Privacy Policy

TRUSTe

EFFECTIVE DATE: December 21, 2016

Our Policy:
Welcome to Summitas, a web site and service (the "Site") operated by Summitas, LLC ("Summitas", "we", "us" and/or "our"). This Site is operated by Summitas and has been created to provide those who subscribe to our Site (each, a "Subscriber", also "you" and "your") with access to and use of the services offered by Summitas from time to time including a digital vault, collaboration tools, email and content regarding wealth management, philanthropy and lifestyle issues (the "Services"). This Privacy Policy sets forth our policy with respect to personally identifiable data ("Personal Data") and other information that is collected from Subscribers of our website, https://www.summitas.com and mobile application. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged Summitas, LLC.

Information We Collect:
When Subscribers interact with us through the Site, we may collect Personal Data and other information, as further described below:

Personal Data That You Provide Through the Site and Mobile Application: We collect Personal Data when a Subscriber voluntarily provides such information, such as when a Subscriber registers for the Site, contacts us with inquiries, responds to one of our surveys, or uses certain Services made available through the Site. Subscribers will be asked to provide their name, email address, phone number, postal address and payment information such as credit card number. Wherever Summitas collects Personal Data, we make an effort to provide a link to this Privacy Policy.   

 "Member Invitation"

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.

Publicly Displayed Information: Subscribers supply their email address and must create a Login ID, Password, and public Display Name (used as an alias on the Site). The public Display Name is to protect Subscribers' identities from other users of the Site. Notwithstanding the foregoing, Summitas is a subscription only website and therefore any Personal Data or Publicly Displayed information will only be available to paying subscribers and in accordance with this Privacy Policy. Accordingly, Subscribers are advised to use a non-identifiable pseudonym as the Display Name. Summitas cannot and shall not be responsible for protecting the privacy and/or security of any Personal Data Subscribers choose to make publicly available through the Site, including, but not limited to, any information made available via the Display Name, the Site's messaging service, comments in blogs and forums, and/or through information shared in the digital office.

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.

Consent: By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to this Site, you acknowledge and agree that such Personal Data may be stored on servers operated by Summitas and the authorized third parties referred to herein located in the United States.

Other Information:

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.

Log Files

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.

Tracking technologies:

We Summitas, LLC and our partners use technologies such as cookies or similar technologies to analyze trends, administer the website, track users' movements around the website, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level.

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:

Summitas uses the Personal Data you provide in a manner that is consistent with this Privacy Policy and the disclosures and other notices posted on the Site. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For example, we will use your registration information to register you as a subscriber to the service and we will use your payment information to process your payments.  In addition, we may use Personal Data as described below:

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.

Additional Uses: If we intend on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

Our Disclosure of Your Personal Data and Other Information:

Summitas is not in the business of selling your Personal Data. Except as otherwise disclosed in this Privacy Policy, we do not share, sell, rent or trade Personal Data collected through the Site with third parties. We consider this information to be a vital part of our relationship with you. If you do not want us to share your personal information with these companies, contact us here.There are, however, certain circumstances in which we may share your Personal Data with certain third parties as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of a business transfer as consistent with this Privacy Policy. You will be notified of any such change in ownership or control of your Personal Data via email or through the posting of a notice on the Site.

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.

Your Choices:
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.

Exclusions:
This Privacy Policy does not apply to any Personal Data collected by Summitas other than Personal Data collected through the Site. This Privacy Policy does not apply to documents, data and other information you elect to store in your Digital Vault. This Privacy Policy shall not apply to any unsolicited information you provide to Summitas through this Site or through any other means. This includes, but is not limited to, information posted to any public areas of the Site, such as blogs and/or forums (collectively, "Public Areas"), any ideas or suggestions for new products or modifications to existing products, and other unsolicited submissions (collectively, "Unsolicited Information"). All Unsolicited Information shall be deemed to be non-confidential and Summitas shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution. 

Children:
The Summitas Site is not intended for use by any users under the age of 18. Summitas does not knowingly collect Personal Data from any individuals under the age of 18.  If you are under the age of 18, please do not submit any Personal Data through the Site. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on this Site without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Data to Summitas through this Site, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Web Sites:
This Privacy Policy applies only to the Site. This Site may contain links to other web sites not operated or controlled by Summitas (the "Third Party Sites"). The policies and procedures we described here do not apply to the Third Party Sites. The links from this Site do not imply that Summitas endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies. 

Public Profiles

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.

Security:
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

Data Retention
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
When using a mobile device, information from our site may be shared with third party applications located on your mobile device.  If you decide to use third party applications on your mobile device, any information those applications collect may be sent to third parties and the Summitas privacy policy does not apply. However, third party applications may have their own privacy policies that you should review.

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:
Your access to and use of this Site is subject to the Terms of Use.

Changes to Our Privacy Policy:
The Site and our business may change from time to time. As a result, at times it may be necessary for Summitas to make changes to this Privacy Policy. If we decide to change our policy, we will post those changes to this Privacy Policy and also post a notification on our Site alerting you that our Privacy Policy has been changed so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this Privacy Policy at any time, so please review it frequently.  If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page prior to the change becoming effective.

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.

Upon request Summitas, LLC will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. If your Personal Data changes, or if you no longer desire our service, or if you wish to have your Personal Data removed from public forums and blogs, you may log in to the Site and navigate to My Account, where you can access and utilize options for editing your profile and managing your account information.  If you want to stop using your account you may deactivate it or delete it. When you deactivate an account, no user will be able to see it.  When you delete an account, it is permanently deleted from Summitas; however, even after you remove information from your profile or delete your account, copies of that information may remain viewable elsewhere to the extent it has been shared with others, it was otherwise distributed pursuant to your privacy settings or in accordance with the privacy policy, or it was copied or stored by other users.  You may reach us through our Contact page, by telephone or via regular mail using the contact information listed below. We will respond to your requests 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.

Contacting Summitas:
If you have any questions about our Privacy Policy or the information practices on this Site, you may reach us at Contact or at:

Summitas, LLC
335 Madison Avenue
Suite 1432
New York, New York  10017
Telephone: (877) 752-1717