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Privacy Policy

Privacy Policy

Welcome! This privacy policy (“Privacy Policy“) governs the websites https://www.climbcredit.com and https://app.climbtalent.com/ (including both mobile and desktop versions of our sites) (the “Site”), including your use of interactive devices, features, widgets, plug-ins, applications, content, downloads and/or other online services that we own and control and that post a link to this Privacy Policy (the Site and other online services we offer are collectively referred to herein as the “Service”), which are made available by Climb Investco, LLC and Climb Credit, Inc. (collectively, “Climb“, “we” “our” or “us“). This Privacy Policy does not apply to: (i) any data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy; or (ii) the data practices of third parties that may interact with our Service.

To the extent we provide you notice of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.

In addition, please review the Service’s ‍Terms of Use, which governs your use of the Service.

By using our Service, you consent to our Privacy Policy and Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below.

If you do not agree to the terms of this Privacy Policy, please do not provide us with any Personal Information and do not use this Service.

Table of Contents

It is important that you read and understand the entire Privacy Policy before using the Service. To ease review, each section below contains a brief introductory summary and a link to the full explanation. Click on the headings and the “More” buttons to be taken to the full explanation. Any capitalized terms that appear in but are not otherwise defined in the introduction have the meanings given to them elsewhere in the Privacy Policy.

  1. What information does the service collect?
    We collect and receive certain information about you as you interact with our Service, explained further in this Section.
    • Information you provide to us
      You provide most of the information we collect about you. We may collect certain Personal Information, Payment Information, and Demographic Information (defined below) that you provide to us when you interact with the Service. For example, we may collect this information through various forms and in various places on the Service, including when you apply for financing, request information about the Service, use or view our website through the use of cookies, you sign-up to receive emails from us or complete a survey. More
    • Information collected and stored as you access and use the service
      Certain information may be collected from you automatically when you access and use the Service, including any text you submit. For example, we and third parties may use Tracking Technologies (defined below) to collect Usage Information (defined below) based on your Device Identifier (defined below) for a variety of purposes, which may include activities over time and across third party locations. More
    • Information third parties provide about you
      We may obtain information about you from third parties. More
    • Information you provide about a third party
      You may provide us information about others, such as when you add an individual to your account. If so, the information you provide (names, email addresses, etc.) may be used by us so you can obtain the benefits of the Service. More
    • Interactions with third party services
      If you interact with third-party services, those services may send us information about you and you or we may send them information about you. More
    • “Do Not Track” Policy
      We do not look for or respond to “do not track” signals. More
  2. How do we use the information collected?
    We use your Personal Information, Demographic Information and Usage Information for a variety of purposes detailed in this Section. More
  3. How and when do we share information with third parties?
    We may provide your information to third parties under various circumstances detailed in this Section. These may include:
    • When you request information from or provide information to third parties
      If you request information from third parties, request that we send information to third parties or interact with third-party websites, ads, content or tools, we may share your information with such parties and/or they may collect your information directly. More
    • Third parties providing services on our behalf; Schools; and other third parties
      Our vendors may collect your information on our behalf or we may share it with them so that they may provide services to us and you. Other third parties with which we may share your information (including Personal Information), include those parties we have contractual relationships with such as credit bureaus, the School you have chosen to attend, and/or, the Online Program Manager (OPM) that provides course instruction or access to the school you have chosen to attend (collectively “School”); mentors or mentees, partners, and/or employers or prospective employers you interact with or apply to work with or at on ClimbTalent (“Employer”), ACH bank processors, auditors, banks, payment processors and payment facilitators, loan servicers, and collection agencies. It may also include infrastructure providers and analytics platforms. Some may offer you choices regarding the collection and use of your information. More
    • To protect the rights of Climb and others
      There are a variety of administrative and legal reasons for which we may share some or all of your information, including sharing in order to complete our obligations to each other. More
    • Affiliates and business transfer
      We may share your information with our affiliates as well as in the event of a sale, merger or similar transaction. More
    • Your privacy rights
      1. We make good faith efforts to protect the security of Social Security numbers.
      2. You may have the following rights, under certain conditions and as applicable under local law:
        1. The right to access your Personal Information
        2. The right to correct your Personal Information
        3. The right to erase your Personal Information
        4. The right to restrict processing of your Personal Information
        5. The right to portability
    • If you make a request, we will respond to you in a timely manner. Please reach out via email to hello@climbcredit.com, and include your state or country of residency. More
    • SMS messages will only be sent from Climb
      At any time, you may opt out of receiving SMS messages using any of the methods described in the Mobile Short Code Terms of Service in our Terms of Use.
  4. What is our legal basis for processing the information you provide?
    We rely upon a number of different legal bases for processing Personal Information, including processing personal information where it is in our legitimate interest to do so, where it is necessary for the fulfilment of a contract, or where the processing is necessary to carry out our obligations under law. Where we rely on our legitimate interests, we use Personal Information to run our business and to provide the Service you have asked us to provide. You do not have to provide us with personal information; however, if you do not provide us with information we need by law or as required to conduct the Service, we may not be able to offer certain products and services to you. More
  5. Ads and information about you
    We and third parties may send you targeted ads based on your location, information and/or behavior. If you object, you can exercise choices some third parties may offer. More
  6. Does third-party content, or links to third-party sites and/or third-party apps, appear on the service?
    We may allow you to access third-party content on the Service, or to link to third-party applications and locations from the Service, but we are not responsible for your interaction with third-party content, apps and locations. More
  7. How do I change my information and communications preferences?
    You may change certain account information and communications preferences as more fully detailed in this Section. More
  8. What about the transfer of information to the United States?
    You consent to your data being transferred to the United States. More
  9. What should parents know about children?
    We do not intend to collect Personal Information from children. If you think we have, let us know. More
  10. What about security?
    No data security is absolute, but we endeavor to take reasonable steps to secure data appropriately. More
  11. What about changes to the privacy policy?
    We may change this Privacy Policy upon posting of a revised privacy policy. However, we will continue to treat your Personal Information under the terms of the privacy policy in effect when it was collected unless you otherwise consent. More

