Privacy Policy

Effective Date: May 25, 2018

We are (“us,” “we,” “our” or “99Boulders”) committed to respecting the privacy rights of visitors and users of 99Boulders.com (“Site”). We created this Privacy Policy (this “Policy”) to explain what information we collect from you, how we secure that information, and under what conditions we share your information with others. This Policy is only applicable to this Site, and not to any other website you may be able to access from this Site.

99Boulders is the data controller and we are responsible for your personal data.

Contact Details

Our full contact details are:

Full name of legal entity: Alexander Thomas Beale

Email address: alex /at/ 99boulders /dot/ com

Mailing address: 2550 Akers Mill Rd SE, Apt T5, Atlanta, GA 30339, USA

1. NOTICE CONCERNING CHILDREN.

Any website “directed at children under 13” must undertake certain compliance steps pursuant to the Children’s Online Privacy Protection Act [15 U.S. Code § 6502] and COPPA Rule [16 C.F.R Part 312]. This Site is directed at adults, not children. Please contact us immediately if you have knowledge of a child under 13 using the Site.

By providing us with your data, you warrant to us that you are over 13 years of age.

2. WHAT DATA WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymized data.

We may process the following categories of personal data about you:

  • Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. Mostly this includes your name and email address when you send us a message through our contact form. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. For EU residents, our lawful ground for this processing is consent.
  • Technical Data that includes data about your use of our website and online services such as details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system, Google Analytics. We process this data to analyse your use of our website, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our content and advertising. For EU residents, our lawful ground for this processing is consent or our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
  • Marketing Data that includes data about your preferences in receiving marketing from us and our third party software providers and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. For EU residents, our lawful ground for this processing is consent.

We may use User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook ads or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please contact us. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We do not carry out automated decision making or any type of automated profiling.

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive Data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. We do not collect any information about criminal convictions and offences.

3. HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. For more details about this please see our Cookie Policy.

We may receive data from third parties such as Cloudflare (our CDN provider), analytics providers such as Google based in the US, advertising networks such as Facebook and Mediavine based in the US, search information providers such as Google based in the US, affiliate partners such as Amazon and AvantLink based in the US, and marketing software providers such as Sumo and OneSignal based in the US.

4. MARKETING COMMUNICATIONS

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations, etc.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:

  • Service providers who provide IT and system administration services
  • Professional advisers including lawyers, bankers, auditors, and insurers
  • Government bodies that require us to report processing activities
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

  • We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
  • If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
  • Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

7. DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

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

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

In some circumstances we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please contact us.

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 or refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

10. THIRD-PARTY LINKS

This website may include links to third-party websites, plugins, 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 policy of every website you visit.

11. 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. For more information about the cookies we use, please see our Cookie Policy.