Privacy Notice Updated January 1, 2023

Summersalt, Inc. (“Summersalt,” “we,” “us,” or “our”) recognizes that privacy is important and is committed to maintaining the privacy of information it collects. This Privacy Notice explains how we collect, use and share information through our website and services and through interactions with our users (collectively the “Services”) wherever this Notice is posted.

 

By using our Services or otherwise providing personal information to us, individuals in the United States consent to the collection, use, disclosure and other handling of personal information described in this Privacy Policy, except for activities for which we first require their consent to be given through other means. For details about privacy consent in connection with our European operations, please see this section of our Privacy Policy.

 

INFORMATION WE COLLECT

 

We collect information in multiple ways, including when you provide information directly to us and when we automatically collect information from or about you, such as from your browser or device.  We may combine all of the information we collect from or about you from these various sources and use it for all the purposes described below. 

 

Information You Provide Directly to Us

 

We may collect information that you provide when you use our services or otherwise communicate with us, such as during the following interactions:

• When you create an account on the website;
• When you make a purchase or register a product;
• When you register for communications (including to receive emails and texts) or other subscriptions through this website, Twitter, Facebook, Instagram or any other digital media, or social media application;
• When you make a request or an inquiry or contact customer support or provide feedback
• When you participate in a contest, promotion, sweepstakes, survey or other promotion or marketing event;
• When you connect with us on social media;
• When you participate or comment in a blog or forum; and
• When we conduct market research or when we meet you at a social or other event.

In these instances, we collect the following types of information:

• Contact information, such as your full name or company name, email address, phone number and physical mailing or shipping address;
• Authentication Information, such as passwords and reminder questions/answers;
• Order Information, including products purchased, style and usage preferences, sizing and measurement information, and shipping preferences;
• Payment Information such as credit, debit, or other financial account information. This information goes to and is stored with our payment processors.  We do not store such information. 
• Demographic Information, such as age, gender, pregnancy status, or other information you provide in response to surveys or in customer service interactions; and
• Audio information (e.g., if you participate in a customer support call and do not opt out of call recording)

 

Information We Collect Automatically

 

Usage and Device Information. We may automatically collect certain information about you or the computer or devices you use.  For example, we may collect information that is automatically sent to us by your computer or mobile web browser or your internet service provider. This information typically includes your web request, IP address, browser type, domain name and settings, referring / exit pages and URLs, how you interact with links on the website(s), pages viewed, mobile carrier, mobile device identifiers and information about the device you are using to access the Services.

 

Location Information.  We collect and process general information about the location of the device from which you are accessing the Services (e.g., precise or approximate geographic location inferred from an IP address).

 

Cookies and Other Tracking Technologies. We and our service providers may also collect data about your use of the Services through Internet server logs and online tracking technologies, like cookies and/or tracking pixels. A web server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website. that enables us to: (a) recognize your computer; (b) understand the web pages of our website you have visited; (c) recognize repeat users; (d) facilitate the your ongoing access to and use of the Services (e) allow the Services to track usage behavior and compile aggregate data that will allow content improvements and targeted advertising; (f) enhance your user experience by delivering content and advertisements specific to your inferred interests; (g) perform searches and analytics; and (h) assist with security administrative functions. Some cookies may assist in performing essential functions of the Services, such as processing your orders and to enable any purchasing capabilities. These Cookies also may be required for the Services’ functionality, including for system administration, security and fraud prevention. We also use cookies to collect information around abandoned shopping carts. A cart is considered abandoned within one hour of inactivity/lack of purchase. Once the cart is considered abandoned, an email or SMS or MMS message may be sent as a reminder. For more information about how to manage your cookie preferences, please see the “Online Advertising and Direct Marketing Choices” section below.

 

Note that by blocking any or all cookies, you may not have access to certain Services features or offerings.

 

Tracking pixels or web beacons are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, measure popularity of a website and associated advertising, to access user cookies and for retargeting. We and our service providers may also include Web beacons in email messages, newsletters and other electronic communications to determine whether the message has been opened and for other analytics, personalization and advertising. As we and our service providers adopt additional technologies, we may also gather additional information through other methods. 

 

European Users: If our site detects that you are visiting from a European IP address, we will seek your prior consent before deploying cookies for web analytics or advertising, or for other purposes that require consent under European law. To revoke your consent to cookies or to manage your cookie preferences, please visit our Privacy Center. 

 

Information We Collect From Third Party Sources

 

We may receive information about you from other sources, including data vendors, data co-ops, marketing partners, and anti-fraud services. We may add this information to the information we have already collected from you to use for all the purposes described in the privacy policy.