The Full Detailed Privacy Policy

  1. What information does the service collect?
    • Information you provide to us
      On the Service, we may ask you to provide us with certain categories of information, such as: (i) personally identifiable information, which is information that identifies you personally, such as your first and last name, phone number (including mobile phone number), date of birth, home address, email address, social security number, employment and education history, and financial related information, such as bank account(s), financial institution information, information about your assets, credit card numbers and other data related to your credit history and suitability for us to enter into a financing transaction or business relationship with you (collectively, “Personal Information“); (ii) payment information, including your credit or debit card details, bank account information, and payment or other information required to make a purchase (“Payment Information“); and (iii) demographic information, such as information about your gender, education and post-graduation employment information (“Demographic Information“). We may collect this Personal Information, Payment Information, and Demographic Information through various forms and in various places on the Service, including if you apply for financing, including filling out an application form, through “contact us” forms, if you sign-up to receive emails, complete a survey or when you otherwise interact with the Service, including, without limitation, when you use our online student portal, or if you are an employee of a partner or prospective partner School and/or Employer. If we combine Demographic Information with the Personal Information we collect directly from you on the Service, we will treat the combined data as Personal Information under this Privacy Policy, or as otherwise required by applicable law.
    • Information collected and stored as you access and use the service
      In addition to any Personal Information or other information that you choose to submit to us via our Service, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Service (“Usage Information“). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device“) whenever you visit or interact with our Service. To the extent we associate Usage Information with your Personal Information we collect directly from you on the Service, we will treat it as Personal Information.

      This Usage Information may include:
      • your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Service, and our computers identify your Device by its Device Identifier;
      • your Device functionality (including browser, operating system, hardware, mobile network information);
      • The details of your visits and the areas within our Service that you visit and your activities there, including remembering you and your preferences;
      • your Device location;
      • your Device characteristics; and
      • certain other Device data, including the time of day, mouse movements, clicks, page visits, text entered, how long you spent on a page, and other details of your actions, among other information.
    • We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies“). Tracking Technologies may have access to store and/or process data on your Device. A few of the Tracking Technologies used on the Service, include, without limitation, the following (and subsequent technology and methods later developed):

      Cookies. A cookie is a data file placed on a Device when it is used to visit the Service. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage. Unlike Flash cookies, HTML5 cookies do not require a plug-in. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies, go to Adobe’s website www.adobe.com. Please be aware that if you disable or remove cookies, Flash cookies, or HTML5 cookies on your Device, some parts of our Service may not function properly, and that when you revisit our Service your ability to limit cookies is subject to your browser settings and limitations.

