EFFECTIVE DATE: December 21, 2016
Information We Collect:
When Subscribers interact with us through the Site, we may collect Personal Data and other information, as further described below:
If you choose to use our referral service to tell a person about our site, we will ask you for their email address. We will automatically send them a one-time email inviting him or her to visit the site. Summitas LLC stores this information for the sole purpose of sending this one-time email. Your friend may decline their invitation via Decline button in the email to remove their information from our system.
Summitas, LLC collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. Summitas, LLC works with its Clients to help them provide notice to their customers concerning, the purpose for which personal information is collected.
We collect information for our clients, if you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the client that you interact with directly.
Digital Vault Storage: Subscribers will have access to a digital vault that may be used for storing various documents and other information as further described at www.summitas.com/info/security ("Security and Privacy"). The Digital Vault is protected by encryption technology. When uploading documents to store in the Digital Vault, Subscribers are required to select one of the following options regarding the recovery of the passphrase used to protect access to the Digital Vault: (i) the Subscriber may elect to keep the passphrase totally private and not even Summitas will have access to the passphrase; (ii) Summitas will store an encrypted version of the passphrase; and (iii) Summitas will auto-generate a passphrase so that the Subscriber never needs to do so. In addition to selecting an option at the time of upload, Subscribers may also set a default encryption option by editing their profile in My Account. Of these available options for passphrase recovery, option (i) is the most secure. HOWEVER, PLEASE BE AWARE THAT YOU ARE RESPONSIBLE FOR THE OPTION YOU SELECT AND THE RESULTS OF THAT SELECTION. SUMMITAS SHALL NOT HAVE ANY RESPONSIBILITY FOR THE OPTION THAT YOU SELECT AND/OR THE RESULTS THEREOF. BY WAY OF EXAMPLE ONLY AND WITHOUT LIMITING THE FOREGOING, PLEASE NOTE THAT IF YOU SELECT OPTION (I) AND YOU FORGET YOUR PASSPHRASE, THE INFORMATION STORED IN YOUR DIGITAL VAULT WILL NOT BE RECOVERABLE. SIMILARLY, IF YOU OBTAIN A PASSPHRASE AND/OR LOGIN CREDENTIALS AND FAIL TO PROTECT THIS INFORMATION, SUMMITAS CANNOT AND WILL NOT BE LIABLE FOR ANY ACCESS TO YOUR DIGITAL VAULT BY A THIRD PARTY. IN ANY EVENT, SUMMITAS CANNOT AND WILL NOT BE LIABLE FOR ANY LOSSES AND/OR DAMAGES RELATED TO YOUR USE OF AND/OR INABILITY TO USE THE DIGITAL VAULT, INCLUDING, WITHOUT LIMITATION, YOUR INABILITY TO ACCESS AND RECOVER INFORMATION STORED IN THE DIGITAL VAULT. YOU EXPRESSLY ACKNOWLEDGE AND AGREE TO THESE TERMS.
Non-Identifiable Data: When you interact with Summitas through the Site, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Summitas may store such information itself or such information may be included in databases owned and maintained by Summitas affiliates, agents or service providers. This Site may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our Subscriber's Internet service providers. It is important to note that no Personal Data is available or used in this process.
We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you.
As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
Aggregated Personal Data: In an ongoing effort to better understand and serve our Subscribers, Summitas often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Summitas may share this aggregated data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Summitas may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
Our Use of Your Personal Data and Other Information:
Service Access Provision and Monitoring: We may use your Personal Data to provide you with access to and use of the Services and to monitor your use of the Services.
On-going Service Improvements: We may also use your Personal Data and other personally non-identifiable information collected through the Site to help us improve the content and functionality of the Site, to better understand our users and to improve the Services.
User Communications and Requests: If you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem. We may use Personal Data provided to us to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each communication we send you will contain instructions permitting you to "opt-out" of receiving future communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.
Our Disclosure of Your Personal Data and Other Information:
Agents, Consultants and Related Third Parties: Summitas, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function and we will not grant them permission to use your Personal Data for their promotional purposes.
Summitas, LLC may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.
Legal Requirements: We reserve the right to disclose your Personal Data as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Site.
You can use the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.
Links to Other Web Sites:
The profile you create on our site will be publically accessible unless otherwise indicated. You may change the privacy settings of your profile through your account portal.
Summitas takes reasonable steps to protect the Personal Data provided via the Site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from this Site may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Data to Summitas via the Internet.
Information stored in Digital Vaults will be protected by encryption. In order to implement this feature, Summitas will provide Subscribers with a downloadable applet that works with the Subscriber's web browser to encrypt and transmit documents that will be stored in the Digital Vault. You are responsible for protecting the privacy and security of your passwords. Summitas cannot and will not be responsible for any losses and/or damages resulting from your failure to protect your passwords.
The security of your Personal Data is important to us. When you enter sensitive information such as a credit card number, on our registration or order forms, we encrypt that information using transport layer security (TLS). To learn more about TLS, follow this link: http://en.wikipedia.org/wiki/Transport_Layer_Security
Summitas, LLC will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Summitas retains information for as long as a user remains a customer and thereafter, for so long as Summitas deems such information commercially useful. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Sharing of Information Using Mobile Devices
Certain of our products and services allow you to interact and share your information with others. Please consider carefully before disclosing any personal information or data that might be accessible to others.
We do not ask for, access or track any location-based information from your mobile device at any time while downloading or using our Mobile Apps or Services.
Other Terms and Conditions:
Updating/Accessing/Amending/Correcting/Deleting Personal Data:
Summitas, LLC has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, who seeks to correct, amend, delete inaccurate data or withdraw consent to further contact should direct his/her query to Summitas, LLC's Client (the data controller). If the Client requests Summitas, LLC to remove the data, we will respond to their request within 30 days.
U.S. - Swiss Safe Harbor Framework
Summitas, LLC complies with U.S. – Swiss Safe Harbor Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. Summitas, LLC has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. Information regarding the U.S. – Swiss Safe Harbor Frameworks can be found at: http://export.gov/safeharbor.
EU –U.S. Privacy Shield
Summitas, LLC participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Summitas, LLC is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework's applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce's Privacy Shield List.
Summitas, LLC is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Summitas, LLC complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Summitas, LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Summitas, LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
335 Madison Avenue
New York, New York 10017
Telephone: (877) 752-1717