PRIVACY NOTICE FOR CREDIT CLIMB
Effective Date: August 23, 2022
Last Updated: August 23, 2022
Be sure to review this Notice carefully to
understand Credit Climb’s privacy practices.
This Privacy Notice (“Notice”) provides information about how Credit
Climb, a Delaware limited liability company (“Credit Climb,” “we,” or
“our”) collects, uses, protects, and shares personal information about you and
describes the rights you may have regarding your personal information. This
Notice applies to Credit Climb, its website, applications, products/subscriptions
(“Products”), features, and application program interfaces, when you
communicate or interact with us either directly or through the use of any of
our online systems and applications, (collectively, the “Online and Offline
Services”).
Use of our Online and Offline Services constitutes your agreement
to the terms of this Notice. If you do not agree with the terms of this Notice,
please do not use our Online or Offline Services.
I.
TYPES OF INFORMATION
1.
Collection
And Use of Your Personal Information
a.
We may collect the following “Personal Information”, including,
but not limited to:
i. Name (first,
last, and/or maiden name) (or that of a family member or child); home address,
billing address, or other physical address; an email address (so we may
communicate with you); a telephone number;
ii. Social security
number; or certain other information, such as date of birth, employment
information, and credit card account information;
iii. Device
identification information which we may associate with a mobile telephone
number you provide in order to access the Online Services;
iv. Information
collected passively via cookies and similar technology;
v. IP addresses,
device identifiers, and application identifiers;
vi. Account and
password information related to financial services;
vii. Debt, income and
financial information;
viii.
Driver’s license number and passport number;
ix. Utility and
income information;
x. Date of Birth;
xi. Marriage Status;
or
xii. Ethnicity.
b.
We may collect Personal Information from:
i. Consumers;
ii. Information
collected passively via cookies and similar technology;
iii. Advertising partners;
iv. Credit reporting
agency and its affiliates; or
v. External data
providers and vendors.
c.
We may collect Personal Information:
i. To verify your
identity;
ii. To enroll you in
the Products, finalize your application during the enrollment process and
create your Credit Climb Product subscription;
iii. To provide you
with Products and their features;
iv. To send emails
and other alerts;
v. To process
payment and complete transactions;
vi. To provide you
with quality customer service;
vii. For product
development, product research, and product improvement by Credit Climb or its
affiliates;
viii.
To prevent fraud on your account, or to identify fraudulent
activity towards Credit Climb;
ix. To enhance and
optimize your experience on our Online and Offline Services and improve our
Products, for example, to test new products, to determine if products that we
are contemplating may be desirable to our customers, for analytics, marketing
research, and business analysis;
x. To perform analytics,
improve user experience, improve our product offerings
xi. To maintain the
accuracy of your credit report and information;
xii. To participate in
our programs, subscribe to our emails or newsletter, or transact other business
with us;
xiii.
To display, optimize and provide you with personalized
advertisements;
xiv. To communicate
with you;
xv. For fulfillment
of your requests and purchases, transactional and other communications about
the Online Services, Offline Services and Products, promotional opportunities
and generally for Credit Climb’s and its affiliates’ internal business purposes
such as, for example, internal analyses and audits;
xvi. For product
development and research, and for any purpose subject to the limitations set
forth in this Notice and applicable law; or
xvii.
For data utilization from third parties, such as your
telecommunications provider, to help confirm your identity and prevent
fraudulent access. It is likely that you authorized your wireless operator to
disclose your mobile number, name, address, email, network status, customer
type, customer role, billing type, mobile device identifiers (IMSI and IMEI)
and other subscriber status and device details, if available, we may provide
this information to our third party service provider, solely to verify your
identity and prevent fraud for the duration of the business relationship. Credit
Climb limits the use of this information to prevent fraud and unauthorized
access or disclosures of your personal information.
2.
Collection of Commercial Information
a.
We may collect information regarding your purchase records of our
Products (“Commercial Information”).
b.
We may collect Commercial Information from:
i. Consumers
ii. Payment
Processor(s)
iii. Credit Climb
c.
We may collect Commercial Information:
i. For fulfillment
of your requests and purchases, transactional and other communications about
the Online Services, Offline Services and Products, promotional opportunities
and generally for Credit Climbs internal business purposes such as internal
analyses and audits; or
ii. To keep a record
of your transaction history.
3.
Internet Or Other Similar Network Activity
a.
