Climbing Nova Privacy Policy

Climbing Nova or ClimbingNova is our basic assessment app. It will ask you for a minimum of personal details and give basic instructions for strength evaluation, monitoring, benchmarking and assessment.

The application can only be used by people over 16 years old. The use of the application by minors requires parental or legal guardianship at all times.

Due to the purpose of the app, the measurement of maximal strength and training, there is a potential risk of injury or harm. The use of this application is at the user’s own risk, and the user understands and accepts this risk by using it. The creators of the application are not responsible for any damage or injury sustained whilst using this application.

ClimbingNova SPJ respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you use our application or visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED
IMPORTANT INFORMATION AND WHO WE ARE
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS

IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy policy informs you on how ClimbingNova collects and processes your personal data including any information that is submitted to us through our applications, through our website or to us in any other way.
It is important that you read this privacy policy in conjunction with any other privacy policies that we may provide to you when we collect or process your personal data. This way you will be aware of how we use your data. This privacy policy supplements other privacy policies and is not intended to override them.

Children

Our application and website are not intended for children and we do not intentionally collect data relating to children or anyone under the age of 16 through our app or we.

We will request confirmation from whoever has parental responsibility for the child that they consent to Climbing Nova application collecting and processing the child’s personal data as set out in this privacy policy. We may also request, collect and process personal data relating to the person with parental responsibility and their relationship with the child for the purpose of verifying this consent and parental responsibility. We reserve the right to suspend or refuse to provide Climbing Nova products or services if we have any concerns regarding the validity of this consent.

If you have parental responsibility and wish to exercise any of the data subject rights on behalf of the child (e.g., review, correct, delete personal data) or if you have any questions about this privacy policy, please contact us at info@climbingnova.com. You may only exercise these rights on behalf of a child if the child authorizes you to do so, if the child does not have sufficient knowledge to exercise the rights themselves, or where it is clearly in the child’s best interests to do so.

When reviewing this privacy policy in relation to a child’s personal data, the words “you” and “your” may refer to the child and his or her personal data, as well as to you and your own personal data.

CONTROLLER

Contact details of ClimbingNova can be found in https://climbingnova.com/quienes-somos/

CONTACT DETAILS

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at info@climbingnova.com.

You have the right to make a complaint at any time to the concerned supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.

Changes in Privacy Policy and Your Duty to Notify Us of Changes
We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

Our application and website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

THE DATA WE COLLECT ABOUT YOU

Basic Identity Data first and last names, email address (this is mandatory information which we require to use the application

Detailed Identity Data includes date of birth, gender and sex and other information such as country of residence and gender, home address and telephone number.

Profile Data includes your username for our websites or our app (for our products or services only), purchases or orders made by you, your interests, preferences, feedback and survey responses. And information you provide about yourself and any preferences in your user account;

Contact Data includes billing address, delivery address, email address, country location.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us

Social Media Data includes Instagram handle and bio/posts/stories/reels and any direct messages, Facebook profile name and public profile. Information/posts/stories/reactions and any direct messages, Youtube subscriber name and public profile information/posts/reactions. Any information you share in a social media post where you tag, use a hashtag, link, or otherwise direct the post to our attention;

Usage Data includes information about how you use our websites, our app and our products and services.

Technical Data includes internet protocol (IP) address or Media Access Control (MAC), your login data, browser type and version, time zone setting and location, operating system and platform, a unique device identifier (when using our app) and other technology on the devices you use to access our websites and our app including Bluetooth.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Fitness/lifestyle activity data provided by you or generated through your use ClimingNova application and services, including activity data generated by the devices that you connect to the ClimbingNova App;

Information you provide about yourself which you choose to share with us via a free text field, for example, when completing workout reviews, giving feedback to us about your experience in the application, completing member surveys, etc.;

Communications with us or directed to us via letters, emails, chat services, calls, and social media;

Internet or other similar network activity depending on your permissions. For example, browsing identifiers, advertising ID, cookie identifiers, information on your interaction with the website, or advertisement.

Assessment Data includes (not all of these will apply to every service): your training and climbing history including perceived strengths/weaknesses; links to your public climbing logbooks (such as 8a.nu or UKClimbing.com); climbing aims and goals; physical metrics including weight, height, arm span, date of birth, gender; physical testing data including strength (fingers, core, upper and lower body), mobility and flexibility, endurance, and technique; and feedback relating to assessment & testing process.

Nutrition Data includes information relating to nutritional intake, timing and quality, and perceptions around food.

Training/Coaching Data includes (not all of these will apply to every service): your training and climbing history including perceived strengths/weaknesses; links to your public climbing logbooks (such as 8a.nu or UKClimbing.com); climbing aims and goals; session/training logs, feedback relating to nutrition/training plan services and climbing performance; basic athlete monitoring information including sleep, energy, and stress levels; and information relating to nutritional intake, timing and quality, and perceptions around food.

