Identity and contact details

• Email address
• Tax jurisdiction
• Name and billing address (only collected when you subscribe to a paid plan)

Service related information

• Payment and transaction details for services you've purchased from us or enquiries about our services
• Your preferences for our services and your marketing preferences
• Feedback and survey responses
• Personal information contained in user-uploaded documentation (see User Documentation section below)

Cryptocurrency information

• Cryptocurrency wallet addresses
• Transaction IDs for cryptocurrency transactions
• Cryptocurrency balances on centralised exchanges
• List of exchanges you have traded on

Digital information

• IP address and general location information derived from your IP address 
• Security tokens
• Search and browsing behaviour
• Website usage patterns
• Cookie preferences and usage

Recordings

• Records of chat interactions you have with our support team
• Call recordings
• Records of meetings and decisions

Professional information (for job applicants and workers)

• Employment history
• Professional experience
• Required authorisations and licences
• Professional registrations
• Information about your right to work in the relevant jurisdiction

Connected App Integration Data

• Your cryptocurrency transaction history
• Your portfolio holdings
• Your tax reports and capital gains or loss summaries
• The wallets and exchanges you have connected to your account
• Your tax settings and jurisdiction

Connection and session details generated when you authorise a third party application or AI tool to connect to your account

Business operations

• To manage our relationship with you as a customer or supplier
• To process and deliver our services
• To handle your inquiries, support requests, and communications
• To maintain accurate records for billing and administration
• To verify your identity when required or permitted by law
• To facilitate connections between yours account and any third-party apps or tools you choose to connect, including passing your personal information to those apps on your instructions and managing the access tokens that keep those connections running

Communication and support

• To respond to your questions and support requests
• To communicate important updates about our services
• To handle inquiries made through our website or platforms
• To manage your participation in surveys, feedback sessions, or events

Service improvement

• To conduct analytics and market research
• To improve our business operations and services
• To develop and enhance our applications and platforms
• To understand how our services are used

Marketing and promotions

• To send you promotional information about our services and events
• To inform you about products or services that may interest you
• To manage your marketing preferences
• To run competitions, promotions, and special offers
• To provide additional benefits to our customers

Employment purposes

• To assess employment applications
• To evaluate candidate qualifications
• To manage professional certifications and licences
• To maintain employment records

Legal and compliance

• To comply with our legal obligations
• To respond to court orders or legal processes
• To maintain required business records
• To fulfill regulatory requirements or reporting obligations
• To protect our legal rights and interests or as authorised by law

Service providers

• IT service providers
• Data storage providers
• Web hosting and server providers
• Payment processors
• Marketing and advertising providers
• Analytics providers

Professional advisers

• Bankers
• Auditors
• Insurers and insurance brokers
• Legal advisers

Business partners

• Our existing or potential agents
• Our business partners or contractors

Corporate transactions

If we merge with or are acquired by another company, or sell our business assets:

• Your information may be disclosed to our advisers
• Your information may be disclosed to the potential purchaser's advisers
• Your information may be included in the transferred assets

Legal and regulatory bodies

• Courts and tribunals
• Regulatory authorities including as required for reporting obligations
• Law enforcement officers

Other parties

• A parent, subsidiary, or affiliate of our company
• Third parties you have authorised
• Emergency services when necessary
• Any other parties as required or permitted by law

Third parties we currently use include, but are not limited to:

• Amazon Web Services
  
  
• Anthropic
• CookieBot
  
  
• FirstPromoter
  
  
• Google Marketing Platform
  
  
• Intercom
  
  
• Meta
  
  
• Microsoft Advertising
  
  
• OpenAI
  
  
• Ortto
  
  
• PostHog
  
  
• SendGrid
  
  
• Stripe
• VWO
  
  
• X (Twitter)

Storage and access

We store your personal information in Australia and the United States of America. However, your information may be accessed from or transferred to other locations in these circumstances:

• When our service providers are located overseas
• When we work with overseas business partners
• When using cloud-based services or data storage solutions

If you connect a third-party app to your account, your information may be sent to and processed by that app in countries outside Australia, including the United States. That processing is covered by the third-party provider's own privacy policy. We are not responsible for how they handle your information once it has been passed to them.

Our approach to overseas disclosure

Before disclosing your personal information overseas, we take reasonable steps to ensure that the recipient treats your information in accordance with applicable law by only sending what is necessary, requiring recipients to protect your information through contractual agreements which require the recipient to comply with the privacy standards in applicable law or through other mechanisms that provide comparable safeguards and by monitoring how recipients handle your information.

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Providing information

You can choose whether to provide personal information to us, however, if you don't provide certain information, we may not be able to provide some services. Let us know if you don’t want to provide information and we will let you know when information is required versus optional.

