Privacy Notice

Last Updated Nov 11, 2019

Introduction

FreeClimb is a cloud-based Communications Platform as a Service that provides an API that allows businesses to integrate voice and messaging services into their software applications (“FreeClimb API Services” or “Services”). FreeClimb is owned by Vail Systems, Inc. (“Vail”). This Privacy Notice applies to FreeClimb API Services, including documentation, support, and account web portals. Before you submit information through FreeClimb API Services and websites, review this Privacy Notice carefully, as by using FreeClimb API Services or submitting information through FreeClimb web portals you consent to the collection, use, and disclosure of your information as provided in this notice.

Why We Collect Data

Data collected will only be used for the following purposes:

  • To provide FreeClimb API Services
  • To send you system alert messages and maintenance notifications
  • To understand how you use the product and what areas need improvement
  • To bill you and provide you reports on your usage of the services
  • To calculate taxes
  • To authenticate account portal and API access
  • To comply with laws and regulations
  • To help us troubleshoot issues that arise
  • To address your questions
  • To provide support
  • To contact you about the account
  • To inform you about product updates, promotions, and events

What Data We Collect

  • Account data including email, account user name, account password, first name, last name, phone number, billing address, company name
  • Customer Data as defined in the FreeClimb Terms of Service
  • Device information
  • Web server access log data
  • Credit card payment information (credit card numbers are provided by you directly to our payment provider without being handled by FreeClimb)
  • Details on how you intend to use FreeClimb API Services and business requirements
  • URLs that can be invoked to communicate with customer applications
  • The IP address sending requests to FreeClimb API Services or receiving requests from FreeClimb API Services
  • Phone numbers
  • Actions performed by you while using FreeClimb API Services, including portal actions, API requests made, and FreeClimb Performance Command Language (PerCL) commands used
  • Call detail information and your end users’ telephone numbers that you pass on to us
  • FreeClimb product usage information
    How We Collect Data
    Some information, such as account information, you provide us through our portal or through a request to FreeClimb Support. We also collect some information automatically, such as product usage data, which is collected via tracking technologies, such as cookies and web beacons (to help us understand how customers are using our web portal and products so we can improve your navigation experience) and via application and system logging (to track IP address, device information, operating system, browser ID, and a risk score). Some information is collected via third parties, such as a risk score based on device and browser information collected when users sign up for the service.

When We Share Data

We may share your data for the following purposes.

  • Credit card payment information is collected by our payment processors, which share that data with us.
  • Device/browser information at the time of enrollment is shared with third-party risk assessment providers to protect our platform and its users from attacks, fraud, and other abuse.
  • Some data is shared with and received from telephony operators to the extent necessary to route and connect communications from the sender to the intended recipient. How those telephony operators handle the data is generally determined by those operators’ own policies and local regulations.
  • When necessary, we may share your address with telecommunications carriers from whom we’re requesting phone numbers for your use.
  • Some data is shared with and received from third-party fraud prevention and security service providers to protect FreeClimb customers from malicious activity.
  • To acquire an SMS short code on your behalf.
  • We may access and disclose information to law enforcement officials, including the content of communications, if: (i) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or government request; (ii) to enforce our agreements and policies; (iii) to protect the security or integrity of our services and products; (iv) to protect ourselves, our other customers, or the public from harm or illegal activities; or (v) to respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury.
  • FreeClimb may share data with its affiliated companies or third-party companies that provide and support the Services.

Security Measures

We apply appropriate security controls to protect the privacy of your data both online and offline. These measures vary based on the sensitivity of the information that we collect, process and store and the current state of technology.

Customer Data Access, Changes, and Deletion

You can access and make changes to certain account data via the account portal. You will also be able to access call detail information collected about usage of the services.

You may request deletion of your FreeClimb account and its data. You should know that deletion of your FreeClimb account will result in you permanently losing access to your account and all Customer Data to which you previously had access through your account.

