CLIMB TECHNOLOGIES PRIVACY POLICY

INTRODUCTION

At Climb Technologies Inc. we are committed to protecting your privacy. This Privacy Policy covers how Climb Technologies Inc. collects, receives, uses, retains, and discloses Personal Information on Climb Technologies Inc.’s website.

Climb Technologies Inc. (the “Company”, “Climb Technologies”, “us”, “we”, or “our”) operates the Climb Technologies website, https://climb.care (the “Site”), any other websites, web applications or mobile applications that the Company owns or controls and which posts or links to this Privacy Policy now existing or implemented in the future, all related applications, widgets, software and tools and the services which Company agrees to provide to you (the “Services”). This Privacy Policy covers all Personal Information collected by Climb Technologies through the Services.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not register with or use any part of the Site or the Services. By submitting information through the Site or in connection with the Services, you agree to the terms of this Privacy Policy and you expressly consent to the processing of your Personal Information in accordance with this Privacy Policy. We will review this policy regularly, and we may update it from time to time. This Privacy Policy is incorporated into and subject to our Terms of Use.

This Privacy Policy also explains how we process “personal data” about people in the European Economic Area (“EEA”), United Kingdom (“UK”) or Switzerland, as required under the General Data Protection Regulation (“GDPR”). For people in California, we have also prepared a Supplemental Privacy Statement for California Consumers under CCPA(“California Statement”) in compliance with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). Please review our California Statement below for more information.

1. When We Collect Personal Information.

When you visit the Site, you are free to view the Site without providing any Personal Information. In order to register to use the Site, you will be required to provide certain Personal Information about yourself. Each time you visit the Site and login, we request that you provide Personal Information about yourself, and we may collect Navigational Information on our Site. Each time you apply to join a clinical trial, we request that you provide Personal Information about yourself.

2. Definitions.

2.1 Data Controller - Data Controller means the person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information is, or is to be, processed. For the purpose of this Privacy Policy, we are the Data Controller of your Personal Information. You can contact us at Climb Technologies Inc., 405 Arguello Blvd. Ste. 200 San Francisco, CA 94118 or via email at privacy@climb.care.

2.2 Service Providers - Service Providers means any natural or legal person who processes the data on behalf of the data controller.

We may use the services of various Service Providers in order to process your Personal Information more effectively.

2.3 Data Subject - Data Subject is any identified or identifiable individual who is using the Site and is the provider of Personal Information.

2.4 Personal Information -Personal Information means individually identifiable information of a Data Subject that is personally identifying such as name, email address, and phone number and which is not otherwise publicly available. Personal Information also includes information about a Data Subject’s activities, such as information about his or her activity on the Site, and demographic information, such as date of birth, gender, address and geographic area.

2.5 Research Organization - Research Organizations are entities which run clinical trials and use the Site and the Services to identify appropriate persons for their clinical trials.

2.6 Usage Data - Usage Data is data collected automatically either generated by the use of the Site or from the Site’s infrastructure itself (for example, the duration of a page visit).

3. Information Collection and Use.

We collect several different types of information for various purposes to provide and improve our Service to you.

4. Types of Data Collected.

We collect several different types of information for various purposes to provide and improve our Service to you, including:

4.1 Information You Provide To Us.

We collect Personal Information you may provide to us. The specific types of Personal Information we collect will depend upon the Services you use, how you use them, and the information you choose to provide. The types of data we collect directly from you includes, without limitation:

  • ● Name, address, phone number and email address
  • ● Company and current title
  • ● Log-in credentials, if you create an account
  • ● Health data about yourself, for example medical history or health conditions
  • ● Information about your session interactions with us
  • ● Feedback or correspondence you send to us
  • ● Any other information you choose to directly provide to us in connection with your use of the Services.

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

4.2 Usage Data

We may also collect information how the Site is accessed and used. This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of the Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

4.3 Tracking Cookies Data.

We use cookies and similar tracking technologies to track the activity on the Site and hold certain information.

Cookies are files with small amounts of data which may include an anonymous unique identifier. Cookies are sent to your browser or device from a Site or application and stored on your device. You have choices with respect to cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies that may prevent us from providing you with the full range of Services we offer.

We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them).

