2.1.1 Register to use our services or apply for a reseller or credit account (through the Platform). This includes the following mandatory information: Your name, email address, phone number, the organisation you represent, identity number or passport number, and company registration number;

2.1.2 Your preferences;

2.1.3 Information about your use of the Platform;

2.1.4 The IP address of your computer or device may be used to determine your geographic location and to assist in customising your experience on the Platform;

2.1.5 Location. If you elect to use location-based features on the Platform and turn on the location services settings on your device or computer;

2.1.6 Provide your contact details to us: For example, when you access or register to use any websites, applications, or services we make available, or when you update those details; and

2.1.7 Contact us offline. For example, by telephone, fax, SMS, email, or post

4.1.1 Provide the services you request and features of the Platform: We use the personal information you give us to provide the services you request, including –

4.1.1.1 to create and set up your user account;

4.1.1.2 if you use the Platform to manage your reseller account, submit credit applications or process orders, we will collect and store this information so that you can review it on the Platform and track your account activity.

4.1.2 Communicate information about our products and services and for other promotional purposes: With your prior consent, or as otherwise permitted by applicable Data Privacy Law, we will use your personal information to provide information that we believe is of interest to you, including marketing communications and news concerning our services, products, vendor promotions, events and other promotions. Such consent will be collected by means of a separate, voluntary opt-in tick box on the relevant form or registration page, which is distinct from your acceptance of this Privacy Policy and our Terms and Conditions. This consent mechanism will clearly describe the nature of the communications to which you are consenting. You can opt-out at any time after you have given your consent to such communications by contacting us using the details set out in paragraph 12 below or by clicking “unsubscribe” in any marketing communication.

4.1.3 Customer service communications: We use your personal information to manage our relationship with you as our customer and to improve our services and enhance your experience with us.

4.1.4 Administrative or legal purposes: We use your personal information to operate our business, including for statistical and marketing analysis, systems testing and to diagnose technical and service problems, maintenance and development of our Platform, compliance with the Financial Intelligence Centre Act, 2001 (Act No. 38 of 2001) (“FICA”) (including customer due diligence, identity verification and ongoing monitoring), or in order to deal with a dispute or claim. We may also perform data analysis based on the data we collect from you for statistical and marketing analysis purposes.

4.1.5 Security, health, administrative, crime prevention/detection and legal purposes: We may use your personal information to verify your information and identity, and to protect against, identify and prevent fraud and other unlawful activities. We may also share your personal information with government authorities or enforcement bodies for compliance with legal requirements, or as otherwise required or permitted by applicable Data Privacy Law.

4.1.6 Other purposes: We may also use your personal information in other ways, and where we do so, we will provide specific notice at the time of collection and obtain your consent unless otherwise permitted by applicable Data Privacy Law.

4.2.1 to carry out our obligations under the contract we have with you;

4.2.2 to comply with a legal obligation;

4.2.3 if it is in our legitimate interests to do so as a business (e.g. for administrative purposes and to improve the functionality of our Platform); and

4.2.4 where you have consented to our using your personal information (e.g. to process your special personal information and for direct marketing related uses).

6.1.1 other companies and members within the Climb Global Solutions group, including Climb Global Solutions, Inc. and Climb Global Solutions Ltd;

6.1.2 our trusted third party service providers with whom we contract to assist us in providing services to you, including cloud infrastructure and hosting providers (such as Microsoft Azure), credit insurers, and other service providers engaged from time to time;

6.1.3 These service providers process your personal information strictly in accordance with our instructions and for the purpose for which such personal information has been disclosed to them. They will always be under obligation to protect your personal information on terms that provide the same or equivalent protection as set out in this Privacy Policy;

6.1.4 only where you have provided consent, other companies, contractors or agents in connection with our marketing efforts, or marketing platform providers, including selected vendor partners for joint promotional activities and co-branded or co-sponsored campaigns;

6.1.5 government authorities, law enforcement bodies and regulators for compliance with legal requirements, or where otherwise required by applicable Data Privacy Law; and

6.1.6 our legal and other professional advisers in order to enforce our legal rights in relation to our contract with you.

8.1.1 Request information. You may request information about whether we hold personal information about you, where we got your personal information from, what personal information is held or being used; why we are holding/using it i.e. the purpose; and whether or not the supply of such information is voluntary or mandatory (as well as the consequences if you fail to provide personal information)

8.1.2 Request access to your personal information. This allows you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;

8.1.3 Right to rectification of the personal information that we hold about you. If you believe that the personal information we have is inaccurate or incorrect, you have the right to ask us to correct that personal information.

8.1.4 Request erasure of your personal information. You have the right to ask us to delete or remove your personal information from our records where there is no good reason for us continuing to process it.

8.1.5 Right to object to processing of your personal information. 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, you have the right to object to the processing of your personal information for that purpose;

8.1.6 Right to portability. You have the right to receive your personal information in a portable format.

8.1.7 Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes to which you originally agreed, unless we have another proper and legitimate basis for doing so;

8.1.8 Right to complain: You have the right to complain and lodge a complaint with–

8.1.8.1 If you are in South Africa, the Information Regulator (South Africa) whose details are –

9.1.1 We may transfer your personal information outside the Republic of South Africa, including to the United States of America, where your personal information may be stored on cloud-based systems hosted by Microsoft Azure. Such transfers will only take place where adequate safeguards are in place to protect your personal information, in accordance with section 72 of POPIA.

9.1.2 Where your personal information is transferred, we take measures to protect your personal information as described in this Privacy Policy and in compliance with applicable Data Privacy Law. We also require all third party data recipients (including our service providers) to process your information in a secure manner and in accordance with Data Privacy Law.

9.3.1 We will not retain your personal information for longer than is necessary to fulfil the purposes for which it is being processed. However, in terms of FICA, records obtained during the customer due diligence process must be retained for a minimum period of five (5) years from the date on which the business relationship is terminated or the relevant transaction is concluded. Personal information will not be retained for longer than is required by applicable law.

9.3.2 When we no longer need your personal information, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal information that we use, and if we can de-identify your personal information so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.