Please note that certain data associated with that account may nonetheless remain on FreeClimb’s servers. For instance, call detail records and billing information will be retained. Similarly, data associated with your account that we are required by law to maintain will not be deleted. Data may also be retained in an aggregated or anonymized form that does not specifically identify you.

To request deletion of your FreeClimb account, email us at privacy@freeclimb.com. Or, if you prefer, please write to us at:

Vail Systems, Inc.
Attn: FreeClimb API Services Data Privacy
570 Lake Cook Road STE 400
Deerfield, IL 60015

Cookies and Tracking Technologies

Our site uses cookies and similar technologies to keep customers logged in and to track how customers use our portal and sites. Use of these tracking technologies enables us to provide personalized information, to remember product preferences, to keep our sites running efficiently, to help you obtain information you need and to provide a secure environment for transactions. Do-not-track signals are web browser settings that request that a web application disable its tracking of an individual user. At this time, our site does not respond to do-not-track signals and similar mechanisms.

Third Party Access

Vail uses certain trusted third parties to help us provide, improve, promote, and protect the services we provide. These third parties may access, process, or store your information to perform tasks only for the purposes we’ve authorized and we require them to provide at least the same level of protection for your information as described in this Privacy Policy. We may also share with third parties aggregated or anonymized data that does not directly identify you.

FreeClimb websites may contain links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by FreeClimb API Services and websites.

Data Protection Rights and Choices

  1. Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have specific rights with respect to their personal information, including: The right to request disclosure of FreeClimb’s data collection and sales practices in connection with the requesting consumer, including the categories of personal information Vail has collected, the source of the information, Vail’s use of the information in connection with FreeClimb API Services and, if the information was disclosed or sold to third parties, the categories of personal information disclosed or sold to third parties and the categories of third parties to whom such information was disclosed or sold;

  2. The right to request a copy of the specific personal information collected about them during the 12 months before their request (together with right #1, a “personal information request”);

  3. The right to have such information deleted (with exceptions);

  4. The right to request that their personal information not be sold to third parties, if applicable; and

  5. The right not to be discriminated against because they exercised any of the new rights.

Please note the following on personal information requests:

  1. You may only make a personal information request twice in a 12-month period;
  2. Vail will need to collect information from you to verify your identity; and
  3. Vail will respond within 45 days of receiving a personal information request.

If you would like to exercise any of these rights, please contact us at our email privacy@freeclimb.com with “Privacy Request” in the subject line. Or, if you prefer, please write to us at:

Vail Systems, Inc.
Attn: FreeClimb API Services Data Privacy
570 Lake Cook Road STE 400
Deerfield, IL 60015

Children’s Data

We do not knowingly collect any personal information directly from children under the age of 13. If we discover we have received any information from a child under the age of 13, we will take reasonable steps to delete that information as quickly as possible. If you believe we have any information from or about a child under the age of 13, please contact us at privacy@freeclimb.com.

Business Transfers

In the event of any sale, merger, reorganization, restructuring, dissolution or similar event involving our business or assets, personal data may be part of the transferred assets.

Dispute Resolution

If you have any complaints regarding our compliance with this privacy policy, you should first contact us. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this privacy policy. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please see our Terms & Conditions for further information.

Notifications About Changes to this Privacy Policy

We may update this Privacy Policy as necessary to reflect changes we make and to satisfy legal requirements.

If we decide to make changes to our privacy policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information in accordance with the privacy policy under which the information was collected.

If, however, we are going to use users’ personally identifiable information in a manner different from that stated at the time of collection we will notify users via email. However, if users have opted out of all communication with the site, or deleted/deactivated their account, then they will not be contacted.

In addition, if we make any material changes in our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on our website notifying users of the change. In some cases where we post a notice we will also email users, who have opted to receive communications from us, notifying them of the changes in our privacy practices.

Contact Us

If you have questions or concerns regarding this statement, you may send an email to privacy@freeclimb.com with “Privacy Policy Inquiry” in the subject line. Or, if you prefer, please write to us at:

Vail Systems, Inc.
Attn: FreeClimb API Services Data Privacy
570 Lake Cook Road STE 400
Deerfield, IL 60015