We may collect the following “Internet Related Information,”
including, but not limited to:
i. Information about
your interactions with the website, for example, when you view or search
content, we receive and track that information; web session; log file
information; information such as the website(s) you visited, when you visited
the website, how long you stayed, your behavior while you were on our website
and from what device you accessed the website; device identification
information which we may associate with a mobile telephone number you provide
used to access the website; the IP address and information related to that IP
address, the internet service provider or proxy used, operating system
information, browser information (the pages you view, how long you stay on each
page, how often you come back and your behavior while you are on our websites);
and which advertisement, emails, SMS notifications or other push notifications
related to the website and/or Product, offer or online content you view,
access, or click on, including to get to the Online Services or while you are
on the websites;
ii. Information
collected from advertising partners; or
iii. Local storage objects
such as HTML5 and Flash to store content information and preferences.
b.
We may collect Internet Related Information from:
i. Individuals
(directly); or
ii. Cookies and
similar technology.
c.
We may collect Internet Related Information:
i. To continually
enhance and optimize the Products and the Online Services, based on up-to-date
user experience and available technology;
ii. To improve the
delivery and development of the Products;
iii. To customize our
web site and/or customer service experience;
iv. To develop new
Products;
v. To display,
optimize, and provide you with personalized advertisements;
vi. To measure
advertising effectiveness;
vii. To perform site
analysis;
viii.
For product development and research, and for any purpose subject
to the limitations set forth in this Notice and applicable law; or
ix. For data
utilization from third parties, such as your telecommunications provider, to
help confirm your identity and prevent fraudulent access. It is likely you
authorized your wireless operator to disclose your mobile number, name,
address, email, network status, customer type, customer role, billing type,
mobile device identifiers (IMSI and IMEI) and other subscriber status and
device details, if available, we may provide this information to our third
party service provider, solely to verify your identity and prevent fraud for
the duration of the business relationship. Credit Climb limits the use of
this information to prevent fraud and unauthorized access or disclosures of
your personal information.
4.
Geolocation Data
a.
We may collect “Geolocation Data,” derived from using various
technologies to determine your location including, but not limited to IP
address, Wi-Fi access points, and cell towers.
b.
We may collection Geolocation Data from:
i. Consumers;
ii. Cookies and
similar technology; or
iii. Telecommunications
providers.
c.
We may collect Geolocation Data for the following reasons:
i. Fraud prevention
ii. Target
advertisements
iii. For fulfillment
of your requests and purchases, transactional and other communications about
the Online and Offline Services and Products; promotional opportunities and
generally for Credit Climbs internal business purposes such as, for example,
internal analyses and audits
iv. For product
development and research, and for any purpose subject to the limitations set
forth in this Notice and applicable law
v. For data
utilization from third parties, such as your telecommunications provider, to
help confirm your identity and prevent fraudulent access. It is likely you
authorized your wireless operator to disclose your mobile number, name,
address, email, network status, customer type, customer role, billing type,
mobile device identifiers (IMSI and IMEI) and other subscriber status and
device details, if available, way may provide this information to our third
party service provider, solely to verify your identity and prevent fraud for
the duration of the business relationship. Credit Climb limits the use of
this information to prevent fraud and unauthorized access or disclosures of
your personal information.
5.
Sensory Data.
a.
We may collect audio and electronic recordings “Sensory Data”,
such as recordings from when you speak with customer service.
b.
We may collect Sensory Data from consumers.
c.
We may collect Sensory Data:
i. To provide
customer service and support consumers;
ii. To train agents
to ensure best customer service delivery;
iii. To ensure legal
and compliance obligations; or
iv. To help answer
questions and resolve disputes.
6.
Professional Or Employment
a.
We may collect employment information (“Employment Information”) from
consumers.
b.
We may collect Employment Information:
i. To enhance and
optimize your experience and improve our Products and our affiliates’ Products,
for example, to test new products, to determine if products that we are
contemplating may be desirable to our customers, for analytics, marketing
research, and business analysis
ii. To display,
optimize and provide you with personalized advertisements.
7.
Inferences Drawn from Other Personal Information.
a.
We may collect information based on your behavior on our site
(“Inferences”), such as site preferences or characteristics.
b.
We may collect these Inferences from:
i. Consumer;
ii. Cookies and
similar technology; or
iii. Advertising partners.
c.