We use functionality, security and personalization cookies for authentication, to remember your settings, to keep track of your activity during a visit to the Site, to prevent fraud, and protect you as you interact with the Services, to conduct usability tests, to improve Site performance, and to implement certain features of the Site.

We use analytics and customization cookies, including third party cookies, to gather information on how the Site is being used by our visitors and to measure how popular our marketing campaigns are. We use the data we get to help customize the Site and products for you and make the content you see as relevant as possible. We may also use the data we collect to help identify and prevent fraud, and to track visits from our affiliates or partners.

We may use social networking cookies, which allow visitors to share our pages and content through third-party social networking websites.

We may use Targeting/advertising cookies help us to customize and regulate (e.g., by capping the frequency of) the advertisements you receive, provide you with tailored offers, and measure the effectiveness of our advertising. For instance, if we target an ad campaign through an online advertising network, we might use cookies on our Site to estimate how many viewers of the ad later visited our Site - and therefore, how effective the ad campaign was. Or, we might “retarget” visitors to our Site by providing them offers (whether through online display media, email or direct mail) similar to those they viewed or expressed interest in during their Site visits.

Third parties may use cookies and other technologies to collect information about your online activities over time and across different websites. Please be aware that the use of cookies by third parties is not covered by our Privacy Policy.

Web beacons are electronic images that may be used on the Site or in our emails. We use web beacons to deliver cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon. We may also use clear gifs or other data files or identifiers to collect information for statistical purposes and to improve and develop the Services. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are placed on a hard drive, clear gifs are embedded invisibly on web pages.

4.4 Google Analytics.

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of the Site. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Services available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page here.

4.5 ChatGPT API.

We use ChatGPT’s application programming interface ( the “ChatGPT API”) to integrate ChatGPT (“ChatGPT”) functionalities into our platform. ChatGPT is a language model and by its nature may provide responses that may not be accurate or complete. You are solely responsible for the information you input into the Site, including Personal Information. We are not responsible for any inputs by you, including any inputs that may be inaccurate, offensive, or illegal. For more information on the terms of use and privacy rules of ChatGPT, please visit the OpenAI Terms of Use here and the OpenAI Policies here.

4.6 Application Programming Interface (“API”).

We may collect Personal Information through third-party APIs. An API is a programming interface that may be used to connect two computer applications for a variety of purposes, including to provide us with analytics regarding the use of our website and/or platform, to integrate with social media, add features or functionality to our website and/or platform, or to facilitate online advertising. APIs may enable third parties to collect personal information directly via our website and/or platform.

5. Do Not Track.

We do not respond to browser-based “do not track” signals.

6. Use of Personal Information.

Climb Technologies uses or may use your collected data for various purposes:

  • ● To operate, provide and improve our Services;
  • ● To send information or content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
  • ● To promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
  • ● To send information to you regarding changes to our Terms of Use found at https://climb.care/terms-of-service, this Privacy Policy or other legal agreements;
  • ● To respond to support requests as well as send you information regarding service upgrades, improvements or issues regarding the use of the Site;
  • ● To gather analysis or valuable information so that we can improve the Site;
  • ● To monitor the usage of the Site;
  • ● To ensure network and information security;
  • ● To inform you of upgrades or changes to the Site; and
  • ● To detect, prevent and address technical issues.
7. Disclosure of Personal Information.

7.1 Disclosures. Regardless of any choices you make regarding your information (as described below), the Company may disclose information if it believes in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on the Company; or (b) protect or defend the rights or property of the Company, users of the Services, or any other party.

7.2 Affiliates. We may share some or all of your information with any other company or individual that directly or indirectly controls, is controlled by or is under common control with the Company (each an “Affiliate”), if any, in which case we will require our Affiliates to honor this Privacy Policy. We may share your personal information in connection with, or during negotiations of, a transaction that alters the structure of our business, such as a reorganization, merger, sale, transfer, change of control, or other disposition of all or a portion of our business, assets or stock, including a bankruptcy or similar proceeding. If another company acquires the Company or our assets, or an Affiliate or its assets, that company will possess the information we have collected and will assume the rights and obligations described in this Privacy Policy.

