Climb is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website or our services, then you can be assured that it will only be used in accordance with this privacy statement.
In line with GDPR, this policy is effective from 21/05/2018, and we will update you with any changes to future updates to our Privacy Notice.
We understand the importance of GDPR and our role as a custodian of the data you have provided to us either as an interested person or as a user of the Climb platform (thank you for that).
Here is a simple summary of the content of this policy, it separates into two parts.
- We will only collect your data if you want us to, that includes providing us your details as part of a business discussion.
- We act as a data controller for data we collect.
- We don’t do everything ourselves, we use other sub-processors such as AWS, Fasthosts, Stripe, Google Analytics, Office 365, ClearBooks, Cloudflare and Teamwork as part of our data processing.
- As part of the move to GDPR compliance we have used legitimate interests as a legal method of consent to continue to process the data of our users, and people that have previously signed up, or have provided their details as part of ongoing business discussions.
- As has always been the case, when it comes to removing yourself from Climb communications, you can unsubscribe at anytime, and if you aren’t a Climb user, not only will we remove you from future marketing, we will remove your information from Climb.
- We do collect cookies, but we don’t really do anything with them. It’s really just aggregated reporting within Google Analytics. If that changes, so will this bullet point.
- If you wish us to remove your data, or wish to request a subject access request, please let us know by contacting us at firstname.lastname@example.org
- We act as a data processor for our customers, they are the data controller. That means they control the system, and they collect and provide the data for the platform that Climb develops to operate.
- Therefore, any data requests related to the activity of our customers, needs to be directed to them rather than ourselves. We will only be part of the various business system they operate as part of their business.
- We don’t do everything ourselves, and unless otherwise agreed we use other sub-processors such as AWS, Fasthosts, Stripe, Google Analytics, Office 365, ClearBooks, Cloudflare and Teamwork as part of our operations and data processing.
The Legal Bit
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your sensitive information and how we will deal with it. For the purposes of the Data Protection Act (‘the DPA’) and the EU General Data Protection Regulation (‘the GDPR’), sensitive information includes what is defined as your ‘personal data’.
By visiting climbcreative.co.uk or by using Atlas® you accept and consent to the practices described in this Privacy Notice including the processing of your personal data under this lawful basis.
In this Privacy Notice, we seek to abide by the letter and spirit of the guidelines laid out by the UK Information Commissioner’s Office in the document ‘Privacy Notices, Transparency and Control’.
Who We Are
More formally, we are Climb Creative Limited. We are a company registered in England and Wales with Company number 7523310 and our registered office is at Studio 209, Northern Design Centre, Gateshead, NE8 3DF.
We are registered with the Information Commissioners Office under registration number ZA285304 and you can view more details of our registration online here.
For the purposes of the DPA and in-line with the GDPR, Climb Creative Limited is the Data Controller. If you register to use our commercial services then we will also as a Data Processor on your behalf. You should list Climb within your Privacy Notice as a Data Processor and refer your customers to our Website should they require more information about our service.
If you have any concerns about the way we use your information or any questions about this Privacy Notice, please let us know. We can be contacted via email at email@example.com, or you can write to us at the address above.
What we do with your information
We will use your information to:
- Send our newsletter to you and to send you information about the services that we offer and other related topics;
- Send you updates about any changes or new features for Atlas® or news of any new services;
- Collect feedback about our services; and
- Send you information about the services we provide by other agreed means.
We compile statistics about user trends on our Website, which are used by third party organisations to understand how users interact with businesses, brands and one another online and to advise about these things. These statistics are drawn from a dataset which does not contain any information from which you can be identified.
- If you are an existing user of the Atlas® platform prior to the date of this notice than any communication will be delivered on the legal basis of Legitimate Interests.
- If we you have provided us with your contact details as part of initial or ongoing business discussions, we will continue to process your information on the legal basis of legitimate interests.
- If you have previously signed up to receive marketing information from us by signing up to the website, we will continue to process your information on the legal basis of legitimate interests.
Wherever, we used the legal basis of legitimate interests, we have carried out a Legitimate Interests Assessment to document this legal basis.
Information we collect from you
We will collect and process the following information about you:
Information you give us – this is information about you that you give us by filling in forms on our Website or by corresponding with us by phone, email or otherwise. We only request from you the minimum data required for you to use our service.
The information we require from you to sign up to our mailing list will include your first name and an email address.
