PRIVACY AND DATA SECURITY STATEMENT
This Statement was last updated: [06/02/2023] and is effective as of that date.
Summa Money including its websites and affiliated entities, (collectively, “our,” “we,” or “us”) values and respects the privacy of its customers and visitors. While operating our business and interacting with you, we collect, use, and share personal information as disclosed in this Privacy and Security Statement.
This Privacy and Security Statement provides you with detailed information about how Summa Money and its subsidiaries, divisions, affiliates, brands and other companies that link to this Privacy and Security Statement collect, use, share, and protect personal information, and describes your choices and rights available. This Statement also applies to personal information we receive from business partners and other third parties. We encourage you to read this Statement carefully and if you have any questions to contact us using the methods listed below.
If you are applying for a job, please see the end of this Privacy and Security Statement with regards to the information we collect in association with your applicant. The remainder of this Privacy and Security Statement does not apply to applicant information.
Understanding Your Data
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How We Collect Information |
How We Share Your Information |
How We Use Your Information |
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We collect your information when you contact us, interact with our digital offerings, or when we received your information from one of our partners. |
We may share, broker or sell your information to our partners or other third parties. We are selective about who we share your information with. We only share, broker or sell personal information in accordance with applicable law. |
We use the information we receive about you to provide you with information about special offers and to provide information about our partners or other third parties. We may sell or broker the information we receive. We also use the information you share with us to maintain and enhance our products/services. |
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Examples of how information might be collected:
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Examples of how information is used:
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What Information Do We Collect?
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Personal Identifiers |
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What does this include? |
Why do we collect this information? |
Where do we collect this information from? |
Who do we share this with? |
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Name, email address, phone number, username, physical address, device identifier, IP address. |
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Customer Records |
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What does this include? |
Why do we collect this information? |
Where do we collect this information from? |
Who do we share this with? |
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Customer’s name, signature, address, telephone number, credit card number, debit card number, or any other financial information. |
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Protected Classification / Demographic Information |
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What does this include? |
Why do we collect this information? |
Where do we collect this information from? |
Who do we share this with? |
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Age, sex, marital status. |
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Commercial Information |
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What does this include? |
Why do we collect this information? |
Where do we collect this information from? |
Who do we share this with? |
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Products or services purchased, purchasing history, and other purchasing or consuming histories or tendencies, including reviews you submit. |
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Internet and Network Activity |
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What does this include? |
Why do we collect this information? |
Where do we collect this information from? |
Who do we share this with? |
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Browsing history, search history, information about your interaction with our websites, applications, electronic communications, or advertisements. |
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Geolocation Data |
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What does this include? |
Why do we collect this information? |
Where do we collect this information from? |
Who do we share this with? |
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Location based on device location or IP address. |
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How Do We Collect Information?
We collect information directly from you.
For example, we collect information when you:
- Make an online or in store purchase
- Submit information via our website or mobile application
- Submit information to our marketing partners using our website
- Request information about a product or service
We collect information from you passively. We occasionally use tools to optimize your experience like browser cookies, pixel tags, and web beacons to collect information when you use our websites and applications to interact with us. For more information and the choices you have regarding these tools, please see our “Tracking Tools” section below.
How Do We Use The Information?
We use the information we collect:
- To provide you with the product, service or information you requested.
- For example, fulfilling orders, delivering reports, ensuring delivery.
- Administering your participation in a contest or promotion.
- Contact you about our websites.
- To improve our products and services, including digital content.
- Monitoring or improving our websites and any related mobile applications.
- Personalizing the content on our digital services.
- To personalize digital content and learning about customer trends and interests.
- Customizing the advertising content you see.
- Researching and analyzing your use of, or interest in, our products, services and content and the products, services and content offered by others.
- Developing and displaying content and services tailored to your interests on our website and other websites.
- To identify the devices used to access digital content.
- Customizing the advertising content you see.
- Developing and displaying content and services tailored to your interests on our website and other websites.
- To prevent fraud, protect Summa Money’s security and assets.
- Verifying compliance with applicable laws and regulations.
- Monitoring compliance with our terms and conditions of service.
- To deliver marketing communications and advertise.
- Providing special offers to you from us and/or affiliates and subsidiaries or other third parties.
- Communicating with you about products or services that may be of interest to you.
Information Sharing
We may sell or share your information for business purposes and as legally required or permitted by law. Below are examples in which we share or sell your information.
