Summit Public Affairs
Revised as of November 15, 2023
SUMMIT PUBLIC AFFAIRS is a United States Limited Liability Company subject to the laws of the United States. The United States may not offer a level of privacy protection as great as that offered in other jurisdictions. Since our servers are located in the United States, your data may be transferred to, stored, or processed in the United States. By using our Services, you understand and consent to the collection, storage, processing, and transfer of your data to our facilities in the United States and those third parties we share your data with as described in this Policy and our Terms and Conditions of Use.
A Special Notice about Children
Children (under the age of 18) are not eligible to use the Website unsupervised, and we ask that children do not submit any personal information to us. If you are under the age of 18, you may only use this Website in conjunction with, and under the supervision of your parents or guardians.
Users Under 13 Years of Age
The Website is not directed to children under the age of 13. We do not knowingly collect information, including Personal Information, from children or other individuals who are not legally able to use our Website and Services. If we obtain actual knowledge that we have collected Personal Information from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13, via our contact form or by writing to us at email@example.com. By using the Services, you are representing to us that you are not under the age of 13.
In general, you may visit the Website without telling us who you are or revealing any of your personal information. There are two primary ways SUMMIT PUBLIC AFFAIRS will collect your personal information:
First, SUMMIT PUBLIC AFFAIRS may collect information submitted when creating a user account, requesting or downloading one of our publications, sending us an email, telephoning us, by subscribing to our newsletter, or by your communicating with us on social media, including any personal information you submit. Whether or not you choose to provide personal information is entirely up to you.
Second, SUMMIT PUBLIC AFFAIRS may track the domain address from which you visit the Website through cookies (see “Cookies” Section below), analyze this data for trends and statistics, and use the information for internal marketing purposes. SUMMIT PUBLIC AFFAIRS will never sell your information to third parties.
The manner in which we will collect and use your information is set forth below.
Collection and Use of Personal Information
We will collect all the information that you supply to us including personal information and personal messages you submit. The collection of this information enables us to provide you with the services, assistance, information, and content you have requested. In furtherance of these objectives, SUMMIT PUBLIC AFFAIRS may collect the following personal information:
Contact Information: If you submit your name, email address, phone number, billing address, or any other personal contact information on our user account information form, contact form, or via email or other communication mechanism, then you are deemed to have given consent for us to use such information to contact you (“Contact Information”).
Customer Information: We may record and retain records of your specific personal information and messages submitted to us through the user account information form, contact form, or email or other communication mechanism (“Customer Information”).
Credentials: We collect passwords, password hints, and similar security information used for authentication and account access.
Statistical Information: We may gather statistical information from website visitors and analyze this data for trends and statistics (“Statistical Information”).
Data Integrity and Purpose Limitation
We only collect Personal Information that is relevant for providing the Services. We process Personal Information in a way that is compatible with providing the Services or as otherwise authorized by you. We take reasonable steps to ensure that Personal Information is reliable for its intended use, accurate, complete, and current.
SUMMIT PUBLIC AFFAIRS adheres to the U.S. safe harbor policy privacy principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. If you have any questions regarding this policy, contact SUMMIT PUBLIC AFFAIRS through the Contact Form or write to us at: firstname.lastname@example.org .
Some consumers may not know that cookies are being placed on their computers when they visit websites. If you want to know when this happens, or to prevent it from happening, you can set your browser to advise you when a website attempts to place a cookie on your computer.
Do We Share Your Information?
We may only share your personal information with third-party independent suppliers for purposes of tracking information generated through the Website for marketing purposes. If we engage a third-party independent supplier, they will be obligated not to use or share your personal information for unauthorized purposes.
We will never sell, rent, or lease your personal information to a third party.
SUMMIT PUBLIC AFFAIRS may use your Collected Information in the following ways:
Contact Information: We may use your Contact Information to provide information that you have requested, provide services associated with your business registration, send you a requested publication, or send you our newsletter as published if you have subscribed. Specifically, we may use your email address and phone number to contact you.
Customer Information: Any Customer Information that you disclose to us may be used to respond to your inquiries submitted to us.
Payment Information: We may use your payment information to process payment for memberships and other services requested by you.
