This Privacy Policy explains how Summit and its subsidiaries, (collectively, the “Summit Group” or “we” or “us” or “our”) collect, use, and process your personal information. We collect information from you in various ways when you interact with our products and services. By submitting your personal information on our Websites, you have consented to our collection and use of information as explained in this Notice and agree to be bound by our Terms of Use. We request that you read this Privacy Policy carefully. Occasionally, we will update this Policy, so please do return and review our Privacy Policy from time to time.

Please note that if you choose to invest in any offering advertised on our website, you may be required to agree to a separate agreement, including, but not limited to, new or additional privacy notices or terms of use.

Collection of information

Non-Personally Identifiable Information: Summit collects Non-Personally Identifiable Information from you regarding your usage of our products and services. Non-Personally Identifiable Information refers to data that does not, by itself, identify individual persons and may include, without limitation, website pages viewed, articles, presentation and videos viewed, time spent using certain features of the website, demographic data such as server locations, cookies existing on your devices used to access Summit, search criteria used and results, date, time, connection speed, internet protocol ("IP") address, which may also be contained on server logs, and/or other information which does not specifically identify you. We collect this information using various technologies, including, but not limited to, cookies and server logs. "Cookies" are pieces of information that may be placed on your device by a website for the purpose of facilitating and enhancing your communication and interaction with that website. "Server logs" can be either a single log file or several log files automatically created and maintained by a server of activity performed by the server, which can include information about any transaction you conduct with the server.

Personally Identifiable Information: Summit also collects Personally Identifiable Information from you when you interact with our products and services and communicate with a member of our team, including but not limited to, when you sign up for an account, make an investment, verify your identity, record and verify accredited investor status, provide payment instructions, or send us an email through the Summit website. Personally Identifiable Information refers to information that allows us to identify you personally. Such information may include, but is not limited to, your email address, name, phone number, birthday, age, income, assets, physical address (such as home or business address), or other information you provide or upload to the Websites (such as photographs, answers to questionnaires or surveys, or responses filled in on blank forms made available on the site).

We refer to Personally Identifiable Information and Non-Personally Identifiable Information collectively herein as "Personal Data". We may collect and store information, which could include Personal Data, locally on your computer or device using mechanisms such as browser web storage or application data caches.

Our collection of Personal Data is necessary to our legitimate interests, which serves as our lawful basis for processing your Personal Data. Such legitimate interests are to run our business, keep our records updated, ensure legal and regulatory compliance, fulfil our obligations as a service provider, develop our products/services, and inform our marketing strategy.

We use analytics programs and service providers, such as Google Analytics, which can use first party cookies to report on your interactions with our Websites. Google Analytics collects information including, but not limited to, the time of each of your visits to Summit Websites, whether you have visited Summit websites before, what site referred you to Summit Websites, and what pages you viewed on Summit Websites.

This Privacy Policy does not cover the collection of information by cookies or other methods by third parties, such as our business partners. We do not control how such third parties collect information or by what means as such third parties may use their own cookies to collect information about you.

Use of Information

Summit will use information you provide to us to better serve you and enhance your experience with Summit Websites, among other things. This may include having to modify or copy such information, such as images or textual or narrative content you provide, in order to provide you with a seamless and enjoyable experience.

Toward these ends, you consent to our use and disclosure of any information submitted to us via Summit Websites, information collected when you access Summit Websites in any manner, or information collected through your use of our other products and services, and you acknowledge that you have no expectation of privacy, confidentiality or privilege in such information.

Summit will use Personal Data;

(1) To market our products and services to you.

(2) To provide services and products requested by you.

(3) To enable our vendors and contractors to provide and assist us in the marketing, operation, troubleshooting and analysis of our website and other services.

(4) To meet any regulatory requirements for the offer or sale of securities required by law, rules or regulations to our affiliates or members.

(5) To engage in any other lawful activities we believe are consistent with the foregoing.

(6) To protect against legal liability. We may provide any of these services through third parties, which may necessitate sharing your Personal Data with them.

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 instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Summit may also use your Personal Data to help us improve the content and functionality of our website, to better understand our users and to improve our services. Summit may use this information to communicate with you regarding our services or to tell you about services we believe will be of interest to you. If at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below or opt-out using our unsubscribe forms.

Summit may employ or contract with other third parties, companies, or individuals to perform certain functions or services on its behalf. Examples of these services from such third parties, companies, or individuals, may include ID verification, payment storing and processing, sending postal mail and e-mail, providing marketing assistance, and/or providing customer service. As such, these third parties, companies, or individuals may have access to your Personal Data as needed to perform their functions or services, and may not use it for other purposes.

Summit may also use and disclose your Personal Data: to investigate and help prevent potentially unlawful activity or activities that threaten the integrity of our Websites; to protect and defend our rights or property or the rights or property of others; as required by courts or administrative agencies; and in connection with a financing, sale, merger, or reorganization of Summit's business or assets. Any successor in interest to our business would acquire the information we maintain, including your Personal Data, and may alter the terms of this Privacy Policy.

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 the transferred assets and you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. We may also share your Personal Data with our affiliates for purposes consistent with this Privacy Policy.

Summit may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Summit, (iii) act in urgent circumstances to protect the personal safety of users of the website or the public against fraud or other harm, or (iv) protect against legal liability.

Summit does not and will not sell any of your Personal Data to any third party for purposes of advertising, soliciting, or telemarketing.

Third Party Websites and Services

Our Websites contains links to other websites and services not maintained by Summit. In addition, other websites and services may also reference or link to Summit Websites. We encourage you to be aware when you enter or leave our website, or surf the Internet, and to read the privacy statements of each website and service that you visit. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of, other websites or services.

Testimonials

We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name and other information. Please contact our support team if you wish to update or delete your testimonial.

Opt-Out Policy

You will be able to modify the information concerning your account by visiting the website and editing any information you wish to change. You will be able to change your e-mail address, password, contact information, or other log in information by visiting your account's settings.

We may at times send you e-mail communications with marketing or promotional materials. If you prefer not to receive such marketing or promotional e-mails from us, or have your Personal Data used for any other direct marketing purposes, you have the right to opt-out and may unsubscribe completely by clicking the appropriate links at the bottom of the emails, managing your preferences on the website, or contacting us on the platform or over email. Please note that opt-out requests may take up to five (5) days to process.

Please also note that at times we may need to send you e-mail communications that are transactional in nature such as service or termination announcements or payment confirmations which are communications you will not be able to opt-out of. Please note that after clicking the appropriate links to unsubscribe, or submitting a request to opt-out, you will, remain opted out for all other, and future promotional e-mails.

Security

We use reasonable efforts to secure access to Personal Data and protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input, but will not be liable for any failure to safeguard such information, whether inadvertent or otherwise. Wherever appropriate, we obfuscate and/or encrypt information in our systems and/or during information transfer. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee it's absolute security.

Changes to This Privacy Policy

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this notice at any time. Any changes or updates will be effective immediately upon posting to the web site and/or sending a notification to all registered users via email regarding such update. You should review this notice regularly for changes, and can determine if changes have been made by checking the Effective Date below. Your continued use of our website, products, and services following the posting of any changes to this notice means you accept such changes.

This Privacy Policy was last updated on March 1, 2021.