We may collect Inferences:
i. To determine how users interact with our website and how we can improve the
user experience;
ii. To create a
customer profile in order to better optimize your customer experience and offer
personalized advertisements;
iii. For fulfillment
of your requests and purchases, transactional and other communications about
the Online and Offline Services and Products; promotional opportunities and
generally for Credit Climb’s internal business purposes such as, for example,
internal analyses and audits;
iv. For product
development and research, and for any purpose subject to the limitations set
forth in this Notice and applicable law;
v. For data
utilization from third parties, such as your telecommunications provider, to
help confirm your identity and prevent fraudulent access. It is likely that you
authorized your wireless operator to disclose your mobile number, name,
address, email, network status, customer type, customer role, billing type,
mobile device identifiers (IMSI and IMEI) and other subscriber status and
device details, if available, we may
provide this information to our third party service provider, solely to verify
your identity and prevent fraud for the duration of the business relationship. Credit
Climb limits the use of this information to prevent fraud and unauthorized
access or disclosures of your personal information.
IV.
COLLECTION AND USE OF INFORMATION
1.
Your Authorization to Credit Climb. When you subscribed
to any of the Products, you provided written instruction and authorization for Credit
Climb to obtain your credit information to display it to you, as well as to use
and share the information provided by you, along with your credit information,
to obtain personalized offers from third parties and display personalized
offers to you.
2.
Cookies, Pixels, and Similar Technology.
a.
Information Collected Passively via Cookies and Similar
Technology. A cookie is a small text file that a web server places on your
computer or device when your browser accesses a website. Cookies store data
specific to a client or website and are designed to create a record of or
“remember” online activity. We use cookies for a number of different purposes.
Some cookies are necessary to ensure the site functions properly and some
enable us to deliver an individualized Online Services experience.
b.
Use of Information. When you use the website, Credit Climb,
commercial partners, and service providers may use cookies and similar
technologies like pixel tags and web beacons to facilitate your access to and
use of our Online Services, and to improve, enhance and personalize your
experience for advertising purposes on the site. Like many websites, we also
use this technology to collect and store information to customize user
experience, track activity on the site, as well as to deliver and measure
online advertising, including Personalized offers and retarget advertisements. Credit
Climb advertising commercial partners and service providers may also use
cookies or similar technologies for the management and delivery of email
communications so that, for example, Credit Climb knows when an email
communication to you has been delivered or opened.
c.
Cookie Authorization. You generally have the ability to accept or
decline cookies. Most web browsers give you a choice to modify your browser
settings to decline some or all cookies. We provide you choices to manage your
privacy and sharing. Not accepting cookies may make certain features of the
site unavailable to you. If you would like more information about cookies, you
can visit http://www.cookiecentral.com/n_cookie_faq.htm. Partners and
service providers may separately permit you to opt-out of some or all of their
information collection activities.
3.
Analytics. Credit Climb uses a number of additional third-party
tools for analytical and advertising purposes. These tools provide internet or
similar network activity, geolocation and Inferences drawn from other network
activity, collected over time, and from other websites on which Credit Climb
displays advertisements and enables Credit Climb to understand and improve the
delivery of advertisements, enhance or modify our Online Services and Products,
as well as understand consumer experience. We may also use this information to
segment, enhance or modify our advertisements and to personalize your
experience.
4.
Credit Climb’s Credit Reporting Business. Access to
information on this Credit Climb database is limited to: (1) entities with a
permissible purpose to receive it, as defined in the Fair Credit Reporting Act;
(2) entities with a permitted use under the Gramm-Leach-Bliley Act; (3)
companies who resell Credit Climb data as permitted under law; and (4)
companies who process data on behalf of Credit Climb.
5.
Links to other sites or services. This Notice does
not apply to other third-party sites or services. Please remember that
personalized offers and other opportunities presented on Online Services will
include a link or linking ability to a third-party site or application. If you
click on a link or browse to a third-party site from our site/service, your
activity and interaction is subject to that third party's rules and policies.
These third-party sites are not controlled by Credit Climb and Credit Climb is
not responsible for the privacy practices or the content of any such third-party
site. Personalized offers are provided to you as a convenience and the display
of a third party offer through our Online Services is not an endorsement by Credit
Climb. If you provide any information to a third party, then the third party’s
respective privacy policies will apply with regard to any information you provide,
or which may be collected by the third party. If, however, the third-party site
provides that Credit Climb’s Notice applies to the information provided by you
on that site, then Credit Climb’s policies will apply to the information
collected for the purpose of enrolling in the Products once we receive the
information from you or the third party. We recommend that you review the
online privacy statements on these other sites to understand their privacy
practices and treatment of personal information so that you can make an
informed decision regarding your use or interaction with their site/service.