Statistical Information: We may use Statistical Information to help diagnose problems with and maintain our computer servers, to manage our Website, and to enhance our Website and services based on the usage pattern data we receive. We may generate reports and analysis based on the Statistical Information for internal analysis, monitoring, and marketing decisions. We may provide Statistical Information to independent third parties for marketing purposes, but when we do so, we will not provide them with any personal information.
We may also disclose your personal information to comply with a court order, subpoena, search warrant, or other legal process; to comply with legal, regulatory, or administrative requirements of any governmental authorities; to protect and defend SUMMIT PUBLIC AFFAIRS, its subsidiaries and affiliates, and their officers, directors, employees, attorneys, agents, contractors, and partners, in connection with any legal action, claim, or dispute; to enforce the Terms and Conditions of Use of the Website; to prevent imminent physical harm; and in the event that we find that your actions on the Website violate any laws.
Accessing and Modifying Account Information.
You may update the information that is stored in your user account by visiting our sign in page of your user account or by emailing us at email@example.com .
You may “Opt out” of having your personal information shared by providing us with written notice identifying which communications you choose not to receive by writing to us at: firstname.lastname@example.org .
Specifically, we will retain your Personal Information while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly; or
• To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymize it.
We may contract with third parties to maintain and host the Website. Any information you submit to us, including personal information, may be placed, and stored on a computer server maintained by this third-party host.
SUMMIT PUBLIC AFFAIRS does not provide the technologies used to build this Website, and therefore, neither recommends nor endorses the same. Any information regarding identified technologies, including their capabilities, limitations, and applications, should be sought directly from their manufacturers. SUMMIT PUBLIC AFFAIRS hereby disclaims any rights to trademarks, service marks, trade names, logos, copyrights, patents, domain names, or other intellectual property interests of third parties.
Links to Other Material
The Website may contain links to other websites, including but not limited to, Facebook, Twitter, Instagram, YouTube, and LinkedIn. These links and plug-ins are for your convenience. Websites linked to and from the Website are not necessarily under the control of SUMMIT PUBLIC AFFAIRS and SUMMIT PUBLIC AFFAIRS shall have no responsibility or liability whatsoever for the content or privacy practices of any linked websites, or any link or linking program at any time. You should read and understand our policies with respect to such third-party links, as stated in the Terms and Conditions of the Website.
The Website uses commercially reasonable security measures to protect the loss, misuse, and alteration of the information under our control; however, no system is impenetrable.
We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet. Specifically, E-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Privacy Rights Notice to California Residents
The State of California enacted the Shine the Light law (California Civil Code Section 1798.83) that permits users who are California residents to request certain information regarding the disclosure of certain “personal information” during the past year for marketing purposes. To make such a request, please contact us using our contact form or alternatively write to us at email@example.com .
Your Rights Under California Consumer Privacy Act of 2018 (CCPA)
Disclosure of Personal Information We Collect About You
You have the right to know:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information is collected;
- Our business or commercial purpose for collecting or selling personal information;
- The categories of third parties with whom we share personal information, if any; and
- The specific pieces of personal information we have collected about you.
Please note that we are not required to:
- Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
- Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
- Provide the personal information to you more than twice in a 12-month period.
- Personal Information Sold or Used for a Business Purpose
In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
- The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
- The categories of personal information that we disclosed about you for a business purpose.
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale [or disclosure] of your personal information. If you exercise your right to opt-out of the sale [or disclosure] of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale [or disclosure] of your personal information, by emailing us at firstname.lastname@example.org .
Right to Deletion
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
- Delete your personal information from our records; and
- Direct any service providers to delete your personal information from their records.
Please note that we may not delete your personal information if it is necessary to:
- Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
- Comply with an existing legal obligation; or
- Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination
You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
- Deny goods or services to you;
- Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Provide a different level or quality of goods or services to you; or
- Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to our business by your personal information.
Your Rights Under GDPR
Right to Access: The right to be provided with a copy of your personal information (the right of access).
Right to Rectification: The right to require us to correct any mistakes in your personal information.
Right to be Forgotten: The right to require us to delete your personal information—in certain situations.
Right to Restriction of Processing: The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data.
Right to Data Portability: The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object: The right to object:(a)at any time to your personal information being processed for direct marketing (including profiling); (b) in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
Effective Date and Changes
YOUR CONTINUED USE OF THE WEBSITE FOLLOWING OUR POSTING OF A CHANGE NOTICE WILL CONSTITUTE BINDING ACCEPTANCE OF THOSE CHANGES.