Summits Exchange
Limited (in incorporation) (“us“, “we” or “Company“) respect the privacy of our users
(each, “you” or “User“) and are committed to protect the privacy of Users who access, download, install or
register to our mobile application (the “Application“), our website or any other online services we
provide (collectively: the “Services“). The Company has papered this Privacy Policy to outline our
practices with respect to collecting, using and disclosing your information when you use the Services. We
encourage you to read the Privacy Policy carefully and use it to make informed decisions. By using the
Services, you agree to the terms of this Privacy Policy and your continued use of the Services constitutes
your ongoing agreement to the Privacy Policy. The Privacy Policy is a part of the Terms of Service and is
incorporated there in by reference. In this Privacy Policy you will read about, among other things:
* With whom we share the information and for what purpose
* For how long we retain the information
* How we protect your information
* Advertisements
* Advertising ID and Advertising Identifier
* Cookies and Google Analytics
WITH WHOM WE SHARE THE INFORMATION AND FOR WHAT PURPOSE
We do not rent, sell, or share your Personal Information with third-parties except as described in this
Privacy Policy. We may share Personal Information with the following recipients: (i) our subsidiaries;
(ii) affiliated companies; (iii) subcontractors and other third-party service providers; (iv) auditors or
advisers of our business processes; and (v) any potential purchasers or investors in the company. In
addition to the purposes listed in this Privacy Policy, we may share Personal Information with our
recipients for any of the following purposes: (i) storing or processing Personal Information on our behalf
(e.g., cloud computing service providers); (ii) processing such information to assist us with our business
operations; (iii) performing research, technical diagnostics, personalization and analytics. We may also
disclose Personal Information or any information you submitted via the Services if we have a good faith
belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any
applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including
investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action
regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or
exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of
us, our affiliates, our Users, yourself or any third-party; (vi) for the purpose of collaborating with law
enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or
other legal rights.
FOR HOW LONG WE RETAIN THE INFORMATION
We respect your privacy rights and therefore you may contact us at any time and request: (i) to access,
delete, change or update any Personal Information relating to you (for example, if you believe that your
Personal Information is incorrect, you may ask to have it corrected or deleted); or (ii) that we will
cease any further use of your Personal Information (for example, you may ask that we will stop using or
sharing your Personal Information with third-parties) or that we shall remove your Personal Information
(subject to any other legal obligation that may require us to keep the information). Please note that
unless you instruct us otherwise we retain the information we collect for as long as needed to provide the
Services and to comply with our legal obligations, resolve disputes and enforce our agreements. We may
rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
If you wish to raise a complaint on how we have handled your Personal Information, please contact us
directly at . If you are not satisfied with our response or believe we are collecting or processing your
Personal Information not in accordance with the laws, you can complain to the applicable data protection
authority.
HOW WE PROTECT YOUR INFORMATION
We take great care in implementing and maintaining the security of the Services and your information.
We employ industry standard procedures and policies to ensure the safety of your information and prevent
unauthorized use of any such information. Although we take reasonable steps to safeguard information, we
cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we
make no warranty, express, implied or otherwise, that we will prevent such access. If you feel that your
privacy was treated not in accordance with our policy, or if any person attempted to abuse the Services or
acted in an inappropriate manner, please contact us directly at .
ADVERTISEMENTS
We may use a third-party advertising technology to serve advertisements when you use the Services. This
technology uses your information with regards to your use of the Services to serve advertisements to you
(e.g., by placing third-party cookies on your web browser). We may also use our third-parties and share
with them Users’ information to assist us in evaluating the success of our advertising campaigns and help
us retargeting our Users. You may opt-out of many third-party ad networks, including those operated by
members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For
more information about this practice by NAI and DAA members, and your choices regarding having this
information used by these companies, including how to opt-out of third-party ad networks operated by NAI
and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and
http://optout.aboutads.info/#!/.
ADVERTISING ID AND ADVERTISING IDENTIFIER
The Google Advertising ID is an anonymous identifier, provided by Google Play services. If your device
has an Advertising ID, we may collect and use it for advertising and user analytics purposes. We may also
use Apple’s Advertising Identifier (IDFA), which is a non-permanent device identifier provided by Apple,
and any information obtained through the use of the Advertising Identifier, for the purpose of
advertising. By downloading the Application or using the Services you explicitly agree that we may
associate your Advertising ID and your Advertising Identifier with your applicable persistent device
identifier. This will facilitate our ability to improve your personalized experience. Further, we may use
other persistent identifiers for non-advertising purposes. If your device does not have Advertising ID or
Advertising Identifier respectively, we will use other identifiers.
UPDATE OR AMMENDMENTS TO THE PRIVACY POLICY
We may revise this Privacy Policy from time to time, in our sole discretion, and the most current
version will always be posted on our website or Application (as reflected in the “Last Revised” heading).
In the event of a material change to the Privacy Policy, we will notify you through the Services or via
email, or you may be notified within the Application. We encourage you to review this Privacy Policy
regularly for any changes. Your continued use of the Services, following the notification of such
amendments, constitutes your acknowledgement and consent of such amendments to the Privacy Policy and your
agreement to be bound by the terms of such amendments.