      Web Beacons/Tracking Pixels. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our Service’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Service, to monitor how users navigate the Service, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.

      Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. Depending on browser settings and other criteria outside our control, the code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.

      Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other system and application configuration data, for purposes of identification.

      ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.

      Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

      We may use Tracking Technologies for a variety of purposes, including:

      Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Service, including cookies required to prevent fraudulent activity, improve security or allow you to make use of Service functionality.

      Performance Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Service, including as part of our analytic practices or otherwise to improve the content, ads, products or services offered through the Service.

      Functionality Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Service, including identifying you when you use our Service or keeping track of your specified preferences.

      Targeting Related. We may use Tracking Technologies to deliver content, including ads relevant to your interests on our Service and third-party services based on how you interact with our advertisements and/or content. This includes using Tracking Technologies to understand the usefulness to you of the content and ads that have been delivered to you.

      There may be other Tracking Technologies now and later devised and used by us in connection with the Service. Further, third parties may use Tracking Technologies in connection with our Service, which may include the collection of information about your online activities over time and across third-party websites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially interacting with third-party Tracking Technologies in connection with use of our Service and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties.
    • Information third parties provide about you
      We may receive information about you from third parties and other users of the Service, such as from credit bureaus, credit reporting service providers, loan servicers, Schools, and identity verification services. Additionally, we may, from time to time, supplement the information we collect directly from you on our Service with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with Personal Information we collect on the Service, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties, even if they have used our technology to collect it and share it with us.
    • Information you provide about a third party
      You may provide us with information of others if you authorize someone else to access your account on your behalf such as if you set up a joint account with another person or provide information about a co-applicant or co-borrower. Additionally, Schools and other designated individuals or entities may provide information about employees, administrators or individuals otherwise authorized to interact with us on behalf of a School partner. Further, Employers or other designated individuals or entities may provide information about individuals authorized to interact with us on behalf of an Employer partner. Any Personal Information you provide about another person will be treated in accordance with the terms of this Privacy Policy, and as required by applicable law.
    • Interactions with third parties
      The Service may include functionality that allows certain kinds of interactions between the Service and a third-party web site or application. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, when you register with the Service, you may have an option to use your Facebook, Twitter, Google or other account provided by a third-party site or application to facilitate the registration and log-in or transaction process on the Service, or otherwise link accounts. If we offer and you choose to use this functionality to access or use our Service, the third-party site or application may send Personal Information about you to us. Further, if you click on social media icons on the Service (such as for Facebook, Twitter or Instagram), those actions may be associated with, and we may have access to, your Personal Information you provided on those third-party sites or applications. If so, we will then treat it as Personal Information under this Privacy Policy, since we are collecting it as a result of your accessing of and interaction on our Service. In addition, we may provide third-party sites’ interfaces or links on the Service to facilitate your sending a communication from the Service. For example, we may use third parties to facilitate emails, tweets or Facebook postings. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. Climb may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Service.
    • “Do Not Track” Policy
      Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.
  1. How do we use the information collected?
    We may use your Personal Information, Demographic Information or Usage Information that is subject to this Privacy Policy:
    • to determine your eligibility (e.g., creditworthiness) to enter into a financing transaction with you;
    • to provide you with information such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties, including to let you know about new products, services or upcoming events;
    • to verify your identity, including your accounts on the Service;
    • manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
    • manage and protect our information technology infrastructure;
    • to provide the Service, including the opportunities available on the Service;
    • to improve the Service, marketing endeavors or our Service offerings;
    • to customize your experience on the Service or to serve you specific content or ads that are relevant to you, including using your location information to display advertisements for businesses in your close vicinity;
    • to provide customer support, including to resolve disputes, repossess items for accounts in default, collect fees and account balances, and troubleshoot problems;
    • to contact you with regard to your use of the Service and, in our discretion, changes to the Service and/or Service’s policies;