Access to your information

You can request access to the personal information we hold about you and we will respond to your request within a reasonable time. We may charge a reasonable administrative fee for providing access and if we cannot provide access, we will explain why and explore alternative ways to share relevant information.

Correction rights

You can ask us to correct any information that is inaccurate, out of date, incomplete, irrelevant or misleading and we will take reasonable steps to correct your information promptly. If we cannot make the correction, we will explain why and discuss alternatives. You can ask us to add a statement to your information noting your requested correction.

Marketing communications

You can opt-out of receiving marketing communications at any time. Each marketing communication will include an unsubscribe option. You can change your marketing preferences by contacting us. We will process your request as soon as practicable.

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How to contact us about your rights or to make a complaint and what happens next

Technical safeguards

• Enterprise-grade encryption for data storage and transmission
• Regular security testing and monitoring
• Automated threat detection systems

Operational security

• Staff training on security and privacy
• Strict access controls based on job requirements
• Regular security audits and incident response procedures testing

Physical security

• Secure premises with controlled access
• Secure disposal of physical documents
• Equipment security protocols

Public information

Please note that any information you choose to share publicly on online platforms (such as comments or reviews) can be accessed and used by others. We cannot control or protect information that you make publicly available.

What We Use

We use cookies, tracking pixels, and similar technologies on our website and in our emails to improve your experience and our services.

Cookies

• Small text files stored on your device
• Help remember your preferences
• Enable certain website functions
• Make your interactions with our website more efficient

Tracking Pixels

• Tiny, invisible images in web pages and emails
• Help us understand how you interact with our content
• Allow us to measure email engagement
• Enable more relevant content delivery

How we use these technologies

Your control

You can manage these technologies by:

• Adjusting your browser settings to block or delete cookies
• Using privacy-focused browser extensions
• Configuring your email client to block images
• Using our cookie preference settings

Note: Blocking all cookies may affect website functionality and your user experience.

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Google Analytics

We use Google Analytics to understand how people use our website. This involves cookies that collect information about your browsing activity. You can opt out of Google's advertising features through your Google account settings, browser add-ons, or your device's privacy settings. Google provides various tools and options to control how your data is used for advertising purposes. You can learn more about how Google uses your data and your available options on Google's privacy pages.

Meta advertising tools

We use Meta's advertising tools (such as Meta Pixel) to understand how our ads perform and to show you more relevant advertisements on Meta platforms like Facebook and Instagram when you visit our website or app. You can manage whether we connect information from our website with your Meta account for advertising purposes by adjusting your settings within your Meta account preferences.

What we collect

When you use single sign-on to connect with us, we'll receive personal information from that provider based on your privacy settings with them. This may include your name, username, profile picture, and other details you've chosen to share.

How we use it

We use this information to create your profile on our platform and give you access to our services.

Overview

We use artificial intelligence and machine learning technologies in our business operations and services, including AI tools provided by third parties. We only use these technologies when legally permitted and necessary for our business.

How we use AI

We may use AI technologies to:

• Conduct analysis and data processing
• Generate and modify content and coding
• Improve and optimise our services and operations
• Automate routine tasks and communications
• Personalise your experience with our services
• Support quality assurance processes
• Assist with customer support and queries

Data protection and security

When we work with third-party AI providers, we ensure they handle your personal information in accordance with privacy laws through contractual requirements and appropriate safeguards.

Your rights and our commitments

Any information generated or inferred about you by AI technologies is treated as personal information, and you maintain all the rights outlined in this privacy policy. When using AI with your personal information, we commit to:

Third party AI tools you connect to your account

As well as our own use of AI described above, you can connect third-party AI tools to your Summ account. If you do:

• depending on the permissions you grant, the tool may access your transaction history, portfolio, tax reports, connected wallets and exchanges, and tax settings. If you also turn on write access, the tool may be able to add or change information in your account
• we do not store the prompts you send to the third-party tool or the responses it gives you. That information passes through in transit and is not kept by us
• your account information accessed through the connection is stored in the same systems we use for the rest of your Summ data
• we do not guarantee the accuracy of anything a third-party AI tool produces, including any tax-related outputs like capital gains summaries or tax reports. You should check these with a qualified accountant before relying on them
• you can disconnect a third-party tool at any time through your account settings. This will stop it from accessing your account going forward, but we cannot retrieve or delete any information it has already received

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Purpose: Business operations

Legal basis for using this information:

• Performance of a Contract
• Legal Duty (for billing and record-keeping requirements)
• Legitimate interests

Types of information we use: 

• Identity and contact details
• Service related information
• Cryptocurrency information
• Digital information 
• Recordings
• Connected App Integration Data

Purpose: Communication and support

Legal basis for using this information:

• Legitimate interests

Types of information we use: 

• Identity and Contact Data
• Cryptocurrency information
• Digital Information

Purpose: Service improvement

Legal basis for using this information:

