EFFECTIVE DATE: March 21, 2012
Summitas, LLC ("Summitas", "we", "us" and/or "our") complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Summitas has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Summitas’ certification, please visit http://www.export.gov/safeharbor/.
Information We Collect:
When Subscribers interact with us through the Site, we may collect Personal Data and other information, as further described below:
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/nypbt ("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) Summitas will store an encrypted version of the passphrase; and (ii) 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. 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.
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.
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:
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 credit card number and/or social security number, National ID, personal health information) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). To learn more about SSL, follow this link: http://www.rsa.com/rsalabs/node.asp?id=2293
Summitas retains information for as long as a user remains a customer and thereafter, for so long as Summitas deems such information commercially useful or legally required.
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.
Other Terms and Conditions:
Updating/Accessing/Amending/Correcting/Deleting Personal Data:
335 Madison Avenue
New York, New York 10017
Telephone: (877) 752-1717
Last updated March 21, 2012