Parental Responsibility Data includes first name, last name, address, email address, telephone number and relationship to the child for any person claiming parental responsibility (“Person(s) with Parental Responsibility”).

We may also collect, use and share aggregated data, such as statistical or demographic data, for any purpose. Aggregate data may be derived from your personal data, but is not considered personal data under the law, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or application feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data to be used in accordance with this privacy policy.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information and genetic and biometric data). . We also do not collect any information about criminal convictions and offenses.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you our services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Automated technologies or interactions. As you interact with our website and/or App, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, add-in and other similar technologies.

Direct interactions. You may give us your Basic Identity, Detailed Identity, Social Media Data, Contact, Financial Data, Assessment Data, Nutrition Data, Training/Coaching Data and Gender Identity Data by filling in forms or by corresponding with us by email, via the chat function in our app, or otherwise (including via our app, direct messages, posts or reactions/likes on our social media platforms). This includes personal data you provide when you: order our products or services; are using our services and/or providing feedback in order to continue using our services; create an account on our websites or our app; subscribe to our services or publications request marketing to be sent to you; enter a competition, promotion or survey; or give us feedback or contact us (including by email, using our app, or using our social media platforms).

Third parties or publicly available sources. We will receive Technical Data from analytics providers such as Google based outside the EU.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe Inc, Royal Mail, and UPS and its/their affiliates.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when we are permitted to do so by law. Most commonly, we will use your personal data in the following circumstances:

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will obtain your consent before sending you direct marketing communications by email or text message. You have the right to withdraw your consent for marketing at any time by contacting us.

We will only use your personal data when we are permitted to do so by law. Most commonly, we will use your personal data in the following circumstances:

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data. The legal grounds for processing your data are:

Purpose/Activity	Types of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Basic Identity(b) Contact	Performance of a contract with you
To process and deliver your order including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us	(a) Basic Identity(b) Contact(c) Financial(d) Transaction(e) Marketing and Communications	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)
(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)	(a) Basic Identity(b) Contact(c) Profile(d) Marketing and Communications	(a) Performance of a contract with you(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable us provide our assessment and/or training/nutrition/coaching services to you, to understand your needs, and to communicate with you	(a) Basic Identity(b) Detailed Identity(c) Contact(d) Assessment Data & Training/Nutrition /Coaching Data(e) Technical Data	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To enable us to create and update computer generated models which inform our assessment reports to you and other clients	(a) Basic Identity(b) Detailed Identity(c) Assessment Data & Training/Nutrition/Coaching Data	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to develop our products and services and grow our business)
To enable us to conduct research —there has been very little long-term or large scale climbing specific research for academic or coaching purposes. Lattice is on a mission to fill this gap by using personal data for the purposes of scientific research to improve sport specific knowledge in the climbing community. We will pseudonymise all data for research purposes, and anonymise any data presented in a scientific paper or journal.	(a) Basic Identity(b) Detailed Identity(c) Assessment Data & Training/Nutrition /Coaching Data	(a) Necessary for our legitimate interests (to develop our products/services and grow our business)
To enable you to partake in a prize draw, competition or complete a survey	(a) Basic Identity(b) Social Media Data(c) Contact(d) Profile(e) Usage(f) Marketing and Communications	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our websites and our app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Basic Identity(b) Contact(c) Technical Data	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation
To deliver relevant website/app content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Basic Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) Technical Data	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our websites, our app, our products/services, marketing, customer relationships and experiences	(a) Technical Data(b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our websites and our app updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Basic Identity(b) Contact(c) Technical Data(d) Usage(e) Profile(f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)
To enable us to comply with a request from an affiliate assessor to provide a completed report following an assessment you have booked with them	(a) Basic Identity(b) Detailed Identity(c) Contact(d) Assessment Data	Necessary for our legitimate interests (to provide our services and grow our business)

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile, and Social Media Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We do not share the information we collect about you from the website with any 3^rd parties. However, we may share this information with law enforcement agencies, Government and regulatory bodies to meet legal and regulatory obligations.

INTERNATIONAL TRANSFERS

Whenever we transfer your personal data out of Europe we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by Europe.
Where we use certain service providers, we may use specific contracts approved by the European Commission and adopted by the UK Government which give personal data the same protection it has in Europe.
Where we use providers based in the US, we ensure that adequate safeguards are in place to protect your personal data.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

HOW LONG WILL WE USE YOUR PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our Retention Policy which you can request from us by contacting us.

In some circumstances, you can ask us to delete your data: see “Your Legal Rights” below for further information.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact info@climbingnova.com

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.