7.3. Research Organizations. Any Personal Information, including health data, that you share directly with a Research Organization that intends to run or is running a clinical trial will be subject to the privacy practices of such Research Organization and we shall have no responsibility or liability for the handling of your Personal Information by such Research Organization.

7.4 Disclosure to Third Party Service Providers. We may share your Personal Information with Service Providers or other business partners that are contractually bound (via business associate agreements entered into between the Company and each Service Provider) to safeguard your information. We may make such disclosure in order to provide you with the Services; to conduct quality assurance testing; to facilitate creation of accounts; to facilitate your use of the Service; to process any transactions you make through our Site or Services (including without limitation credit card processing); to provide technical support; or to offer you certain products or services or for their promotional or marketing purposes, as permitted by law. We may also share your information with any other party with your express consent.

7.5 Third-Party Platforms. We may link to or frame third-party websites, decentralized applications and platforms (collectively, “Third-Party Platforms”). Our provision of a link to or frame of any Third-Party Platform is for your convenience and does not signify our endorsement of such Third-Party Platform or its contents. If we display third-party websites through a frame, you are on another site. During this process, another entity may collect information from you. We have no control over, do not review, and cannot be responsible for, these outside Third-Party Platforms or their content or their privacy practices. Please be aware that the terms of this Privacy Policy do not apply to these Third-Party Platforms or content, or to any collection of data after you click on links to such Third-Party Platforms.

7.6 Use of Navigational Information. We may use Navigational Information to operate and improve the Site.

7.7 Testimonials and Comments. We may post customer testimonials and comments on our Site, which may contain Personal Information. We will obtain each customer’s consent via email, Instagram, Facebook, or other social network prior to posting the customer’s name and testimonial.

7.8 Security of your Personal Information. We are committed to protecting the security of your Personal Information. We use a variety of industry-standard security technologies and procedures to help protect your information from unauthorized access, use, or disclosure. But remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

8. Your Choices Regarding Your Information.

8.1 Choices. We offer you choices regarding the collection, use, and sharing of your information. When you receive communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive. Should you decide to opt-out of receiving future mailings, we may share your e-mail address with third parties to ensure that you do not receive further communications from these third parties. Despite your indicated e-mail preferences, we may send you emails related to your account or transactions thereunder, or notices of any updates to our Terms of Use or this Privacy Policy.

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Service may be inaccessible or not function properly. You can choose whether or not to allow the Service to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Service may be inaccessible or not function properly.

8.2 Changes to Information. You may change any information in your account by sending an e-mail to us at privacy@climb.care. You may request deletion of your information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives.

8.3 To Unsubscribe from Our Communications. . You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails or by sending us email us at privacy@climb.care. or at the following address:

By Postal Mail:

Climb Technologies Inc.Attention: Privacy405 Arguello Blvd. Ste. 200San Francisco, CA 94118

Customers cannot opt out of receiving transactional emails.

9. Links to Other Site and Mobile Applications.

The Site may contain links to other sites or mobile applications that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.

We may maintain pages for Climb Technologies on social media platforms such as LinkedIn and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use, and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party site or services.

10. Legal Basis for Processing Personal Information Under General Data Protection Regulation (GDPR)

10.1 If you are from the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, the Company’s legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.

The Company may collect and process your Personal Information because:

  • ● We need to perform a contract with you.
  • ● You have given us your consent to do so.
  • ● The processing is in our legitimate interests and it is not overridden by your rights.
  • ● To comply with the law.
  • ● To protect the vital interests of an individual.
  • ● For the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

The Company will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We also may retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. We do not use your Personal Information for the purposes of automated decision-making or profiling.

10.2 Transfer of Data. Your information, including Personal Information, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

The Site is hosted in the United States. If you are located outside of the United States and choose to provide information to us, please note that we may transfer the data, including Personal Information, to the United States or other country and process it there

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer to the United States or another country.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Information.

10.3 Disclosure of Data

Legal Requirements

The Company may disclose your Personal Information in the good faith belief that such action is necessary:

  • ● To comply with a legal obligation
  • ● To protect and defend the rights or property of the Company
  • ● To prevent or investigate possible wrongdoing in connection with the Site
  • ● To protect the personal safety of users of the Site or the public
  • ● To protect against legal liability

10.4 Your Data Protection Rights Under General Data Protection Regulation (GDPR).

If you are a resident of the EEA, you have data protection rights to correct, amend, delete, or limit the use of your Personal Information. To exercise any of these rights, please contact us at privacy@climb.care.

