Privacy Policy

This Privacy Policy explains how Clym Ltd., its subsidiaries and affiliated companies, (collectively, “Clym,” “we,” or “us”) collects, uses, and discloses information about you. This Privacy Policy applies when you use our website(s), mobile application(s), and other products and services covered by this Privacy Policy (collectively, our “Services”), contact our customer service team, engage with us on social media, or otherwise interact with us.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the bottom of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or providing you with a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

CONTENTS

• Collection of Information
• Use of Information
• Sharing of Information
• Third-Party Embeds
• Transfer of Information to the United States and Other Countries
• Your Choices
• Your California Privacy Rights
• Additional Disclosures for Individuals in Europe
• Contact Us

COLLECTION OF INFORMATION

DATA WE COLLECT

Data provided by Customers:

• Account Registration. When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number. We might also ask you to provide information about the company, its address, phone number, VAT, DPO contact data (Service Data) that you may choose to make public or not. If you choose to refer a friend to our Services, we may also collect your friend’s email address so that we may send them a referral or promotional code to sign up for our Services.
• Payment Information. When you add your financial account information to your Account, that information is directed to our third-party payment processor. We do not store your financial account information on our systems; however, we have access to, and may retain, subscriber information through our third-party payment processor.
• Communications. If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

Data provided by End Users:

• Account Registration. When an End User register for an Account with Clym, we may ask for contact information, including items such as name, email address. 
• Data collected by the Customer. Clym Services allows Customers to decide what data they want to collect about the End Users. The collection and use of this data will be subject to Customer privacy policy. For this type of data Clym plays the role of data processor, does not control the data that is collected, it’s purposes and ways the data is handled and use.
• Communications. If the End User contact us directly, we may receive additional information about you such as name, email address, phone number, the contents of the message and/or attachments he/she may send us, and any other information he/she may choose to provide.

The personal information that the End User is asked to provide to Clym, and the reasons why he/she is asked to provide it, will be made clear at the point we ask him/her to provide such personal information.

Data we collect when Customers or the End Users use of Clym Services:

• Cookies. We only use essential, functional or analytics cookies that help us provide you with the service. 
• First-party cookies. The data we collect includes internet protocol (IP) addresses, browser type, web pages, operating system, date/time stamp. To collect this information, a cookie is set on your computer or device when you visit Clym Services or, in case of an End User, when he/she visits a website that implements Clym Services. Cookies contain a small amount of information that allows our web servers to recognize you. We store information that we collect through cookies. To provide our Customers with the Clym Service, End Users & Customers are tracked across different websites and services. 
• Third-party cookies. We might use other third-party services in order to provide you with Clym Services or to analyze our traffic. These services, might set up their own cookies to remember you. In case these cookies are not essentials to deliver our service, we’ll ask for your consent before loading them. Please review the Cookie policy for a complete list of cookies we use.
• Usage of our Services. When you use Clym Services, we collect information about your engagement with and utilization of our Services, such as: sites that use Clym Services; features that are used; IP/location; browser agent data. We use this data to operate the Clym Services, protect the security and safety of Clym Services and our customers, maintain and improve the performance and utilization of the Clym Services, develop new features and provide customer support. You can read more about our usage of cookies in our Cookie Policy. 

Data we receive from Third Parties:

• Third-Party Identity Providers. If you choose to link our Clym Services to a third-party identity provider, we will receive information about the End User account, such as an authentication token, email, name from the third-party identity provider, to authorize linking. 
• Third-Party Partners. We may receive information about you from our third-party partners such as contact data from events’ organizers. We may use the data to contact you and present Clym Services, but only to the extent of the consent you provided and the third-party partner passed it to us.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer reading preferences based on your reading history.

USE OF INFORMATION

We use the information we collect to provide, maintain, and improve our Services. We also may use the information we collect to:

• Create and maintain your Clym account;
• Process transactions and send related information, such as confirmations, receipts, and user experience surveys;
• Send you technical notices, security alerts, and support and administrative messages;
• Respond to your comments and questions and provide customer service;
• Monitor and analyze trends, usage, and activities in connection with our Services;
• Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Clym and others;
• Comply with our legal and financial obligations; and
• Carry out any other purpose described to you at the time the information was collected.

SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy:

• We may share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, storage, and other infrastructure, analytics, payment processing, fraud prevention and security, customer service, communications, and marketing.
• We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. If we are going to disclose your personal information in response to legal process, we will give you notice so you can challenge it (for example by seeking court intervention), unless we are prohibited by law or believe doing so may endanger others or cause illegal conduct. We will object to legal requests for information about users of our Services that we believe are improper.
• We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Clym, our users, the public, or others.
• We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• We share personal information with your consent or at your direction.
• We also share aggregated or de-identified information that cannot reasonably be used to identify you.