• Legitimate interests

Types of information we use: 

• Service related information
• Cryptocurrency information
• Digital information 
• Recordings

Purpose: Marketing and promotions

Legal basis for using this information:

• Legitimate interests

Types of information we use:

• Identity and Contact Data
• Digital Information

Purpose: Employment purposes

Legal basis for using this information:

• Legitimate interests
• Legal Duty
• Consent
• Performance of a Contract

Types of information we use: 

• Identity and Contact Data
• Professional Data

Purpose: Legal and compliance

Legal basis for using this information:

• Legal Duty

Types of information we use: 

• All relevant personal information

Our approach to overseas transfers

When we transfer your personal data outside the EU or United Kingdom, we ensure it receives appropriate protection by:

• Only transferring your information to countries that European Data Protection Laws recognise as providing adequate protection for personal information, 
• Putting in place a contract with the third party that means they must protect personal data to the same standards as the EU or UK, or
• Transferring personal data to organisations that are part of specific agreements on cross-border data transfers with the EU or UK.

How long we keep your information

We only keep your personal data for as long as we need it to:

• Provide our services to you
• Meet our legal, tax, accounting or regulatory obligations
• Handle any complaints or legal issues that may arise

We may keep your information for longer periods if:

• You make a complaint that we need to investigate or respond to
• We reasonably believe legal action involving our relationship with you might occur
• The law requires us to keep it for specific timeframes

How we decide retention periods

When determining how long to keep your information, we consider:

• How much information we have and how sensitive it is
• The risk of harm if the information was accessed without permission
• Whether we can achieve our purposes in other ways
• What legal, regulatory, tax or accounting rules require
• The nature of our relationship with you and the services we provide

What happens when we no longer need your information

Once we no longer need your personal data, we will securely delete or destroy it in accordance with our data retention policies and legal requirements.

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You can request information about retention periods for your data and ask for early deletion where legally possible.

Rights in relation to personal data

In addition to the rights you have in our policy above, you also have the below rights.

Right to Erasure 

You can request deletion of your personal data in certain limited circumstances as set out in European Data Protection Law, such as where the data is no longer necessary or has been unlawfully processed. This right is not absolute and we may be required or entitled to retain your data for legal, regulatory or legitimate business reasons.

Right to Restrict Processing

You can ask us to suspend processing where:

• You contest the accuracy of the data
• Processing is unlawful but you don't want erasure
• We no longer need the data but you need it for legal claims
• You've objected to processing pending verification of our legitimate grounds

Right to Data Portability

Where technically feasible, you can receive your personal data in a structured, commonly used format or have it transmitted to another controller where:

• Processing is based on consent or contract
• Processing is automated

Right to Object

You can object to processing based on legitimate interests or for direct marketing purposes. We will stop processing unless we can demonstrate compelling legitimate grounds.

Right to Withdraw Consent

Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of prior processing.

Representative

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:

• United Kingdom (UK)
• European Union (EU)

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website: https://app.prighter.com/portal/17779954965

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Do not track

Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “Do Not Track” signals.

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We adhere to the standards outlined in this privacy policy, ensuring we collect and process personal information lawfully, fairly, transparently, and with legitimate, legal reasons for doing so.

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CCPA-permitted financial incentives

In accordance with your right to non-discrimination, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels for the goods or services we provide.

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Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your personal information, and we will provide written terms that describe clearly the nature of such an offer. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

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California notice of collection

In the past 12 months, we have collected the following categories of personal information enumerated in the California Consumer Privacy Act:

• Identifiers, such as name, email address, phone number, account name, IP address, and an ID or number assigned to your account;
• Commercial information, such as products or services history and purchases;
• Geolocation data.

For more information on information we collect, including the sources we receive information from, review the “Information We Collect” section. We collect and use these categories of personal information for the business purposes described in the “Collection and Use of Information” section, including to provide and manage our Service.

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Right to know and delete

If you are a California resident, you have rights to delete your personal information we collected and know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us, the:

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• Categories of personal information we have collected about you;
• Categories of sources from which the personal information was collected;
• Categories of personal information about you we disclosed for a business purpose or sold;
• Categories of third parties to whom the personal information was disclosed for a business purpose or sold;
• Business or commercial purpose for collecting or selling the personal information; and
• Specific pieces of personal information we have collected about you.

To exercise any of these rights, please contact us using the details provided in this privacy policy.

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Shine the light

If you are a California resident, in addition to the rights discussed above, you have the right to request information from us regarding the manner in which we share certain personal information as defined by California’s “Shine the Light” with third parties and affiliates for their own direct marketing purposes.

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To receive this information, send us a request using the contact details provided in this privacy policy. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.

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Contact us

For any questions or concerns regarding your privacy, you may contact us using the following details:
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Email: info@summ.com