 

Social Media Information.  If you interact with us through a social media service or log in using social media credentials, depending on your social media settings, we may have access to your information from that social network such as your name, email address, friend list, photo, age, gender, location, birthday, social networking ID, current city, your comments about our Services, and the people/sites you follow. When you submit information to a third party, you are subject to that third party’s terms of use and privacy policies, for which we are not responsible.

 

HOW WE USE AND DISCLOSE YOUR INFORMATION

 

How We Use Your Information

 

We and our service providers may use the information we collect from and about you, for one or more of the following purposes:

 

• Respond to your inquiries, collect your suggestions, and fulfill your requests, such as to send you email alerts, and contact you to answer any questions to the extent possible.
• Send you important information regarding the website or terms, conditions, and policies and/or other administrative information. 
• Complete and fulfill your purchase, request or inquiry, for example, to communicate with you regarding your order, your return or other answers to your questions, and provide you with related service and assistance, if any.
• Send you marketing communications that we believe may be of interest to you, including information about upcoming opportunities, invitations, events, apps, and exclusive deals. 
• Personalize your experience on the Services by presenting opportunities, products and offers tailored to you.
• Create inference data about you and your interests based on purchases you have made and how you use the Services.
• Allow you to participate in surveys, sweepstakes, offers, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your information, so we recommend that you read these rules carefully.
• Allow you to communicate and interact with others through our website (for example, through a blog, message board, messaging functionality, chat functionality, profile or other social media).
• Enable our business purposes, such as data analysis, audits, researching and developing new products and services, enhancing this website, improving our services, developing marketing events, identifying usage trends and determining the effectiveness of our promotional campaigns. We may analyze aggregated demographic information and information for historical, statistical, or scientific purposes, or we may store the information for your convenience should you return to this website in the future. 
  
• For any other purpose, with your consent where appropriate.
  
  

How We Disclose Your Information

 

We and our service providers will disclose the information we collect from and about you for the following business and operational purposes:

• Service Providers: We may provide access to or disclose your information with third parties who perform services on our behalf, such as sales, marketing, product content and features, advertising, research, customer service, delivery, data storage, security, fraud prevention, payment processing and order fulfillment and legal services. We also use third-party web analytics services on our website to collect and analyze usage information through cookies and similar tools as described in the “Information We Collect Automatically” section above; engage in auditing, research, or reporting; and provide certain features to you.
• Affiliates: We provide access to or disclose your information with current or future affiliates for the purposes described in this Privacy Notice.
• Third Party Partners for Direct Marketing: We may disclose and/or share your information with third party partners to provide you with information, including marketing, about services that we think you might want. You may opt out of such sharing by visiting our Privacy Center. You may also visit our Privacy Center at any time to opt-out of receiving promotional communications from Summersalt. Please note that if you decide to opt-out of receiving promotional information or other communications after you have previously opted-in, your change in preference will only affect future contacts. We may still contact you as necessary regarding Summersalt, any request you have made for services or products from Summersalt, changes to this Privacy Notice and other transactional matters. As used herein, “sell”
  is used as defined in applicable law, such the California Privacy Rights Act (“CPRA”) or the Virginia Consumer Data Protection Act (“VCDPA”), as applicable, and “share” refers to sharing for purposes of cross-context behavioral advertising or targeted advertising, as contemplated under applicable law, such as the CPRA and VCDPA.
• Third Party Partners to Provide Co-Branded or Jointly Offered Products and Services: We may from time to time partner with another brand or retailer or other third party to offer services, products, events and promotions on a co-branded or cross-promotional basis. The information you provide in connection with our Services may be collected directly by, or disclosed to the third party, as well as with any participating sponsors or advertisers of such services. You can opt-out of these disclosures under the Opt-Out section of this Privacy Policy below. 
• Protection of Summersalt and Others & Legal Compliance: We may access, retain and disclose the information we collect and maintain about you if required to do so by law or on a good faith belief that such access, retention, or disclosure is reasonably necessary to: (i) comply with law or legal process (e.g., a subpoena or court order) and requests from public or governmental authorities; (ii) enforce our Terms of Service, this Privacy Notice, or other contracts with you, including investigation of potential violations thereof; (iii) respond to your requests for customer service; and/or (iv) protect the rights, property or personal safety of Summersalt, its agents and affiliates, its users, and/or the public; (v) investigate security breaches; and (vi) to allow us to pursue available remedies or limit the damages that we may sustain. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and similar purposes.
• Business Transfers: We may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third party, customer information (including your email address) would likely be one of the transferred business assets.
  
