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PRIVACY POLICY

Last updated: June 11, 2025

1. Who we are
Clift Climbing Kft. ("Company," "Clift," "we," "our," or "us") is the data controller responsible for your personal data. We are committed to protecting your privacy and processing your personal data in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and applicable Hungarian data-protection law.

  • Registered company: Clift Climbing Kft.

  • Registered address: Üllői út 55., 1091 Budapest, Hungary

  • Company registration number (Cégjegyzékszám): 01-09-370447

  • VAT number: 27985508-2-43

  • Email (privacy contact): support@cliftclimbing.com

 
This Privacy Policy explains how we collect, use, share and safeguard your personal data when you use:
 

  • our website (cliftclimbing.com);

  • our mobile application ("Clift Climber", the "App"); and

  • our Clift Interactive systems, including Clift Interactive (Interactive Wall), Clift Sentry and Clift Track

 
(together, the "Services").
 
2. What personal data we collect

Category
Examples
When collected
Account / identity data
Name, email address, username, year of birth
Account creation and use of the Services
Usage data
Climbing routes/problems completed, grades, dates and times of activity, performance metrics, in-app interactions
While you use the App and Interactive systems
Device & log data
Device IP address, device name, operating system version, app version/configuration, crash and error logs, timestamps
Automatically, especially on errors
Cookies & similar technologies
Session, preference and security cookies; analytics identifiers
When you visit the website (see Section 8)
Communications
Emails and messages you send us, support requests, newsletter sign-up
When you contact us or subscribe

We only collect data that is necessary for the purposes described below.

3. Why we use your data and our legal bases (GDPR Art. 6)
We process your personal data only where we have a lawful basis to do so:

Purpose
Legal basis
Creating and managing your account; providing the App and Interactive systems
Performance of a contract (Art. 6(1)(b))
Recording and displaying your climbing activity and progress
Performance of a contract (Art. 6(1)(b))
Sending service/administrative messages (e.g. security, account, important changes)
Performance of a contract / Legitimate interests (Art. 6(1)(b)/(f))
Securing the Services and preventing fraud or abuse
Legitimate interests (Art. 6(1)(f))
Analysing usage to improve and develop the Services
Legitimate interests (Art. 6(1)(f)) - and consent where analytics cookies are used
Sending newsletters and marketing
Consent (Art. 6(1)(a))
Non-essential cookies and tracking
Consent (Art. 6(1)(a))
Complying with legal obligations and responding to lawful requests
Legal obligation (Art. 6(1)(c))

Where we rely on legitimate interests, we have assessed that those interests are not overridden by your rights. You can ask us about this assessment at any time.


4. Who we share your data with
We do not sell or rent your personal data. We share it only with:
 
Service providers (processors) who help us run the Services under contract and confidentiality obligations:
 

 
Other recipients:
 

  • Legal authorities - where required by law or to establish, exercise or defend legal claims, or to protect the rights, safety and property of Clift, our users or others.

  • Business transfers - in connection with a merger, acquisition, financing or sale of assets, in which case we will require the recipient to honour this Privacy Policy and notify you of any change of controller.

 
 
5. International data transfers (GDPR Arts. 44-46)
Some of our processors are located outside the European Economic Area (EEA), including in the United States. Where we transfer your personal data outside the EEA, we ensure an adequate level of protection through one or more of the following safeguards:
 

  • transfer to a country covered by a European Commission adequacy decision;

  • the EU-U.S. Data Privacy Framework (for certified US providers); and/or

  • the European Commission's Standard Contractual Clauses (SCCs), together with supplementary measures where needed.

 
You can request a copy of the relevant safeguard by emailing support@cliftclimbing.com.
 
 
6. How long we keep your data (retention)
We keep personal data only for as long as necessary for the purposes set out above, then delete or anonymise it.

Data
Retention
Account & profile data
For the life of your account, then deleted within 30 days of account closure
Climbing/usage data
While your account is active, or anonymised for analytics
Log & crash data
Up to 12 months
Marketing / newsletter data
Until you unsubscribe or withdraw consent
Support communications
24 months
Data we must keep by law (e.g. accounting)
For the statutory retention period

7. Your rights (GDPR Arts. 7, 15–22, 77)
Subject to the conditions in the GDPR, you have the right to:
 

  • Access the personal data we hold about you;

  • Rectify inaccurate or incomplete data;

  • Erase your data ("right to be forgotten");

  • Restrict or object to our processing, including objecting to direct marketing at any time;

  • Data portability - receive your data in a structured, machine-readable format and have it transferred where technically feasible;

  • Withdraw consent at any time, where we rely on consent (this does not affect processing carried out before withdrawal);

  • Not be subject to automated decision-making that produces legal or similarly significant effects (we do not carry out such automated decision-making or profiling - see Section 10).

 
To exercise any of these rights, email support@cliftclimbing.com. We will respond within one month as required by the GDPR. There is normally no charge.
 
Right to complain: If you believe we have not handled your data properly, you may lodge a complaint with the Hungarian supervisory authority:
 
Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH) Address: 1055 Budapest, Falk Miksa utca 9-11, Hungary Website: https://naih.hu · Email: ugyfelszolgalat@naih.hu
 
You may also complain to the supervisory authority in your EU country of residence.
 
 
8. Cookies and similar technologies
When you visit our website we use cookies and similar technologies. Essential cookies (needed for security and basic functionality) are always active. Non-essential cookies (e.g. preference and analytics cookies) are only set after you give consent through our cookie consent banner.
 
You can accept, reject or change your cookie choices at any time using the cookie settings available on the website. Most browsers also let you block or delete cookies.
 
 
9. Children's privacy
The Services are intended for users aged 16 and over (see also our Terms of Use). The age of digital consent in Hungary is 16. If you are under this age, you may use the Services only with the consent and supervision of a parent or guardian, and we will only process your data on that basis. We do not knowingly collect personal data from children below the applicable age of consent without verifiable parental consent. If you believe a child has provided us data without such consent, contact us at support@cliftclimbing.com and we will delete it.
 
 
10. Automated decision-making and profiling
We do not make decisions based solely on automated processing (including profiling) that produce legal effects concerning you or similarly significantly affect you.
 
 
11. Security
We implement appropriate technical and organisational measures to protect your personal data, including encryption in transit and at rest, access controls and authentication, and use of providers that maintain recognised security standards. No method of transmission or storage is completely secure, but we work to protect your data and review our measures regularly.
 
 
12. Data breaches
If a personal data breach is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority within 72 hours where required, and we will inform you without undue delay where the breach is likely to result in a high risk to you, in line with GDPR Arts. 33–34.
 
 
13. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. We will post the updated version on our website and update the "Last updated" date above. For significant changes we will provide a more prominent notice (e.g. by email or in-app). Your continued use of the Services after an update constitutes acceptance of the revised policy where permitted by law.
 
 
14. Contact us
Questions or requests about this Privacy Policy or your data:
Clift Climbing Kft. Email: support@cliftclimbing.com Address: Üllői út 55., 1091 Budapest, Hungary

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