6.
Market Research. From
time-to-time, you may be presented with a survey or other questions to solicit
feedback about your use of the Products and the Online Services. Your
participation in these types of market research activities is optional. Should
you choose to participate, we may use information you provide to improve and/or
develop our Products and services.
7.
Securing Your Personal Information. We take security
seriously at Credit Climb and maintain physical, electronic, and administrative
safeguards to protect any information that we collect. Credit Climb uses
security technologies to safeguard credit information and any information you
provide us, and maintain policies, procedures, and compliance mechanisms, such
as training, independent review and third-party verification of our stated
practices, to ensure adherence to our information security plans. When Credit
Climb shares information as described in this Notice, we enter into written
agreements with such third parties to ensure that the physical and information
security environments of such third parties satisfy Credit Climb standards.
8.
Managing Your Account. You are
responsible for maintaining the accuracy of the information that you provide to
Credit Climb and for your own password management and online safety when
accessing the Products. Please always consider best practices like changing
your password routinely, using a strong password that is not the same as you
use for other websites, and not accessing the Products with unsecure devices or
unsecure networks. You may make changes to your account settings, including
your email address, phone number, mailing address, payment card information and
password details. You may also cancel your account online, if applicable, and
manage communications preferences related to certain types of communications
(email and SMS/MMS) from Credit Climb to you. Please note that although you may
manage communication preferences so that you do not receive commercial
communications from Credit Climb outside of the Products dashboard, you may not
decline to receive transactional communications from Credit Climb, which
contain information about your account and the Products. Please also note that
important information about your account, including the alerts that are a part
of the Product, will be sent to the email address and/or phone number that you
have provided, if applicable. It therefore is important that you update your
account information when necessary and actively check email communications from
Credit Climb.
9.
Personal information of Children. You must be at
least 18 to access our Online and Offline Services and Products or become a subscriber
of any subscription plan entitled to subscription benefits. Our Online and
Offline Services are not intended for use by children, and we do not knowingly
solicit or collect information from children. We do not sell the personal
information of children under the age of 16.
10. Assignment. Credit Climb
reserves the right to transfer or assign any and all of the information that we
collect on the website to an affiliate including in connection with any
reorganization, merger, sale, joint venture, assignment, transfer or other
disposition of part or all of the business, assets or stock of Credit Climb.
11. Notice Changes
and Effective Date. We may periodically make changes to this Notice and recommend
that you check back to review this Notice so that you always know how we
collect, use, and share your personal information. Credit Climb reserves the
right to change this Notice at any time without prior notice. We will inform
you of changes to the Notice via publication on our website. The effective date
denotes the date that we publish this Notice to our Online Services. Use of the
Products following any change constitutes your acceptance of the Notice then in
effect. We encourage you to check the website periodically for updates to our
Notice.
V.
RIGHTS
1.
Right To Know
You have the right to request a disclosure of the personal
information collected, sold, and shared about you over the past twelve months
and the purpose for doing so. Upon submission of a verifiable consumer request,
we will provide you with the following information.
If we provide this information to you electronically, the
information will be in a portable format. To the extent that it is technically
feasible, we will provide you the information in a readily useable format that
you can easily transfer to another entity.
2.
Right To Deletion
If we collected personal information from you, you have the right
to request the deletion of this personal information.
3.
Right To Be Free from Discrimination
You have the right to be free from discrimination for exercising
any of the rights under the Colorado Privacy Act. If you choose to exercise any
of your CPA rights, we will not:
·
Deny you goods or services;
·
Charge you a different price or rate for goods or services,
including through granting discounts or other benefits, or imposing penalties;
·
Provide you a different level or quality of good or services; or
·
Suggest that you may receive a different price or rate for goods
or services or a different level or quality of goods or services.
Right To Opt-Out Of The Sale Of Personal
Information.
You have the right, at any time, to direct a business that sells
your personal information to third parties to not sell your personal Information.
Contact Information.
If you have questions or concerns regarding this Notice or the
protection of your personal information and privacy rights, you may contact us at
info@creditclimb.com