  

Legal Bases for Processing (European Operations)

 

Under the General Data Protection Regulation (“GDPR”), our legal grounds for processing personal information in connection with our European operations are as follows:

 

• Legitimate interests: In many cases, we handle personal information on the ground that it furthers our legitimate interests in commercial activities, such as the following, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
• Provision of our Services;
• Customer support;
• Non-marketing communication, and some marketing communication;
• Protecting our customers, personnel and others; and
• Analyzing and improving our business.

 

We may also process personal information for the same legitimate interests of business partners and organizations with whom we work.

 

• Consent: Where required by law, and in some other cases, we process personal information on the basis of consent. For example, we may send certain marketing emails to individuals who have requested them.

 

• To honor our contractual commitments to an individual: Some of our processing of personal information is done to meet our contractual obligations to the individuals to whom the personal information relates, or to take steps at their request in anticipation of entering into a contract with them. For example, when an individual places an order, we can process their payment information on this basis.

 

• Legal compliance: We need to use and disclose personal information in certain ways to comply with our legal obligations.

 

 

Aggregated or De-Identified Information

 

We may aggregate, de-identify, and/or anonymize any information collected through the Services in such a way that we cannot reasonably link information to you or your device. For example, we may use the information to calculate the percentage of Summersalt users who have a particular telephone area code or who use an Android device or an iOS device.

Because this type of information cannot be reasonably linked to you, we may use and disclose this information for any purpose.

 

Online Advertising and Direct Marketing Choices

We may use all information collected through the Services for direct marketing and e-marketing purposes including the sharing of the information with our affiliates or third parties unless you specifically request that it not be used for that purpose.

 

Online Advertising.  We may use and share your information to facilitate the delivery of targeted ads, promotions, and offers to you, on behalf of ourselves and any of our partners, on and off the Services.  Third-party networks and advertising technologies allow for the delivery of advertising from us on other websites you visit. You have choices about how your information is collected and used for online advertising:

• If you are interested in more information about how you can generally limit cookies from being put on your computer to deliver certain types of advertising, please visit  http://networkadvertising.org/optout_nonppii.asp and http://www.aboutads.info/choices to opt-out of receiving tailored advertising from companies that participate in those programs. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
• You may be able to block cookies on your browser. Please consult the "Help" section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). However, note that by blocking any or all cookies, you may not have access to certain Services features or offerings.
• You may also manage your cookie preferences on our site here.
• We use Facebook’s pixel, advance matching and Conversion API. Customer activity data is tracked via Facebook and this can be disconnected by the customer from their Facebook account, click here to do so.

 

Text Marketing. By signing up via text, you agree to receive recurring automated promotional and personalized marketing text messages (e.g. cart reminders) from Summersalt at the cell number used when signing up. Reply HELP for help and STOP to cancel. Msg frequency varies. Msg & data rates may apply. View Terms & Privacy Notice.

 

Email Marketing. To unsubscribe from our marketing emails, please click the “unsubscribe” link in the footer of any marketing email you receive. Please note that even after you unsubscribe from marketing emails, we may continue to send transactional and service-related emails, such as order receipts and communications about updates to our terms of service or privacy policy.

 

Privacy Settings. You may request deletion or correction of your Personal Information. To do so, please visit our Privacy Center to request deletion and contact us at privacy@summersalt.com regarding correction requests.

 

Links to Other Sites

For your convenience, our website may contain certain hyperlinks to other websites as well as to third party websites. This Privacy Notice applies only to information collected on this website and not to information collected on linked sites. We encourage you to be aware when you leave this website and to read the privacy statements of each and every linked site that collects your information.

Children's Information

We are committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children's online activities. We do not target our websites to children less than 16 years of age or knowingly collect information from children for the purpose of selling products or services. If we learn that we have received personal information through our services regarding a child, we will delete it where legally required.

 

Special Privacy Information for Certain U.S. Residents

 

If you are a resident of California or Virginia, applicable law requires us to provide you with some additional information regarding how we collect, use, disclose, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”), as amended by the CPRA, or your "personal data" as defined in the VCDPA, as applicable. For the purposes of this Privacy Notice, "personal information" includes, but is not limited to, all information protected as "personal information" under the CPRA and "personal data" under the VCDPA.