Information we collect about you – Whenever you visit our Website we will automatically collect the following information:
technical information – including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
information about your visit – this includes the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), pages you have visited, page response times, download errors, length of visits to certain page and page interaction information (such as scrolling, clicks, and mouse-overs).
Information we receive from other sources – This is information we receive about you if you use any of the other websites we operate or the other services we provide.
In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this Website. We will also have told you for what purpose we will share and combine your data.
We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).
We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
Where we hold and what we do with your information
The information and content held on our Website is deployed geographically to maximise user experience. All information that could identify individuals within the European Union is stored exclusively within the European Union. We will never share your user information with third parties for promotional purposes.
We hold our data with who are contracted by us for the provision of technical services. We remain responsible at all times for the security of your information, but if you want to know more about how we interact with Fasthosts you can view their Privacy Notice, amongst their other policies here.
We also use AWS, Stripe, Google Analytics, Office 365, ClearBooks to process data and help provide our services.
We store some client data electronically using One Drive for Business. If you want to learn more about One Drives’s service and how they handle your data you can visit their website here.
We may also disclose your information to third parties to whom we may choose to sell, transfer, or merge parts 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.
What we do to ensure the security of your personal information
We take the security of your personal data very seriously. Our approach to information security is constantly evolving and continually reviewed.
We have adopted industry best practices from both technological and business process perspectives in order to make the security of your data a key part of the way we do business.
We have policies and practices in place that not only ensure our compliance under the DPA but also the GDPR, including training and adequate procedures put in place for any staff that handle or have access to sensitive information.
Your rights regarding your personal information
We may contact you via email with updates about the services that we offer or any changes that we have made to our Website.
You can opt in or out at any time by clicking the ‘Unsubscribe’ link in our emails.
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which our service may be advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we are not responsible or liable for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
You have the right to find out about what information we hold about you. You can exercise that right by contacting us and we will send you any request for information in a suitable electronic form within 20 working days.
To make a request for information please contact firstname.lastname@example.org and a member of our team will be in touch.
If your personal data is incorrect then you have the right to rectify this information and ensure that it is accurate and up to date. If your data is incorrect then please contact us at the email address above and a member of the team will rectify this on your behalf.
You have the right ‘to be forgotten’ and to have your personal identifiable information permanently deleted from our systems. Again, if you would like to exercise this right then please contact us at email@example.com.
There will be no charge made for reasonable electronic access to your information, your right to rectification or for your right to be forgotten from our systems.
How long we hold your information for
At Climb we have procedures in place to regularly review every 12 months what personal data we hold. If you have not interacted with us or accessed our services during this or the subsequent period then we will delete your personal data from our systems, but will send you an email first informing you of our intention to do so.
Of course, you have the right to forgotten at any point and can find out more about this in the ‘Access to Information’ section above.
Changes to this Privacy Notice
Any changes we may make to our Privacy Notice in the future will be posted on this page. Should you register for an account with Climb then any changes will be notified to you when you next log in to make use of our services.
The new terms may be displayed on-screen and you will be required to read and accept them to continue your use of our services.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
As part of our overall approach to privacy and transparency, this section describes what cookies are in the context of our web and mobile interfaces, and what their use means to you. At the end, we’ve included some links to help you research cookies and their impact, and how you can use your web browser to control the way it manages cookies.
We use the following types of cookies:
- Strictly necessary cookies –these are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-payment system.
- Analytical/performance cookies – these allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies –these are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies –these cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose but these cookies will contain no information capable of identifying you personally to us.
You can find more information about the individual cookies we use and the purposes for which we use below:
We use Google Analytics to understand general trends about our content and traffic sources; for example, where users come from, which pages are most popular, which sites provide most traffic, how our marketing efforts impact the amount of visits we receive.
Google’s statement about privacy can be found here.
The Twitter button allows our users to share details of Climb with their followers more easily.
We use Facebook button to allow you to share details of Climb with your friends and other Facebook users.
We use a LinkedIn button to allow you to share our platform and the services we offer with your connections. LinkedIn’s information about privacy can be found here.
More information about cookies
Still don’t know what cookies are? Then why not follow the link conveniently located here which provides more information about what they are and how they work.
Contact the Information Commissioner if there is a problem
If you consider we have not addressed your problem, you can contact the UK Information Commissioner’s Office for assistance. Further information can be found here.