Legal

Privacy
Policy

Effective Date: May 6, 2026 — Climb Group, Inc.

01

Information We Collect

When you visit the Site, we may collect certain information automatically, including your IP address, browser type, referring URLs, pages viewed, and the date and time of your visit. This information is collected via standard server logs and analytics tools.

When you voluntarily submit information through our inquiry or email capture forms — such as your name, email address, company, and message — we collect and store that information in order to respond to your inquiry and evaluate a potential business relationship.

We do not knowingly collect sensitive personal data such as financial account numbers, government identification numbers, or health information through the Site.

02

How We Use Your Information

We use the information we collect to: (1) respond to your inquiries and communicate with you about our services; (2) evaluate and develop potential business relationships; (3) send you updates about Climb, if you have opted in to such communications; (4) analyze usage of the Site to improve its content and functionality; and (5) comply with legal obligations.

We do not sell, rent, or otherwise disclose your personal information to third parties for their own marketing purposes.

03

Legal Basis for Processing

If you are located in the European Economic Area (EEA) or United Kingdom, our legal bases for processing your personal data are: (1) your consent, where you have provided it; (2) the performance of a contract or pre-contractual steps at your request; (3) our legitimate interests, including operating and improving the Site and communicating with prospective clients; and (4) compliance with a legal obligation.

You may withdraw consent at any time by contacting us at the address below, without affecting the lawfulness of processing based on consent before its withdrawal.

04

Sharing Your Information

We may share your information with: (1) service providers who assist us in operating the Site, conducting our business, or servicing you, subject to confidentiality obligations; (2) professional advisors such as lawyers and accountants; and (3) law enforcement, regulators, or other parties where required by applicable law or to protect the rights, property, or safety of Climb, our clients, or others.

Any third-party service providers we engage are contractually required to handle your information securely and in accordance with applicable law. They are not permitted to use your information for their own purposes.

05

Cookies & Tracking

The Site uses cookies and similar tracking technologies to understand how visitors interact with our pages. These include analytics cookies (to measure traffic and usage patterns) and marketing cookies (used by third-party platforms to help us understand the effectiveness of our communications).

We use HubSpot for marketing automation and CRM, Lemlist and Apollo.io for outreach tracking, and standard analytics tools. Each of these services may place cookies on your device when you visit the Site.

You may control cookie settings through your browser preferences. Disabling certain cookies may affect the functionality of the Site. Most browsers allow you to refuse cookies or delete them at any time.

06

Data Security

We implement reasonable technical and organizational measures to protect your personal information against unauthorized access, loss, misuse, or alteration. However, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee absolute security.

In the event of a data breach that is likely to result in a risk to your rights or freedoms, we will notify affected individuals and relevant authorities as required by applicable law.

07

Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements, or to resolve disputes.

Information submitted through our contact forms is generally retained for as long as there is an active or potential business relationship, after which it will be deleted or anonymized unless a longer retention period is required by law.

08

Your Rights

Depending on your jurisdiction, you may have the right to: (1) access the personal data we hold about you; (2) request correction of inaccurate or incomplete data; (3) request deletion of your personal data; (4) object to or restrict our processing of your data; (5) request portability of your data; and (6) lodge a complaint with a supervisory authority.

California residents may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information is collected and shared, and the right to opt out of the sale of personal information. Climb does not sell personal information.

To exercise any of these rights, please contact us at privacy@climb.ai. We will respond to all verifiable requests within the timeframe required by applicable law.

09

Third-Party Links

The Site may contain links to third-party websites or services that are not operated by Climb. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites. We encourage you to review the privacy policy of every site you visit.

10

Children's Privacy

The Site is not directed to individuals under the age of 16. We do not knowingly collect personal information from children. If we become aware that a child under 16 has provided us with personal information, we will delete it promptly. If you believe we may have collected information from a child, please contact us at privacy@climb.ai.

11

Changes to This Policy

We may update this Privacy Policy from time to time. The date of the most recent revision is indicated at the top of this page. We encourage you to review this Policy periodically. Continued use of the Site following any update constitutes your acceptance of the revised Policy.

12

Contact

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at legal@climb.ai.

Last updated: May 6, 2026