 

Categories of Personal Information We Collect.  Throughout this Privacy Notice, we discuss information we collect from and about users. Under applicable law, we are also required to provide you with the “categories” of personal information we collect.  Depending upon the types of services you use, the categories we collect are:

• Identifiers, including personal and online identifiers (such as name, address, email address, and postal address);
• Customer Records Information (name, signature, physical characteristics or description, address, telephone number, bank account number, credit card number, debit card number, or any other financial information);
• Commercial information (such as purchase history);
• Financial data (such as payment information);
• Internet or other network or device activity (such as information related to your browsing history and the device(s) you use to access the website);
• Geolocation information (e.g., your city and state inferred from IP address);
• Demographic information (e.g., such as age, gender, and pregnancy status).
• Audio information (e.g., if you participate in a customer support call and do not opt out of call recording);
• Inference data about you and your interests based on purchases you have made and how you use the website; and
• Other information that identifies or can be reasonably associated with you.

We do not collect or process any information that constitutes "sensitive personal information" under the CCPA, as amended by the CPRA, or "sensitive data" under VCDPA from consumers.

Use and Disclosure of Personal Information. We may use, or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to make a purchase or ask a question about our products or services, we will use that personal information to respond to your inquiry. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries.
• To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or when we notify you of other uses at the time of collection, or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Summersalt’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Summersalt is among the assets transferred.

When we disclose your personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We may disclose aggregate or anonymous information with any third party, including advertisers and affiliates.

Depending on the circumstances, we may disclose some or all of the above categories of information we collect with: business partners to provide you with services that you request; service providers; other parties, including government entities, when required by law or to protect our users and services; or in connection with a corporate transaction. In addition, we may disclose commercial information and financial data, including your payment information, with payment processors, and we disclose device information and identifiers and internet or other network or device activity with entities that provide content, advertising, and functionality.  See the How We Use Your Information and How We Disclose Your Information sections for more information.

 

Notice of Right to Opt Out of Sales or Sharing of Personal Information We sell and share your personal information, including identifiers, commercial information internet or other network or device information, geolocation, demographic information, and inferences with our third party advertising and co-branded or jointly branded partners for these purposes:

• For online targeted advertising purposes: demographic and statistical information, user-generated content, customer records information, device information and identifiers, connection and usage data, geolocation, and social media information.
• For sharing with third parties to send you relevant offers and promotions: contact and account registration information; customer records information; demographic and statistical information, user-generated content, and geolocation.

Applicable law prohibits third parties who purchase or receive the personal information from reselling or resharing it unless you have received explicit notice and an opportunity to opt-out of further sales or sharing.

We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age. We do not and will not sell or share the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales or sharing may opt-out of future sales or sharing at any time.

Pursuant to applicable law, California and Virginia residents have the right to direct us to not sell or share your Personal Data at any time. To exercise the right to opt-out of the sale, sharing or targeted advertising, you (or your authorized agent) may submit a request to us by visiting the following page: Do Not Sell or Share My Personal Information or our Privacy Center.

 

Your State Privacy Rights

 

If you are a California or Virginia resident, applicable law provides you with certain rights regarding the personal information we have about you. Specifically, you may request:

• Information about, and confirmation of, the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; the categories of third parties with whom we disclose personal information, the specific pieces of personal information we collected about you, and the categories of personal information that we sold and the categories of third parties to whom we sold that information. Such information is also set forth in this Privacy Notice.
• Provide access to and/or a copy of certain information we hold about you.
• Correct inaccuracies in your personal information that we processed.
• A copy of the personal information that we process in a portable, readily usable format that allows you to transmit the information to another controller.
• Delete certain information we have about you.
• Opt-out of the sale of your personal information, the sharing of your personal information or the use of your personal information for targeted advertising.
• Provide you with information about the financial incentives that we offer to you, if any.

 

Non-Discrimination. We will not discriminate against you for exercising any of your rights. Unless permitted by applicable laws, in connection with you exercising your rights, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

However, we may offer you certain financial incentives permitted by applicable laws that can result in different prices, rates, or quality levels. Any legally-permitted financial incentive we offer will reasonably relate to your personal information’s value to us and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. 

 

We will consider all requests and respond within the time period required by law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information or to comply with a legal obligation. Depending on the sensitivity of the information sought, we also may take steps to verify your identity before responding to a request, which might include, at a minimum, verifying your name, email address, and date of birth.

 

Additionally, exercising your deletion rights may mean that you may no longer be able to use portions of Summersalt’s service that require personal information to function (e.g., if you register for an account, you cannot delete your username and password if you want to maintain your account).

 

If you would like further information regarding your legal rights under California or Virginia law or would like to exercise any of them, please contact us at privacy@summersalt.com or via our Privacy Center. You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

 

To exercise your opt-out rights, you (or your authorized agent) may submit a request to us by visiting the following page:  Do Not Sell or Share My Personal Information or our Privacy Center.