THIRD-PARTY EMBEDS

Clym does not host some of the content displayed on our Services. Users have the ability to post content that is actually hosted by a third party, but is embedded in our pages (an “Embed”). When you interact with an Embed, it can send information about your interaction to the hosting third party just as if you were visiting the third party’s site directly. For example, when you load a Clym post page with a YouTube video Embed and watch the video, YouTube receives information about your activity, such as your IP address and how much of the video you watch. Clym does not control what information third parties collect through Embeds or what they do with the information. This Privacy Policy does not apply to information collected through Embeds. The privacy policy belonging to the third party hosting the Embed applies to any information the Embed collects, and we recommend you review that policy before interacting with the Embed.

SECURITY

Clym takes reasonable precautions such as policy-based access control and encryption to protect Data in our possession from loss, misuse, and unauthorized access. Clym follows generally accepted industry standards to protect the Data, both during transmission and once received by Clym. However, no method of transmission over the Internet or method of electronic storage is 100% secure. 

TRANSFER OF INFORMATION TO OTHER COUNTRIES

Clym is headquartered in the United States, and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. For example, we transfer personal data to Amazon Web Services, one of our service providers that processes personal information for us in various data center locations across the globe. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

YOUR CHOICES

Account Information

You may access, correct, delete and export your account information at any time by contacting us at using the Clym privacy widget embedded in this website. Please note that if you choose to delete your data, we may continue to retain certain information about you as required by law or for our legitimate business purposes.

Cookies

Many web browsers are set to accept cookies by default, and Clym uses its own platform for its cookie consent management, and you can control your cookie settings by utilizing the Clym platform available on this and every other website page. For more information, visit our Cookie Policy.

Communications Preferences

You may opt out of receiving certain communications from us, such as digests, newsletters, and activity notifications, by following the instructions in those communications or the Clym platform, as discussed above. If you opt out, we may still send you administrative emails, such as those about your account or our ongoing business relations.

Mobile Push Notifications

With your consent, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

YOUR EUROPEAN DATA PROTECTION RIGHTS

If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you have certain rights and protections under applicable law regarding the processing of your personal data, and this section applies to you.

Legal Basis for Processing

When we process your personal data, we will do so in reliance on the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., providing the products and services you requested).
• When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
• To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of non-administrative communications).
• When we have your consent to do so (e.g., when you opt in to receive non-administrative communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

Data Retention

We store personal data associated with your account for as long as your account remains active. If you close your account, we will delete your account data within 14 days. We store other personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Data Subject Requests

Subject to certain limitations, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. To exercise your rights, please utilize the capabilities of the Clym platform or email us at privacy@clym.io.

Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

• For individuals in the EEA:
  https://edpb.europa.eu/about-edpb/board/members_en
• For individuals in the UK:
  https://ico.org.uk/global/contact-us/
• For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

Please be advised that if you are a resident of the European Union, in case you allow Clym to collect and process certain personal data from you, you have the following rights:

1. Right of Access. You have the right to obtain from us confirmation as to whether or not personal data concerning you are processed, and, where that is the case, you have the right to request and get access to that personal data.
2. Right to Rectification. You have the right to obtain from us the rectification of inaccurate personal data and you have the right to provide additional personal data to complete any incomplete personal data.
3. Right to Erasure (“Right to be Forgotten”). In certain cases, you have the right to obtain from us the erasure of your personal data.
4. Right to Restriction of Processing. You have the right to obtain from us restriction of processing, applicable for a certain period and/or for certain situations.
5. Right to Data Portability. You have the right to receive from us in a structured format your personal data and you have the right to (let) transmit such personal data to another controller.
6. Right to Object. In certain cases, you have the right to object to processing of your personal data, including with regards to profiling. You have the right to object at further processing of your personal data in so far as such data have been collected for direct marketing purposes.
7. Right to be Not Subject to Automated Individual Decision-Making. You have the right to not be subject to a decision based solely on automated processing.
8. Right to Filing Complaints. You have the right to file complaints with the applicable data protection authority on our processing of your personal data.
9. Right to Compensation of Damages. In case we breach applicable legislation on processing of your personal data, you have the right to claim damages from us for any damages such breach may cause with you.

YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

In the preceding 12 months, we have collected the following categories of personal information: identifiers, commercial information, internet or other electronic network activity information, and inferences. For details about the precise data points we collect and the categories of sources of such collection, please see the Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

Clym does not sell your personal information.

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose about you, (2) request deletion of your personal information, (3) opt out of any sales of your personal information, if we engage in that activity in the future, and (4) not be discriminated against for exercising these rights. You may make these requests by emailing us at privacy@clym.io or by completing the form listed in the Clym platform. We will verify a webform request by asking you to provide identifying information. We will not discriminate against you if you exercise your rights under the CCPA.

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. This may include requiring you to verify your identity. If you are an authorized agent seeking to make a request, please contact us by using the Clym platform or via email at privacy@clym.io or by calling 1-866-275-2596.

CONTACT US

If you have any questions about this Privacy Policy, please contact us privacy@clym.io.

If you are from the EEA, Switzerland, or the United Kingdom, please contact us at privacy@clym.io or contact our EU representative at:

1126 bp. Beethoven utca 6.
Budapest, Hungary

Last Updated October 6, 2022