Privacy Policy
Summit Privacy Resources, LLC ("Summit," "we," "us") is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose Personally Identifiable Information (as defined below). This Privacy Policy (the "Policy") describes our practices in connection with Personally Identifiable Information that we collect through this website (the "Site") and by other means. This Policy does not address the collection, use or disclosure of information by any of our affiliates or by third parties.
By using the Site, you agree to the terms and conditions of this Policy. If you do not agree to the terms and conditions of this Policy, please do not use the Site. We reserve the right to change this Policy without prior notice. You can determine when this Policy was last revised by referring to the "LAST UPDATED" legend at the top of this page. Any changes to our Policy will become effective upon our posting of the revised Policy on the Site. Use of the Site following such changes constitutes your acceptance of the revised Policy then in effect.
1. What Types of Information Does Summit Collect From Me?
Summit gathers three basic types of information through the Site: "Personally Identifiable Information" (or "PII"), "Non-Personally Identifiable Information" (or "Non-PII") and “IP Addresses”. Personally Identifiable Information is information that identifies you as an individual. Non-Personally Identifiable Information is aggregated information, demographic information and any other information that does not reveal your specific identity. An IP Address is the Internet Protocol address of the computer that you are using.
a. Personally Identifiable Information. In order for you to take advantage of particular opportunities provided through the Site (for example, to sign up for newsletters or access the Site), we may require that you furnish PII. We collect PII about you through the Site, such as your name, postal address, telephone number, e-mail address, only when you voluntarily provide it to us.
b. Non-Personally Identifiable Information. When you visit and interact with the Site, Summit and third parties with whom Summit has contracted to provide services to Summit may collect Non-PII. Non-PII is generally collected through the Site from four different sources: environmental variables, cookies, pixel tags and other similar technologies and information that you voluntarily provide.
i. Environmental Variables. We and our service providers may also collect certain environmental variables, such as your MAC address, computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version. These environmental variables are collected by most browsers, and can be used to optimize your experience on the Site.
ii. Cookies. We and our service providers may use “cookies” on the Site. Cookies are data that a web server transfers to an individual's computer for recordkeeping and other purposes. We use cookies and other technologies to, among other things, better serve you with more tailored information and facilitate your ongoing access to and use of our Site. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular web site, to your computer. To learn more about cookies, please visit http://www.allaboutcookies.org/.
iii. Pixel Tags. We and our service providers may also use so-called "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some Site pages and HTML-formatted e-mail messages to, among other things, track the actions of Site users and e-mail recipients, to determine the success of marketing campaigns and to compile aggregate statistics about Site usage and response rates.
iv. Information That You Voluntarily Provide. Summit also collects Non-PII (e.g., your geographic location) when you voluntarily provide such information to us. Such information constitutes Non-PII because, unless combined with PII, it does not personally identify you or any other user. Additionally, we may aggregate PII in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using PII to calculate the percentage of our users who have a particular telephone area code. Such aggregate information is considered Non-PII for purposes of this Policy.
c. IP Addresses. When you visit and interact with the Site, Summit and third parties with whom Summit has contracted to provide services to Summit may collect IP Addresses. Your Internet Protocol (IP) address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited.
2. How Does Summit Use Information Collected From Me?
a. Personally Identifiable Information. We may use PII about you in the following ways:
i. Fulfillment of Requests. Summit may use PII about you to fulfill provide you with access to the database, respond to your questions, or send you email updates that you have requested
ii. Administrative Communications. From time to time, in our sole discretion, we may use PII about you to send you important information regarding the Site, changes to our terms, conditions, and policies, or other administrative matters. Because this information may be important to your use of the Site, you may not opt-out of receiving such communications.
iii. Other Communications. If you affirmatively opt-in, Summit and the Affiliated Entities may use PII about you to inform you of products, programs, services and promotions that we believe may be of interest to you.
iv. Compliance With Our Terms and Conditions. We also use PII to help us to identify unauthorized uses of our databases, and to take action as appropriate.
v. Internal Business Purposes. We may also use PII about you for our internal business purposes, such as data analysis, audits, developing new products, enhancing our website, improving our services, identifying usage trends, determining the effectiveness of our promotional campaigns, and ensuring that only authorized users are accessing the database.
b. Non-Personally Identifiable Information. Because Non-PII does not personally identify you, we may use such information for any purpose. In addition, we reserve the right to share such Non PII, which does not personally identify you, with Affiliated Entities and other third parties, for any purpose.
