ICP Privacy Policy

Climb ICP International Limited (‘ICP’) is committed to providing quality products and services to you, and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth), the General Data Protection Regulation (GDPR) for European users, and relevant U.S. privacy laws, including the California Consumer Privacy Act (CCPA). These regulations govern the way in which we collect, use, disclose, store, secure, and dispose of your Personal Information.

What is Personal Information and why do we collect it?

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include: names, addresses, email addresses, phone numbers, preferences when using our services, and other identifying details.

This Personal Information is collected in various ways, including [interviews, correspondence, by telephone, by email, via our website climbicp.com, from media and publications, from other publicly available sources, and from cookies], as well as from third parties. We do not guarantee the policies or privacy practices of authorised third parties.

We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients, and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing or via the unsubscribe link in our emails.

Use of Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website. Cookies help us analyse trends, administer the website, and track users’ movements around the site. We may also use cookies to show you advertisements based on your browsing activities and preferences.

GDPR (EU Residents): For visitors from the European Union, we only use non-essential cookies after receiving your explicit consent. You can manage or withdraw consent at any time via our cookie settings or by adjusting your browser settings.

CCPA (California Residents): You have the right to opt-out of cookies that may be used to “sell” your data under CCPA definitions. You may manage your cookie preferences via our cookie settings tool or by using the “Do Not Sell My Personal Information” link.

Australia: You can manage your cookies through your browser settings. Continued use of our website implies your consent to the use of essential cookies, while non-essential cookies require your opt-in consent.

For more information, please refer to our Cookie Policy or adjust your preferences via our website.

Children’s Privacy (COPPA in the U.S., GDPR’s Age Restrictions)

Our services are not intended for children under the age of 18 (under COPPA in the U.S.) or under the age of 18 (under GDPR in the EU). We do not knowingly collect or solicit Personal Information from children. If we become aware that we have collected Personal Information from a child without verified parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child, please contact us on the details below.

U.S. Privacy Rights (CCPA)

For residents of the United States, particularly those in California, we comply with the California Consumer Privacy Act (CCPA). If you are a California resident, you have the following rights regarding your Personal Information:

Right to Know: You may request that we disclose the specific pieces of Personal Information we have collected about you, including the categories of information, sources, and third parties to whom we may disclose it.

Right to Delete: You may request that we delete the Personal Information we have collected about you, subject to certain legal exceptions.

Right to Opt-Out of Sale: If applicable, you have the right to opt out of the sale of your Personal Information to third parties. While ICP does not sell Personal Information, we respect your right to opt-out under CCPA.

Right to Non-Discrimination: You have the right not to be discriminated against for exercising any of your CCPA rights, such as by being denied goods or services or receiving a different level of service.

To exercise your CCPA rights, please contact us at the email or address below. We will verify your identity before processing your request, and we may ask for additional information to complete the verification process.

For more information on CCPA and your rights, visit the California Attorney General’s CCPA page.

Sensitive Information

Sensitive Information, as defined in both the Privacy Act, GDPR, and CCPA, includes data such as an individual’s racial or ethnic origin, political opinions, religious beliefs, health information, and more. This information will only be used by us:

For the primary purpose for which it was obtained.

For a secondary purpose directly related to the primary purpose.

With your consent, or where required or authorised by law.

Data Retention

We will only retain your Personal Information for as long as is necessary to fulfil the purposes for which it was collected, or as required by law. For example:

Australian Privacy Act: Personal Information will be retained for a minimum of 10 years, as required by legal and business practices.

GDPR (EU): We will retain your Personal Information for no longer than is necessary for the purposes for which it was collected, unless a longer retention period is required by law.

CCPA (California Residents): Personal Information will be retained as long as necessary to provide services to you or until you request its deletion.

After the retention period, we will securely destroy your data, unless it is anonymised for statistical purposes.

Third Parties

Where reasonable and practicable, we will collect your Personal Information directly from you. In some cases, we may receive information from third parties. In such cases, we will take reasonable steps to ensure that you are aware of the information provided to us by the third party.

Disclosure of Personal Information

Your Personal Information may be disclosed in several situations, including the following:

To third parties where you have consented to the use or disclosure.

Where required or authorised by law, including compliance with GDPR and CCPA requirements.

International Transfers

If we transfer your Personal Information outside of Australia, the European Economic Area (EEA), or the United States, we will ensure it is protected with appropriate safeguards. This includes using contracts or other mechanisms approved by relevant authorities to safeguard your data.

Your Rights under GDPR and U.S. Privacy Laws

If you are located within the European Union or the United States, you have certain rights under GDPR and U.S. privacy laws, including:

Right of access: You may request access to the Personal Information we hold about you.

Right to rectification: You can request that inaccurate or incomplete Personal Information be corrected.

Right to erasure (Right to be forgotten): You may request that we delete your Personal Information, subject to legal obligations.

Right to restrict processing: You can request that we limit the processing of your Personal Information in certain circumstances.

Right to data portability: You may request that we provide your Personal Information in a structured, commonly used, and machine-readable format for transfer to another service provider.

Right to object: You can object to the processing of your Personal Information for direct marketing or for any other legitimate interest.

Right to withdraw consent: Where consent is required, you have the right to withdraw your consent at any time.

Right to Opt-Out (CCPA): For U.S. residents, particularly in California, you can opt out of the sale of your Personal Information at any time.

Your Personal Information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country (for example, transferring data from the European Economic Area (EEA) to Australia or the U.S.).

If we transfer your Personal Information outside of the EEA, we ensure that it is protected by appropriate safeguards, such as entering into the European Commission’s Standard Contractual Clauses (SCCs), which are designed to protect your privacy and secure your Personal Information.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse, loss, and unauthorised access, modification, or disclosure. We will take reasonable steps to ensure the security of your data in line with Australian, European, and U.S. regulations.

When your Personal Information is no longer required, we will take reasonable steps to destroy or permanently de-identify it. Most Personal Information is stored in client files, which we are required to keep for a minimum of 10 years.

Data Breaches

In the event of a data breach, ICP will comply with Australian, GDPR, and U.S. requirements, including notifying affected individuals and relevant authorities where required.

Access to your Personal Information

You have the right to request access to the Personal Information we hold about you. Please contact us in writing if you wish to make such a request.

We do not charge a fee for your access request, but we may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information, we may require proof of identification before releasing the requested information.

Maintaining the Quality of your Personal Information

It is important to us that your Personal Information is up to date. We will take reasonable steps to ensure that your Personal Information is accurate, complete, and up to date. If you find that the information we have is not up to date or is inaccurate, please contact us as soon as possible so we can update our records and ensure that we can continue to provide quality services.

Policy Updates

This Privacy Policy may change from time to time and will be available on our website.

Complaints and Enquiries

If you have any queries, concerns, or complaints regarding our Privacy Policy, or if you would like to exercise your rights under GDPR, CCPA, or other privacy regulations, please contact us at:

If you believe that we have not adhered to this Privacy Policy or have violated your privacy rights, you may contact us directly using the details below. Additionally, if you are unsatisfied with our response, you have the right to lodge a complaint with a relevant supervisory authority:

Australia: The Office of the Australian Information Commissioner (OAIC), www.oaic.gov.au

European Union (GDPR): You can contact your local data protection authority within the European Union.

United States (CCPA): You may contact the California Attorney General’s Office via their website, www.oag.ca.gov.

Climb ICP International Limited International Limited

Email: [email protected]

Billing address: 1/435 St Paul’s Tce, Fortitude Valley, QLD Australia 4006