- Service providers that process information on our behalf.
- Financial services companies.
- We will disclose information to detect, prevent, and investigate fraud or unlawful activities.
- Marketing and advertising partners.
- We will disclose information to measure the overall effectiveness of our online advertising and content.
- Develop and deliver targeted advertisements.
- We may sell or share your information with our marketing partners for the purpose of providing you with information about their products and services or other products and services.
- Law enforcement, public and government authorities and other entities we deem necessary to comply with law, support investigations, and protect the rights and property of you, us, and others.
- We will disclose information to respond to a court order or subpoena. We may disclose information if a government agency or investigatory body requests it.
- Any successor to all or part of Summa Money.
- If all our part of our business is sold or otherwise acquired, we may sell or disclose our customer lists and other personal information we collect in preparation for or as part of that transaction.
- Our affiliates and subsidiaries.
- Develop and deliver targeted advertisements.
Sharing Information for Marketing Preferences
Summa Money does not sell your data in exchange for monetary consideration. In order to support tailored advertisements, offers, or content that you may find interesting when you browse the internet, Summa Money may share the personal information that you provide to us or that we collect about you with our trusted third party partners that support online advertising, data co-operatives, mobile advertising, data analytics, social media engagement, data brokers advertising networks or any other activity that may be considered cross-behavioral advertising. This transfer could be defined as a sale, sharing for cross-context behavioral advertising or targeted advertising. Summa Money shares the following categories of personal data for this processing activity: (A) persistent identifiers such as unique device identifiers, email addresses, IP addresses, information related to your browser and operation system, and (B) user activity data such as website engagement information and click data.
You can may opt-out of this at any time by going to the “Contact Us” section below for more information.
Children
Our website and mobile applications are not intended for children. We do not knowingly collect or sell information regarding children under 18 years old. If we become aware that anyone under the age of 18 has submitted personal information to us via our online and mobile applications, we will delete that information immediately. If you are a parent or guardian and believe we have information regarding your child, please contact us using the methods below.
Security
We protect our website and your information by using a range of industry standard technological and organizational security controls. We encourage you to use caution when using the Internet as no system us ever completely secure.
Data Storage and Retention
We ensure data is processed in accordance to the Privacy Statement and to the requirements of applicable law of your country
We will store and retain your personal information in accordance with applicable law and as long as necessary to carry out the purposes described in this Privacy Statement in accordance with our internal data retention procedures. The criteria used to determine the retention periods include:
- how long the personal information is needed in connection with the applicable business, legal, or tax purposes for which we use it;
- the type of personal information collected; and
- whether we are subject to a legal, contractual or similar obligation to retain the personal information (e.g., mandatory data retention laws, government orders to preserve personal information relevant to an investigation, or personal information that must be retained for the purposes of litigation or disputes).
Third Party Website Links
This website contains links to third party websites. This Privacy Statement does not apply to the information practices of those websites. We are not responsible for the content on, or the privacy practices of, social media platforms, or any third party sites or apps to which we link. Those apps, sites and platforms are not controlled by us and therefore have their own privacy policies and terms of use. To be clear: neither this statement nor our terms of use appearing on or in any of our online and mobile resources apply to our social media presence or any third party sites or apps to which we may link. That means even if you take an affinity action on our specific social media profile, and identifiers about you are automatically collected and given to us as a result, that collection and transfer is governed by the privacy policies and other terms of the applicable social media platform and are not our responsibility. If you have questions about how those apps, sites and platforms collect and use personal information, you should carefully read their privacy policies and contact them using the information they provide.
Our Tracking Tools
We may collect personal and other information using digital tracking tools, such as cookies and web beacons, when you use our websites or mobile applications, interact with our emails or applications provided on connected devices, or otherwise engage with our digital offerings. We also partner with third parties that collect information this way.
How to Disable Browser Cookies:
Your browser may give you the ability to control cookies, some of which may enable third parties to collect data about your use of our websites. You can adjust your browser settings to block all cookies. Certain browsers also allow you to limit the blocking of cookies to specific websites. You will need to adjust the settings on each browser and on each device for which you wish to block cookies. Please note that disabling cookies may limit the functionality of our websites.
The tools may collect information about your activities over time and on various digital services offered by us or others.
The tools that we, our vendors, and third parties use include:
- Browser and flash cookies. Cookies are small text files that websites send to your computer or other connected device to identify your browser or to store information or settings. Your browser may provide the ability to be notified when you receive certain types of cookies and how to restrict or disable certain cookies.
