Privacy Policy
Effective: January 1, 2024
This Privacy Policy describes how Summit collects, uses and discloses information, and what choices you have with respect to the information.
Updates in this version of the Privacy Policy reflect changes in data protection law. In addition, we have worked to make the Privacy Policy clearer and more understandable.
When we refer to “Summit”, we mean the Summit entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.
Applicability Of This Privacy Policy
This Privacy Policy applies to Summit’s online workplace productivity tools and platform, including the associated Summit mobile and desktop applications (collectively, the “Services”), summitwealth.io and other Summit websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Summit. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of Summit’s business.
A separate agreement governs delivery, access and use of the Services (the Customer “Contract”), including the processing of any calendar data, meeting data, feedback data or other content submitted through Services accounts (collectively, “Customer Data”). The organization (e.g., your employer or another entity or person) that entered into the Customer Contract (“Customer”) controls their instance of the Services (their “Customer Account”) and any associated Customer Data. If you have any questions about specific Customer Account settings and privacy practices, please contact the Customer whose Customer Account you use.
Information We Collect And Receive
Summit may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:
- Customer Data. Customers or individuals granted access to a Customer Account by a Customer (“Authorized Users”) submit Customer Data to Summit when using the Services.
- Other Information. Summit also collects, processes, generates and/or receives Other Information:
- Customer Account Information. To create or update a Customer Account, you or your Customer (e.g., your employer) supply Summit with an email address, phone number, password, domain and/or similar account details.
- Usage Information.
- Services Metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users work.
- Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
- Device information. Summit collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
- Location information. We receive information from you, Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. Summit may also collect location information from devices in accordance with the consent process provided by your device.
- Cookie Information. Summit uses cookies and similar technologies in our Websites and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services. For more details about how we use these technologies, please see our Cookie Policy.
- Contact Information. In accordance with the consent process provided by your device, any contact information that an Authorized User chooses to import (such as an address book from a device) is collected when using the Services.
- Third Party Data. Summit may receive data about organizations, industries, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to zip codes. Or it might be more specific: for example, how well an online marketing or email campaign performed.
- Additional Information Provided to Summit. We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with Summit.
Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Customer Account setup details, is not provided, we may be unable to provide the Services.
How We Use Information
Summit uses Other Information in furtherance of our legitimate interests in operating our Services, Websites, and business. More specifically, Summit uses Other Information:
- To provide, update, maintain and protect our Services, Websites, and business. This includes the use of Other Information to support the delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Authorized User’s request.
- As required by applicable law, legal process or regulation.
- To communicate with you by responding to your requests, comments, and questions. If you contact us, we may use your Other Information to respond.
- To develop and provide search, learning and productivity tools, and additional features. Summit tries to make the Services as useful as possible for Customer and Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, make Services suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience or create new productivity features and products.
- To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt-out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Summit. These are marketing messages so you can control whether you receive them.
- For account management and other administrative matters. Summit may need to contact you for account management and similar reasons.
- To investigate and help prevent security issues and abuse.
If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, Summit may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”
Data Retention
Summit will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Depending on the Services plan, Customer may be able to customize its retention settings and apply those customized settings at the Customer Account level. The deletion of Customer Data and other use of the Services by Customer may result in the deletion and/or de-identification of certain associated Other Information. For more detail, please contact Customer. Summit may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Summit to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
How We Share And Disclose Information
This section describes how Summit may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Summit does not control how they choose to share or disclose Information.
- Customer’s Instructions. Summit will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.
- Displaying the Services. When an Authorized User submits Other Information, it may be displayed to other Authorized Users in the Customer Account. As an example, an Authorized User’s calendar data may be shared within the Customer Account. Other Information, such as an Authorized User’s profile Information, may be shared, subject to the policies and practices of the other Customer Account(s).
- Customer Access. Owners, administrators, Authorized Users, and other Customer representatives and personnel may be able to access, modify or restrict access to Other Information.
- Third-Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services.
- During a Change to Summit’s Business. If Summit engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Summit’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
- Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective Summit customer the average amount of time spent within a typical Customer Account.
- To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.
- To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of Summit or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
- With Consent. Summit may share Other Information with third parties when we have consent to do so.
Security
Summit takes the security of data very seriously. Summit works hard to protect Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology. Given the nature of communications and information processing technology, Summit cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others.
Age Limitations
To the extent prohibited by applicable law, Summit does not allow the use of our Services and Websites by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with personal data, please contact us at info@summitwealth.io and we will take steps to delete such information.
Changes To This Privacy Policy
Summit may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, Summit will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.
Identifying The Data Controller And Processor
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. In general, Summit is the processor of Customer Data and the controller of Other Information.
Your Rights
Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact Customer for additional access and assistance.
To the extent that Summit’s processing of your Personal Data is subject to the General Data Protection Regulation, Summit relies on its legitimate interests, described above, to process your data. Summit may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Summit’s use of your Personal Data for this purpose at any time.
Contacting Summit
Please feel free to contact Summit if you have any questions about this Privacy Policy or Summit’s practices, or if you are seeking to exercise any of your statutory rights. You may contact us at info@summitwealth.io or at our mailing address below:
Summit Wealth Systems, Inc.
86 Graham Street
Suite 120
San Francisco, CA, 94129
United States