 

An authorized agent may make a request on your behalf. If you use an authorized agent to submit a consumer rights request, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to verify your own identity directly with us or directly confirm with us that you provided the authorized agent permission to submit the request.

 

You may only make a consumer rights request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized agent of such person.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We do not charge a fee to process or respond to your consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

If we deny your request, Virginia residents have the right to appeal our decision. Further, if you appeal and your appeal is denied, you may the right to complain to your state’s attorney general. You may appeal your decision by contacting us at privacy@summersalt.com via our Privacy Center.

 

Shine the Light Disclosures

If you reside in California, you may request certain general information regarding our disclosure of personal information during the preceding year to third parties for their direct marketing purposes. To make such a request, please write to us at privacy@summersalt.com.

 

Privacy Information for Nevada Residents

 

Under Nevada law, Nevada residents who have purchased goods or services from us may opt out of the “sale” of “covered information” (as such terms are defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons.  In some circumstances, we may share your information with certain third parties that we believe can provide you with offers and promotions for products and services of interest to you.  This sharing may qualify as a sale under Nevada law. If you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of “sales” activity emailing us at privacy@summersalt.com.   Please note we may take reasonable steps to verify your identity and the authenticity of the request.

 

International Privacy Rights

 

Depending on the laws of your local jurisdiction, you may have certain rights and additional choices with respect to your information. For example, laws outside the United States (e.g., the United Kingdom, France, Germany and other EU countries) provide individuals in such locations the right to ask us to:

 

• obtain confirmation of whether we hold personal information about them, and receive information about how it is used and disclosed;
• obtain a copy of the personal information, and in some cases, receive it in a structured, commonly used and machine-readable format, or have it be transmitted to a third party in such form;
• update, correct or delete the information;
• object to the use or disclosure of the information;
• withdraw consent previously provided for the handling of the information (without affecting the lawfulness of prior use and disclosure of the information, or of uses and disclosures for which the law does not require consent); and
• obtain a restriction on the use of the information.

 

For example, individuals whose personal information is subject to the General Data Protection Regulation (“GDPR”) have an absolute right to opt out of our handling of their personal information for direct marketing purposes.

 

Many of the rights described above are subject to limitations or exceptions under applicable law.

 

To exercise these rights, except for the right to correct your personal information, please visit our Privacy Center. If you wish to exercise your right to correct your personal information, or raise a complaint on how we have handled your personal information, please contact us at privacy@summersalt.com. Individuals also have a right to file a complaint with the relevant supervisory authority, but we invite you to kindly first give us an opportunity to address your concern.

 

Do Not Track

Our systems do not recognize "Do Not Track" signals, but several of the third party companies who use cookies or beacons on our web sites enable you to opt out of certain behavioral advertising. We also provide you with additional tools to opt out of marketing from us or certain transfers of your information. You can learn about this in the " Online Advertising and Direct Marketing Choices" section of this Privacy Notice.

 

Retention Period

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or allowed by law.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide requested services to you;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them);or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
  
  

Information Security

 

We use safeguards to protect your personal information from unauthorized access or disclosure. Nonetheless, no method of transmission over the Internet, or method of electronic storage, is completely secure so there is still some risk that your personal information may be accessed or misappropriated. Therefore, we cannot guarantee the absolute security of your personal information. If you have any questions about security on our site, you can send an email to us at email address specified below.

 

International Data Transfer

 

Your personal information may be stored and processed in any country where we, our service providers, or any of the other recipients described in the “How We Share and Disclose Your Information” section above have operations, including in the United States or in other countries with data protection laws that the European Commission has not recognized as providing an adequate level of privacy protection. Personal information is typically subject to the laws of the country in which it is held, and sometimes also the laws of other countries that have a connection to its processing, such as the source country. For this reason, your personal information may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of any of the countries described above, pursuant to the laws of such countries. However, this Privacy Policy will continue to apply to personal information collected under this Privacy Policy when it is held by Summersalt or by any third-party processor that has been engaged by Summersalt to act solely on our behalf, regardless of location. Summersalt complies with legal requirements for protecting the movement of data across borders, including through the use of European Commission-approved Standard Contractual Clauses.

 

 

Changes in this Privacy Notice

We reserve the right to modify this Privacy Notice at any time, so please review it frequently. If we make material changes to this notice, we will notify you here, by e-mail, or by means of a notice on our home page.

 

Contact Us

If you have any questions, comments, or would like to request access to your account information, you may contact us at hello@summersalt.com. 

© 2023. Summersalt, Inc. All rights reserved.