Under the GDPR, you have the following data protection rights:

  • ● The right to be informed what Personal Information we hold about you.
  • ● The right to access, update or to delete the Personal Information we have about you.
  • ● The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • ● The right to object. You have the right to object to our processing of your Personal Information.
  • ● The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
  • ● The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • ● The right to withdraw consent. You also have the right to withdraw your consent at any time where the Company relied on your consent to process your Personal Information. (However, withdrawing your consent will not affect the lawfulness of any collection or processing we conducted prior to your withdrawal, nor will it affect collection or processing of your Personal Information conducted in reliance on lawful grounds other than consent.)

We will strive to respond to your request within a month, but this may be extended by an additional two months, if necessary. Please note that we may ask you to verify your identity before responding to your request.

In addition, where we obtain Personal Information about you from a source other than yourself, we may not be required to provide you with certain information described in this Privacy Policy if:

  • ● You already have the information
  • ● Providing you with the information would prove impossible or would involve a disproportionate effort on our part
  • ● We are under legal obligation to obtain or disclose the information, which provides appropriate measures to protect your legitimate interests
  • ● We are obliged to keep the information confidential as a result of an obligation of professional secrecy under applicable law

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the EEA, UK or Switzerland. A list of Data Protection Authorities is available at:https://edpb.europa.eu/about-edpb/board/members_en. Unless otherwise indicated in this Privacy Policy, Climb Technologies is a Data Controller for the Personal Information we collect and process.

11. Residents of Canada

Users of the Site from Canada are informed we take appropriate steps to comply with applicable Canadian data privacy requirements, including the Anti-Spam Legislation (CASL) and the Personal Information Protection and Electronic Documents Act (PIPEDA). Note, however, that Personal Information stored or processed outside of Canada, including in the United States or another foreign country, may not be subject to the PIPEDA. In addition, Personal Information stored or processed outside of Canada is subject to the laws of that other country and may be available to the foreign government of the country in which the Personal Information or the entity controlling it is located pursuant to a lawful order in that jurisdiction. This Privacy Policy is intended to provide the required notices regarding our collection and use of Personal Information, including transfer to the United States.

You may request to access, correct, or delete your Personal Information, or withdraw consent to our collection, use or disclosure of your Personal Information, by contacting us at privacy@climb.care.

12. Children’s Privacy. The Site is not intended to be accessed or used by anyone under the age of 18 (a “Child”).

We do not knowingly collect Personal Information directly from anyone under the age of 13. If you are a parent or guardian and you are aware that your Child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a Child without verification of parental consent we take steps to remove that information from our databases.

13. Changes to This Privacy Policy.

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will endeavor to let you know via email and/or a prominent notice on our Site, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

14. Dispute Resolution

If you have any questions or concerns, please contact Climb Technologies by e-mail at privacy@climb.care. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation. If you and Climb Technologies are unable to reach a resolution to the dispute, you and Climb Technologies will settle the dispute exclusively under the rules of the American Arbitration Association (www.adr.org) as set forth in the Terms of Use found at https://climb.care/terms-of-service.

15. Supplemental Privacy Statement for California Consumers under CCPA

Our business proudly serves or will serve certain natural persons residing in the State of California (each, a“consumer”). This California Statement explains rights that California consumers may have under the CCPA.

When we use the term “personal information” in this supplemental California Statement, we are using that term as CCPA defines it, which CCPA generally defines “personal information” to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. However, personal information does not include publicly available, deidentified, or aggregate consumer information (which are all defined in CCPA). Notably, the definition of “personal information” also does not apply to the collection of personal information from job applicants, employees – whether you are our employee or any employee of the entity arranging access to our Services for you, business owners, directors, officers, or contractors.

15.1 Categories of Personal Information We Collect, the Sources, Purposes for Why We Collect It, Who We Share It With, and Whether We Sell That Personal Information.

Where we act as a “business” under CCPA (meaning we determine the manner and reasons for why we process your personal information), we may be required to disclose additional information regarding the categories of personal information we collect, the sources where we obtain that information, the purposes for why we collect that information, who we share that information with, as well as whether we sell that personal information – all of which depends on the specific Service.