    • to identify your product and Service preferences so that you can be informed of new or additional products, services and promotions;
    • to enable you to participate in a variety of the Service’s features;
    • to improve the overall experience at the Service;
    • to comply with our legal, statutory and regulatory obligations;
    • to determine outcomes from your use of the Service;
    • for internal business purposes; and
    • for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.
  1. How and when do we share information with third parties?
    We may share non-Personal Information, such as aggregated user statistics, with third parties. Further, we may share your Device Identifiers with third parties along with data related to you and your activities. We may share information with a third-party to analyze and organize any collected data on our behalf and at our express direction. Further, we share your Personal Information with (and to) third parties, with whom we have marketing or other relationships for the third parties’ direct marketing purposes only as more specifically explained in our ‍GLBA Privacy Notice. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. Climb may additionally disclose your information as follows:
    • When you request information from or provide information to third parties
      You may be presented with an option on our Service to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools, apps or ads on our Service or link to them from our Service. This may include using third-party tools such as Facebook, Twitter, Pinterest or other third-party posting or content sharing tools and by so interacting you consent to such third party practices. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.
    • Third parties providing services on our behalf; Schools; and other third parties
      We may use third-party vendors to perform certain services on behalf of us or the Service, such as: (i) to assist us in Service operations; (ii) to manage a database of customer information; (iii) hosting the Service; (iv) designing and/or operating the Service’s features; (v) tracking the Service’s activities and analytics; (vi) enabling us to send you special offers or perform other administrative services; (vii) payment processing or loan service providers so they can process the transactions initiated from your Service account; (viii) to assist us with collecting on delinquent accounts; and (ix) other services designed to assist us in maximizing our business potential. Additionally, we may share your information (including Personal Information) with parties with which we have contractual relationships, such as credit bureaus, the School you have chosen to attend, ACH bank processors, auditors, Employers, banks and collection agencies. We may provide service providers and these other third parties with direct access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us among other reasons. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available in Section 4 below. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.
    • To protect the rights of Climb and others
      We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Service’s Terms of Use or other policies applicable to the Service, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Service or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.
    • Affiliates and business transfer
      We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Service or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
    • Your Connecticut privacy rights
      Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.
    • Short code SMS messages
      Short Code SMS messages will only be sent from Climb in the following circumstances and if you opt-in:
      • To provide notifications and reminders regarding your Climb financing application
      • To provide you notifications and reminders regarding upcoming payments
      • To provide you notifications and reminders regarding past due payments
      • To periodically solicit feedback and facilitate surveying efforts
      • To provide other timely account related notifications or alerts
      • At any time you may opt out of receiving SMS messages using any of the methods described in the Mobile Short Code Terms of Service in our Terms of Use. If you opt-out of these messages, we will still communicate with you about your account via email, as appropriate.
    • Non-short code SMS messages
      Non-Short Code SMS messages may be sent for purposes, including surveying, offering career support and resources, etc. These will be sent less than ten times per year and you can opt out at any time by replying STOP to any message you have received. Carrier costs and fees may apply. You do not have to allow us to contact you by text in order to receive financing from Climb. If you opt-out of these messages, we will still communicate with you about your account via email, as appropriate.
  1. Ads and information about you
    Data about your activities online is being collected on our Service for use in providing advertising tailored to your individual interests. We may use third parties such as network advertisers and ad exchanges to serve advertisements across the Internet and may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third party websites and viewing of ads and of our content. Third parties may offer you a choice as to whether or not to have your information collected for that purpose. This section of the Privacy Policy provides details and explains how to exercise that choice.

    You may see certain ads on our Service as well as on other third-party websites across the Internet because we participate in advertising networks administered by third parties. These networks track your online activities over time and across third party websites by collecting information through automated means, including through the use of the Tracking Technologies described elsewhere in this Privacy Policy, and they use this information to show you advertisements (including our ads) that are tailored to your individual interests. The information they collect includes information about your visits to our Service, such as the pages you have viewed. These third-party tracking technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your device and may set or change settings on your device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may act as web beacons, which enable third parties to carry out the previously described activities.

