you or opt out by contacting us at any time using the email address in the “Our contact details” section of this Privacy Notice.
Disclosures of your personal data
We may share personal data with other parties, including those set out below for the purposes set out in the above table:
- Service providers, including specific third parties who provide data processing services to us (for example, software, IT, and system administration services), or who otherwise process personal data on our behalf.
- Business partners, including manufacturers and software publishers who provide us with products needed to fulfill your order.
- Corporate affiliates, for example where they provide IT and system administration services or undertake leadership reporting.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
- Third parties to whom we may choose to sell, transfer, or merge parts or all of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
- Any other person or entity with your consent to the disclosure.
We require all third parties receiving personal data from us to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Digital analytics
We may work with third parties that collect data about your use of our websites and other sites or apps over time for non-advertising purposes. Climb uses Google Analytics and other third-party services to improve the performance of the websites and for other analytics purposes. For more information about how Google Analytics collects and uses data when you use our websites, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.
Additionally, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
Data security
We have put in place security measures to protect the personal data we collect from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. For instance, we take steps to limit access to your personal data by our employees, agents, contractors and other third parties.
We also have put in place procedures to deal with suspected breaches of personal data and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize or deidentify your personal data (so that it can no longer be associated with a specific individual) or create Aggregated Data for research or statistical purposes in which case we may use this information indefinitely without further notice to you. When we deidentify data, we maintain and use such data only in deidentified form—we do not attempt to reidentify this data except as needed to determine that the data is appropriately deidentified.
International visitors
This section applies to those that use our Sites from the European Economic Area (EEA), Switzerland, or the United Kingdom (UK).
What rights are available to me?
Under certain circumstances, you have rights under applicable data protection laws in relation to your personal data. Subject to certain exceptions and limitations, you have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request that your personal data is ported to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us as described in the “Our contact details” section of this Privacy Notice. You have the right to make a complaint at any time to the competent supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority so please contact us in the first instance.
Is personal data transferred?
Some of the parties with whom we may share your personal data are based outside the EEA, UK, or Switzerland so their processing of your personal data will involve a transfer of data outside these jurisdictions.
Whenever we transfer your personal data out of the EEA, UK, or Switzerland, we ensure a similar degree of protection is afforded to it by ensuring that an appropriate safeguard is implemented.
For example, where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EEA. For further details, see European Commission: EU Standard Contractual Clauses – see link.
Please contact us as described in the “Our contact details” section of this Privacy Notice if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA, UK, or Switzerland.
California visitors
The California Consumer Privacy Act (CCPA) provides rights to California residents regarding “personal information” that is subject to the CCPA. If you are a California resident who is a Climb customer, a visitor to our websites, or another business contact of Climb, this section contains disclosures required by the CCPA and provides information about rights you may have under the CCPA.
Personal information we collect and disclose
In the past 12 months, we collected and disclosed the categories of personal information listed below:
- Personal and online identifiers (such as first and last name, email address, or unique online identifiers);
- Recordkeeping information (such as financial information for payment purposes);
- Commercial or transactions information (such as records of products or services obtained or considered);
- Internet or other electronic network activity information (such as interactions with Climb’s websites and emails);
- Audiovisual information (such as video or call recordings);
- Professional or employment-related information;
- Sensitive personal information (such as certain billing information or account log-in information for your account);
- Inferences drawn from the above information about your predicted characteristics and preferences; and
- Other information about you that is linked to the personal information above.
Categories of sources
We collect this personal information from the following categories of sources:
- You, when you provide it to us directly or by using our websites or services;
- Others at your organization, in connection with the business relationship between Climb and your organization;
- Service providers;
- Affiliates not under the Climb brand;
- Commercial data resellers; and
- Event organizers of events you register to attend.
Why we collect, use, and disclose personal information
We collect, use, and disclose personal information for our business and commercial purposes described in the “Purposes for which we will use your personal data” section of this Privacy Notice.
Recipients of personal information
We may disclose each category of personal information we collect to the categories of third parties described in the “Disclosures of your personal data” section of this Privacy Notice. We do not sell the personal information we collect and we do not share the personal information we collect for cross-context behavioral advertising.
Recipients of personal information
California residents have certain rights with respect to the personal information collected by businesses like Climb. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:
- The right to know the categories and specific pieces of personal information we collect, use, and disclose about you, the categories of sources from which we collected your personal information, our purposes for collecting or sharing your personal information, the categories of your personal information that we have either shared or disclosed for a business purpose, and the categories of third parties to which we have disclosed personal information.
- The right to request that we delete the personal information we have collected from you.
- The right to request that we correct inaccurate personal information we maintain about you.
- The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
While the CCPA provides an opt-out opportunity for certain uses or disclosures of “sensitive personal information” (as defined under the CCPA), Climb uses and discloses such information only for purposes permitted by the CCPA that do not require an opt-out opportunity.
If you wish to exercise any of the rights set out above, please email us at compliance@climbcs.com or call us at 800-847-7078 and submit the required verifying information, as further described below.
Verification process and required information
We may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, your name, business email address, and business phone number. We will verify your request by comparing the information provided in your request with the information we maintain about you.
Authorized agent
You may designate an authorized agent to make a CCPA request on your behalf by submitting a written, signed permission to compliance@climbcs.com.
Our contact details
Contact details
- Full name of legal entity: Climb Global Solutions, Inc.
- Email address: Compliance@climbcs.com
- Postal address: 4 Industrial Way West, Suite 300, Eatontown, NJ 07724
- Telephone number: 732-389-0932
March 12, 2024