In some instances, we may combine Non-PII with PII (such as embedding e-mail addresses in cookies). If we do combine any Non-PII with PII, the combined information will be treated by us as PII hereunder as long as it is so combined (see Section 2.a above).
c. IP Addresses. We use IP addresses for purposes such as calculating Site usage levels, helping diagnose server problems, identifying unauthorized use of our database, and administering the Site. We may disclose your IP address to our third party service providers to enable them to provide services. We also use and disclose IP addresses for all the purposes set forth in Section 2(a) above and Section 3 below. Please note that we treat IP Addresses, server log files and related information as Non-PII, except where we are required to do otherwise under applicable law.
3. How Is Personally Identifiable Information Disclosed?
a. Affiliated Entities. We may share PII with our Affiliated Entities so that they may use PII for the purposes of maintaining the Site and the services provided on the Site. Summit is the party responsible for the management of the jointly-used PII.
b. Third Party Service Providers. We work with third parties who provide services such as data analysis, payment processing, order fulfillment, infrastructure provision, IT services, web hosting, customer service, and e-mail delivery services.
c. Assignment. In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Summit's business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings), we may transfer any and all information that we collect from site users to an Affiliated Entity or a third party.
d. Law enforcement; emergencies; compliance. We may disclose PII about you to others as we believe to be appropriate (a) under applicable law including laws outside your country of residence; (b) to comply with legal process (c) to respond to requests from public or government authorities including public or government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any Affiliated Entities; (f) to protect the rights, privacy, safety or property of Summit, the Affiliated Entities, you or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain.
4. Other Important Notices Regarding Our Privacy Practices.
a. Third Party Sites. The Site may contain links to third party web sites. These linked sites (including without limitation the web sites of Affiliated Entities) are not under Summit's control and we are not responsible for the privacy practices or the contents of any such linked site, or any link contained in any linked site. We provide such links only as a convenience, and the inclusion of a link on the Site does not imply endorsement of the linked site by Summit or any Affiliated Entities. If you provide any PII through any such third party web site, your transaction will occur on such third party's web site (not the Site) and the PII you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES, INCLUDING, WITHOUT LIMITATION, THE AFFILIATED ENTITIES.
b. Security. We use reasonable organizational, technical and administrative measures to protect PII under our control. Security measures and tools, such as firewalls, are in place to help protect against the loss, misuse and alteration of the information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Please do not send us sensitive information through email. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us in accordance with Section 4.k ("Contacting Us,") below (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem).
c. Opt-Out. If you change your mind, and no longer wish to receive marketing-related e-mails from us on a going-forward basis, you may opt-out of receiving such marketing-related e-mails by contacting us at the address listed below in “Contacting US.” We will endeavor to comply with your request as soon as reasonably practicable.
d. Changing or Suppressing PII. If you would like to review, correct, update, suppress or otherwise limit our use of the PII about you that has been previously provided to us through the Site, you may contact us by contacting us at the address listed below in “Contacting US.” For your protection, we will only implement such requests with respect to the PII associated with the particular e-mail address that you use to send us your request, and we may need to verify your identity before implementing your request.
In each event, you must clearly indicate the information that you wish to have changed, clearly indicate that you wish to have your PII suppressed from our database or clearly indicate the limitations you wish to put on our use of your PII. We will endeavor to comply with your request as soon as reasonably practicable. We may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed therefrom. Finally, we are not responsible for removing or suppressing information from the databases of third parties with whom we have already shared your PII, or limiting their use of your PII.
e. Retention Period. We will retain your PII for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required by law.
f. Note Regarding the Use of the Site by Children: The Site is not directed to individuals under the age of thirteen (13), and we request that such individuals do not provide PII through the Site.
g. Jurisdictional Issues. The Site is controlled and operated by Summit from the United States, and is not intended to subject Summit or any Affiliated Entity to the laws or jurisdiction of any state, country or territory other than that of the United States. Summit does not represent or warrant that the Site, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. Summit may limit the Site's availability, in whole or in part, to any person, geographic area or jurisdiction, and/or at any time and in Summit’s sole discretion.
h. Contacting Us. If you have any questions regarding this Policy, please contact us by e-mail at subscriberservices@summitprivacy.com, or please write to the following address: Summit Privacy Resources, LLC, 425 Market Street, Suite 3200, San Francisco, California, 94105-2482, USA.