- Server logs, which record information about the device, browser, operating system, network, and other resources you use to access our digital services
- Web beacons and pixels. These are small electronic images deployed on websites and emails that collect information about how users interact with content
- Application software. Software in our mobile and other connected-device applications collects information about how you interact with the digital services
We, our service providers, and third parties use the information collected via these tools to:
- Identify new visitors and users
- Recognize returning customers
- Learn how you came to access our digital services
- Keep you logged into our digital services
- Personalize your experience on our website, device applications, and third-party social networking websites, plug-ins and applications
- Identify your location as determined by the IP address of your devices
- Optimize and tailor our websites and device applications
- Make product recommendations and provide you with advertising content in which we think you will be interested. As part of this customization, we may observe your behaviors on our device applications, our websites, or on other websites and applications. We may also get information about your browsing history and online activities from our trusted business partners and vendors
- Better understand our audience, our customers, our website visitors and device application users, and their respective interests, including by learning about your online activities across devices
Online Interest-Based Ads
- We work with digital advertising and marketing companies to provide you with ads that meet your interests and that enhance your experience with us. These ads may be displayed on websites or device applications operated by us or third parties, and they may be based on information about your activities or preferences collected by us or third parties. These third parties collect information with their own cookies, pixels, and related tracking technology.
Certain coalitions of advertisers allow consumers to opt out of receiving interest-based advertising from members of the coalitions. Please follow the links below to opt out of receiving interest-based advertising from members of these coalitions. You will need to exercise these opt outs on each browser on each device for which you wish to opt out of interest-based advertising.
Our “Do Not Track” policy: Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These browser features are not uniform and, therefore, we do not have a uniform response to those signals. However, Summa Money does not typically track your browsing behavior and, therefore, do not track signals are not necessary.
Exercising Your Privacy Rights
Summa Money takes your privacy seriously. When you submit a request to exercise your rights, we will respond as appropriate within the timeframe permitted under applicable law. We will retain your request and our response (including any supporting documentation) in compliance with applicable law. We may also retain your personal information to the extent required to comply with applicable law, or, to establish, exercise or defend our legal claims and rights.
If you are a resident of the United States or its territories, you may request to access your information, delete your information, and opt out of the sale of personal information.
- Right to Know
- You have the right to request information about your collection, use, and disclosure of your personal information in the past 12 months, including:
- The categories of personal information we collected about you;
- The categories of sources from which we collected that information;
- Our business or commercial purpose for collecting that information;
- The categories of third parties with whom we shared that information; and
- The specific pieces of personal information we collected about you.
- You have the right to request information about your collection, use, and disclosure of your personal information in the past 12 months, including:
- Right to Access
- You have the right to receive a copy of the categories and specific elements of personal information we collected about you in the preceding 12 months.
- The Right to Delete
- You have the right to request that we delete the personal information we collected about you under certain circumstances.
- Right to Opt Out of Sales
- You have the right to direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information.
- Non-Discrimination
- If you exercise these rights, we will not discriminate against you by treating you differently from other individuals who use our sites and mobile resources or purchase our services but did not exercise their rights.
The information you provide will be analyzed to determine whether we can reasonably verify your identity. We may require additional information to process your request.
If you are an authorized agent acting on behalf of a US resident, please email your privacy request using the designated contact methods below and provide the following information about yourself and the person on whose behalf you are submitting the request: full name, mailing address, email address, and phone number. Please provide proof of authorization to act on the other person’s behalf.
California Shine the Light
If you live in California and have an established business relationship with us, you can request, once per year, a list of personal information we have shared with third parties for their direct marketing purposes. Please mention in you are making a “California Shine the Light” inquiry when contacting us using the methods below. We will respond in 30 days.
How to Contact Us
If you have any questions about our privacy and data security policies, procedures and practices, including anything we say in this privacy statement, we encourage you to contact our Privacy Office.
Darwin Investor Network
c/o: Summa Money
2319 N Andrews Avenue
Fort Lauderdale, FL 33311
877-353-6787
ccparequest@darwininvestornetwork.com
Updates to this Privacy Statement
From time to time we may offer additional products or feature additional services which may require we make material changes to this Privacy Statement. When we do, we will revise the date to reflect the most recent update and may provide you with additional notice (such as an email) with more information about our revisions. Unless otherwise stated, these material changes will become effective when posted on our website.