Climb Technologies has not sold any personal information within the last twelve (12) months.

The personal information that Climb Technologies collects, may collect or has collected from consumers in the twelve months prior to the effective date of this Privacy Policy fall into the following categories established by the California Privacy Rights Act:

  • ● identifiers such as your name, address, phone numbers, postal address, email address, IP address, your account log-in information;
  • ● personal information, such as your telephone number;
  • ● information that may reveal age, gender, race, sexual orientation, or other protected classifications;
  • ● commercial information, such as purchases or other purchasing or consuming histories or tendencies;
  • ● internet or other electronic network activity information, including browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
  • ● geolocation data, such as the location of your device or computer, which may in some cases constitute precise geolocation information; and
  • ● professional information, for example data you may provide about your business

The personal information that Climb Technologies collects, may collect or has collected from consumers in the twelve months prior to the effective date of this Privacy Policy, may be collected or disclosed for the following business purposes:

  • ● To provide and maintain our Services, including to monitor the usage of our Services;
  • ● To manage user accounts: to manage user registration;
  • ● To contact users: To contact users by email, telephone calls or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications;
  • ● To provide users with news, special offers and general information about other services and events unless you have opted not to receive such information;
  • ● Protecting against security threats and illegal activities;
  • ● To manage user requests: To attend and manage user requests to the Company;
  • ● Use of service providers: We share information with Service Providers to perform services on our behalf, in compliance with our Privacy Policy and other appropriate confidentiality and security measures;
  • ● Legal reasons: We use information to satisfy applicable laws or regulations, and disclose information in response to legal process or enforceable government requests, including to law enforcement;
  • ● For business transfers: We may use user information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Service users is among the assets transferred; and
  • ● For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience.
  • We may share Your personal information in the following situations:

  • ● With Service Providers: We may share user personal information with Service Providers which are businesses or persons that process information on the Company’s behalf, based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures;
  • ● For business transfers: We may share or transfer user personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company;
  • ● With Affiliates: We may share user information with affiliates, in which case we will require those affiliates to honor this Privacy Policy;
  • ● Law enforcement requests; and
  • ● With Your consent: We may disclose Your personal information for any other purpose with user consent.

15.2 Your Privacy Rights.

If you are a resident of California and are not a job applicant, employee/contractor, or employee/contractor of another company interacting with us in your job role, you have the right to request what information we collect, use, and disclose. You also have the right to request that we delete your information. In addition, as a consumer you have additional rights under the CPRA, including rights to correct inaccurate personal information and limit the use and/or disclosure of sensitive personal information, the right to information about our data retention practices, and the right to opt out of the use of automated decision-making technology. That technology includes the automated processing of personal information for the purpose of evaluating or predicting personal aspects of consumers’ performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

To make a request, you can contact us at privacy@climb.care. Provide us enough information to verify your identity. We will use information you provide to us to verify your identify. If we cannot initially verify your identity, we may request additional information to complete the verification process, such as, for example, a copy of your driver’s license and/or a recent utility or credit card bill.

We will confirm receipt of your request within 10 business days. We must provide the requested information or delete your personal information within 45 days of receipt of your request, but we can use up to an additional 45 days if we let you know that additional time is needed.

You can designate an agent to make a request on your behalf by either: (1) having your agent send us a letter, signed by you, certifying that the agent is acting on your behalf and showing proof that they are registered with the California Secretary of State; or (2) by you and the agent executing and sending us a notarized power of attorney stating that the agent is authorized to act on your behalf. Please note that we may still require you to verify your identity before we process a request submitted by your agent.

California residents also have certain rights regarding the sale of personal information. California residents have the right to opt out of the sale of their personal information by contacting us at privacy@climb.care.

We will not discriminate against you because you have exercised any of your privacy rights under the CCPA.

16. Contact Information.

We welcome your comments or questions regarding this Privacy Policy. Please e-mail us at privacy@climb.care. or contact us at the following address:


By Postal Mail:

Climb Technologies Inc.Attention: Privacy405 Arguello Blvd. Ste. 200San Francisco, CA 94118

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