    This collection and ad targeting takes place both on our Service and on third-party websites that participate in the ad network, such as websites that feature advertisements delivered by the ad network. This process also helps us track the effectiveness of our marketing efforts. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as a DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Site. To learn more about how to opt out of Google’s use of the Google analytics cookies, visit here. To learn more about how to opt out of DoubleClick’s use of cookies, visit the DoubleClick opt-out page here.

    Third-party tracking technologies are not controlled by us, even if they use our technology to help store or collect data. Statements regarding our practices do not apply to the methods for collecting information used by these third-party advertisers and others or the use of the information that such third parties collect. We do however work with third parties to make efforts to provide you with information on their practices and any available opportunity to exercise choice. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties. Further, while we may use a variety of companies to serve advertisements on the website, you may wish to visit http://www.networkadvertising.org/choices, which provides information regarding this practice by Network Advertising Initiative (“NAI“) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver targeted content and/or ads to you, which will affect this and other sites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different device or change web browsers, your NAI opt-out may not, or may no longer, be effective. Additional information is available on the NAI’s website accessible by the above link. You may also be able to opt-out of receiving third-party behavioral ads by visiting the Digital Advertising Alliance (“DAA“) website at http://www.aboutads.info/choices/. Similar limitations may apply to the DAA opt-out. We are not responsible for effectiveness of or compliance with any third-parties’ opt-out options.

  1. Does third-party content, or links to third-party sites and/or third-party apps, appear on the service?
    When you are on the Service you may be directed to other sites and apps that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites or apps and they may be tracking you across multiple online services and may be sharing the results of that tracking with us and/or others. These third parties may have their own terms of service, privacy policies or other policies and ask you to agree to the same. For example, if you click on a link, the “click” may take you off the Service onto a different location. These other online services may associate their Tracking Technologies with you, independently collect information about you, including Personal Information, and may or may not have their own published privacy policies. We are not responsible for these third-party privacy policies or the practices of third-parties. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications. We also encourage you to note when you leave our Service and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.
  1. How do I change my information and communications preferences?
    You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. The Service may allow you to review, correct or update Personal Information you have provided through the Service’s student portal or otherwise by updating your student portal account, and you may provide registration updates and changes by contacting us by email at: hello@climbcredit.com. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the Service, information that you remove may persist internally for Climb’s administrative purposes. You must follow best practices and take reasonable steps to help secure your account and notify us if you learn of any unauthorized access to or use of your account.

    You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our Service, such as administrative and Service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. At any time you may opt out of receiving SMS messages using any of the methods described in the Climb Short Code Terms of Service in our Terms and Conditions.

    If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways:
    • Postal Mail: Climb Credit, 6543 S Las Vegas Blvd, Suite 02B137 Las Vegas, NV 89119 (Attn: Privacy Officer); or
    • Email: hello@climbredit.com
  1. What about transfer of information to the United States?
    Our Service is operated in the United States and intended for users located in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States, according to laws of the United States. By using the Service or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.
  1. What should parents know about children?
    We understand the importance of protecting children’s privacy in the interactive world. We are a general audience service and do not use the Service to knowingly collect personal information from children under the age of thirteen (13) that requires parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA“) without such parental consent. If you are a child under thirteen (13) years of age, you are not permitted to use the Service and should not send any information about yourself to us through the Service.
    In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with personal information without COPPA-required consent, please contact us at hello@climbcredit.com.
  1. What about security?
    We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, service provider, or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Service and provide us with your information at your own risk.
  1. What about changes to the privacy policy?
    We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
  1. How do I raise a concern or complaint?
    Climb takes your privacy seriously, and maintains a process to respond to your concerns regarding violations of this Policy. If you believe that we haven’t complied with this policy in regards to your Personal Information or have questions regarding your privacy with us, please contact us at helloprivacy@climbcredit.com. If you are reporting non-compliance with this Privacy Policy, please describe the issue in as much detail as possible without disclosing any sensitive information about you or third parties. Please ensure that you identify your state and/or country of residence so that we may appropriately resolve your concern. We will respond to your request by email as soon as possible.

    If you are unhappy with how we resolve your complaint, you may be able to escalate your concern to a governing authority, as applicable. We would appreciate the opportunity to first resolve your complaint before you escalate the issue to such authority.

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