Effective Date: January 1, 2020
Climb Channel Solutions is committed to protecting your privacy while providing full transparency as to how we use your data. This Privacy Shield Notice sets out the privacy principles we follow with respect to transfers of personal data from the European Economic Area ("EEA") to the United States, including personal data we receive from individuals who visit our web and mobile sites, who access or use our product or service offerings ("Offerings"), or who otherwise interact with us.
We comply with the EU-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use and retention of personal data from the EU. Climb Channel Solutions, Inc. in the United States has certified to the US Department of Commerce that they adhere to the Privacy Shield Principles in respect of all personal data received from the EEA in reliance on the Shield.
The Federal Trade Commission has jurisdiction over our compliance with the Privacy Shield.
For more information about the Privacy Shield generally, and to view our certification online, please visit https://www.privacyshield.gov.
In case of conflict between the terms of this Privacy Shield Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
Types of personal data we collect and use
The types of personal data we may receive in the United States, as well as the purposes for which we collect and use it, are set out in our privacy & security statement and internal Employee Data Protection Policy and Climb Channel Solutions Notice of Employee Personal Data Processing.
We only process personal data in ways that are compatible with the purposes we collected it for, or for purposes you later authorize. Before we use your personal data for a materially different purpose, we will provide you with the opportunity to opt-out.
Transfers to third parties
Information about the types of third parties to which we disclose personal data and the purposes for which we do so is described in our privacy & security statement respectively.
If we have received your personal data in the United States and subsequently transfer that information to a third party acting as an agent, and such third party processes your personal data in a manner inconsistent with the Privacy Shield Principles, we will remain responsible unless we can prove we are not responsible for the event giving rise to the damage.
Disclosures for national security or law enforcement
Please note that under certain circumstances, we may be required to disclose your personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Access, correction and deletion rights
You have the right to access personal data that we hold about you and request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of a third party. If you would like to request access to, correction, amendment, or deletion of your personal data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity.
We commit to giving you an opportunity to opt out if personal data we control about you is to be disclosed to another independent third party, or is to be used for a purpose that is materially different from those set out in our privacy statements. Where sensitive personal data is involved, we will obtain your express opt-in consent to do such things. If you otherwise wish to limit the use or disclosure of your personal data, please write to us at the contact details set out below.
You can also ask us to remove you from any mailing list to which you previously subscribed by sending us an email or by following the "unsubscribe" link in any marketing communications we send to you.
Questions or complaints
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal data. EEA individuals with inquiries or complaints regarding our Privacy Shield practices should first contact us at compliance@ClimbCS.com or in writing to:
Climb Channel Solutions, Inc.
4 Industrial Way West, 3rd Floor
Eatontown, NJ 07724
We will investigate and attempt to resolve any Shield-related complaints or disputes within fourteen (15) working days of receipt.
If you have an unresolved Privacy Shield complaint that we have not addressed satisfactorily (for non-HR personal data or HR personal data in the context of the employment relationship), we commit to cooperate with the panel established by the EU data protection authorities (DPAs), as applicable, and to comply with the advice given by them in respect of the complaint. Click here for a list of EU DPAs.
You may also have the option to select binding arbitration for the resolution of your complaint under certain circumstances. To find out more about the Privacy Shield's binding arbitration scheme please see https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Changes to this Notice
We reserve the right to amend this Notice from time to time consistent with the Privacy Shield's, requirements.