Introduction and Privacy Principles
The Data Climer Consulting Collects
Information Collected From All Visitors to the Website:
Climer Consulting does not utilize tracking technology on its Website and does not track Users who visit the Website unless they specifically log into the Climer Cards application using their unique credentials as detailed below. Once logged into Climer Cards, Climer Consulting collects information about the User’s use of Climer Cards, including the information they input into the application, page visits and the like as described in the “Use of Non-Personal Data Section.”
Data collected by the Website from all Users, is considered “Non-Personal Data” of a User.
Information Collected from Users Licensing Climer Cards
Climer Consulting collects the following information from Users who license directly with Climer Consulting for access to Climer Cards (collectively “Facilitators”):
The Licensee also has the option to provide additional information after sign-up.
The above information is considered “Personal Data” of the Facilitators and will only be provided to Climer Consulting when submitted by the Facilitator during the sign-up process. Climer Consulting uses Stripe to process credit card information, and will not have direct access to that information after sign up.
Information Collected from Users Utilizing Climer Cards
For those Facilitators who are utilizing Climer Cards with third-parties (“Students”) under a Master License Agreement, Climer Consulting will endeavor to only collect information from those Students which is necessary to grant them access to Climer Cards. However, by its very nature, Students may share personal information during sessions using the Climer Cards application.
Students Over the Age of 13: Students over the age of 13 hereby grant Climer Consulting the explicit consent to collect the information, including any Personal Data, they input into the Climer Cards application.
Students Under the Age of 13: Facilitators have the following options to protect the privacy of Students under the age of 13.
Option 1: The Facilitator may obtain the explicit consent of the Student’s parent or guardian to allow Climer Consulting to collect the Student’s Personal Data.
Option 2: Option 2: The Facilitator may encourage Students not to use their names or other Personal Data during a Climer Cards session and may toggle the reminder in the Facilitator dashboard.
Any information entered into the Climer Cards application during a session will be stored in the software’s database. Therefore, it is the Facilitator’s responsibility to make sure they strictly abide by either Option 1 or Option 2 above.
To the extent above information could be used to identify an individual Student, it is considered “Personal Data” of the Student.
Why Climer Consulting Collects Personal Data and How We Use It
General Use of Personal Data
Climer Consulting uses the Personal Data collected on the Website and in Climer Cards to allow Climer Consulting to provide Users with:
access to the Website and;
Climer Consulting may also use the Personal Data to contact a User for a variety of reasons, such as but not limited to:
notifying a User about use of the Website or;
requesting feedback on the Website, Climer Cards, or its related services.
Marketing and E-Mails
The above paragraph notwithstanding, Climer Consulting will not contact any Students with any marketing e-mails, only Facilitators. Climer Consulting may contact Students (to the extent possible) if Climer Consulting discovers a Student is having technical problems related to the Website or Climer Cards and cannot reach the Facilitator first.
To maintain its mailing list, Climer Consulting uses a software which keeps the list current and tracks if a User opts-out of receiving future communications. Climer Consulting complies with CAN-SPAM and related regulations that govern the use and maintenance of mailing lists.
Storage, Sharing and Disclosure of Personal Data
Storage of Personal Data
Facilitator Access to Student Personal Data
Facilitators will have access to their particular Student information contained in the Climer Cards database. This is a feature of Climer Cards and allows each Facilitator to manage their own sessions and Students. Whether or not a particular Student’s information is Personal Data is dependent on the options elected by the Facilitator and the information submitted by the Student during a Climer Cards session.
Disclosure to Third-Parties
Climer Consulting may disclose Personal Data to third parties under certain circumstances. Climer Consulting may disclose Personal Data to third parties if: 1) a User requested that Climer Consulting do so; 2) to comply with an applicable law, regulation, valid subpoena, or request of the US Government or; 3) Climer Consulting is acquired by or merged into another entity, or all or a portion of its assets are sold or otherwise transferred to another entity, Climer Consulting may disclose Personal Data to that entity. However, if the Personal Data includes information obtained from Students, Climer Consulting will ensure the acquiring entity abides by the privacy protections in this policy, or will provide Facilitators notice and an option to delete their Personal data prior to the sale occurring.
Access to And Control Over Information Held By Climer Consulting
Facilitator Dashboard: Facilitators can update or correct their own information on file with Climer Consulting by using the Facilitator dashboard
E-Mail: Additionally, via e-mail Users can specifically request information about:
What data Climer Consulting has about them, if any;
Changing/correcting any data Climer Consulting has about them;
Deleting any data Climer Consulting has about them and;
Expressing any concern that the User has about use of their data.
Please Note: Climer Consulting will direct any request from a Student for access to their information to the Facilitator they are receiving access from. The Facilitator will have the ability to update or correct Student information, not the Student him\herself.
How Climer Consulting Uses Non-Personal Data
Non-Personal Data may also be automatically collected about a User utilizing the Website. For example, Climer Consulting uses technology to automatically collect Non-Personal Data about the use of Website. This technology is used to track how many Users access Website, the date and time of their visits, the length of their stays, and which pages they view. Climer Consulting may also use technology to determine which web browsers Users use and the address from which they accessed the Website. The information collected using this technology does not identify any User personally and is thus all Non-Personal Data that simply enables Climer Consulting to compile statistics about Users and their use of the Website and related services.
Climer Consulting may store certain information from a User’s web browser using “cookies” or the browser-resident database\cache. A cookie is a piece of data stored on the User’s computer tied to information about the User and their use of the Website. Climer Consulting may use session-ID cookies to confirm that registered Users are logged in. These cookies would terminate once the User closes the web browser. Climer Consulting may also use persistent cookies that store certain Personal Data already provided to Climer Consulting to make it easier for a User to log back into the Website. A User can remove or block cookies using the settings in the User’s web browser if a user wants to disable such functions, but such action may impair the full functionality of the Website.
Climer Consulting does not utilize third-party tracking cookies or engage in cross-website tracking in any way. A User’s utilization of the Website or Climer Cards will not be shared with advertisers.
The Security Practices Of Climer Consulting
Climer Consulting uses industry standard security measures to protect Users’ Personal Data. While such security measures provide reasonable protections against unauthorized access, they do not provide a guarantee that Personal Data will not be compromised in the future. By its nature, a cloud based service like Climer Cards resides on servers and computer systems accessible via the Internet which may be compromised or misused by third-party bad actors that Climer Consulting has no control over.
Whenever a website collects sensitive information a User should confirm that the information is encrypted and transmitted in a secure way. One way that a User may do so is by looking for a closed lock icon at the bottom of the web browser or looking for “https” at the beginning of the address of the web page.
LINKS TO OTHER WEBSITES
Climer Consulting does not intend to collect Personal Data from Users (or Students, as the case may be) that are under the age of thirteen. If a User allows access to the Website to a third party, that User is responsible for ensuring that the information shared by the third party does not contain their first\last name, address, or any other information that may allow Climer Consulting (or any third party) to identify them individually.
To the extent that Personal Data of anyone under the age of thirteen is shared with Climer Consulting by a User, such sharing of the Personal Data serves as the explicit consent for Climer Consulting to collect such information.
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