Privacy Policy

Summitones (“Summitones”, “we”, or “our”) is committed to protecting consumer privacy and handling personal information responsibly. We adhere to industry best practices and data protection standards to safeguard the information we collect from our customers, partners, and users.

This Privacy Policy outlines how we collect, use, share, and protect information obtained through:

  1. Our corporate website and affiliated sites under our control (collectively, the “Websites”), including those linking to this Privacy Policy.
  2. Our proprietary advertising platforms and services (the “Advertising Technology Products”), which include data-driven tools used for campaign optimization and media delivery.

This policy is intended for:

  • Publishers using our platforms to monetize their websites and applications,
  • Advertisers working with us to promote products and services, and
  • End users visiting our Websites or engaging with digital properties using our Advertising Technology Products.

Publishers and Advertisers may have their own privacy policies in addition to this one, especially where their websites or ads involve independent data collection and use.

Information We Collect

We collect information in several ways, including directly from you and automatically through our technology platforms:

Information You Provide

You may provide us with personal or business information by:

  • Signing up for newsletters
  • Filling out forms on our Websites
  • Sending inquiries via email
  • Registering for our services as a Publisher or Advertiser

This may include:

  • Name, email address, and phone number
  • Business information, including tax ID or payment details
  • Contact information required for billing, service delivery, and account support

Account Holders (Publishers or Advertisers approved for our services) may also be asked to provide banking or credit card information to facilitate transactions. This data is kept secure in a password-protected environment.

Account Holders may update or change their information at any time by contacting their assigned account manager.

Information We Collect Automatically

We may automatically collect the following types of data via our Websites and Advertising Technology Products:

  • Cookies: Small text files stored on your device that help identify your browser or session. These are used to personalize experiences and manage ads. You can manage cookie preferences via your browser settings.
  • Device Information: Data such as your browser type, operating system, and device identifiers.
  • IP Address: Used to understand general location and maintain security.
  • Location Data: May be collected directly (e.g., via mobile apps with permission) or inferred via IP address to tailor content and advertising.
  • Analytics: We use third-party tools to analyze usage patterns and improve our services. These may include web beacons and cookies.
  • Log Files: Our servers may log page visits, referral URLs, and session behavior for security and optimization.
  • Web Beacons: Small graphic tags used to monitor activity and collect non-personal data about your interaction with content.
  • Emerging Technologies: As we evolve, we may test and implement new tracking or analytic technologies in compliance with legal requirements.

How We Use Information

We use the collected data for the following core purposes:

  1. Personalization and Optimization: To tailor website content, improve user experience, and deliver relevant ads.
  2. Ad Frequency Management: To control the number of times users see specific ads.
  3. Retargeting: To display ads to users who have previously interacted with Advertiser websites.
  4. Interest-Based Advertising (IBA): To serve ads based on inferred interests. Data is retained for 60 days, then aggregated for analytics and reporting for an additional two years.
  5. Business Operations: Including audits, customer service, contractual obligations, and platform performance monitoring.

Public Forums and Interactive Features

Some of our Websites may offer forums, blogs, surveys, or comment sections. Any information you disclose in these public areas may become publicly accessible. Please use discretion when posting.

Third-Party Websites and Advertisements

Summitones’s Websites may contain links to third-party websites and advertisements. We are not responsible for the privacy practices or content of these sites. Third parties may place their own cookies or tracking technologies. Please review their privacy policies before sharing any data.

We may also engage advertising partners, including those using platforms such as Google Ads or Google Analytics, to deliver tailored ads. Users can manage their preferences or opt out using:

Google Ad Preferences and opt-out tools

Information Sharing

We share your information in limited circumstances:

With Service Providers

We engage third-party vendors for services like data processing, email distribution, ad delivery, and payment facilitation. These partners may access your information solely to perform contracted functions and are required to maintain confidentiality.

With Affiliates

We may share information with affiliated entities for internal purposes, such as platform improvement and customer service.

With Other Third Parties

We may share non-identifying or aggregated information with partners to measure ad performance and improve our services.

Legal and Compliance

We may disclose information:

  • To comply with legal requirements or respond to lawful requests by authorities.
  • To protect rights, safety, and property — our own, yours, or others’.
  • In connection with fraud prevention or investigation of illegal activity.

In a Business Transfer

If Summitones is involved in a merger, acquisition, reorganization, or asset sale, user information may be transferred as part of the transaction.

With Your Consent

We may disclose your information for specific purposes with your explicit consent.

Your Rights and Choices

Depending on your jurisdiction, you may have the right to:

  • Access, update, or delete your personal data
  • Object to certain uses of your information
  • Opt out of marketing communications or targeted advertising

To exercise any of these rights, please contact us at:

We respond to requests in accordance with applicable law.

Policy Updates

We may revise this Privacy Policy occasionally to reflect changes in law, our practices, or our services. Updates will be posted on this page with an updated “Effective Date.” Continued use of our services after updates indicates your acceptance of the revised policy.

Information Security & Storage

We collect personal information through forms, emails, and account registration to respond to inquiries, provide services, and for limited marketing use. Information is stored securely for record-keeping and promotional efforts and retained:

  • Up to 60 days for interest-based advertising.
  • Up to 2 years for data analysis, audit, and compliance.

We may collect data such as IP address, browser type, content viewed, ad interactions, ISP, and time/date of visits.

All data is secured in password-protected systems and handled using industry-standard safeguards

Security Practices

We treat data as a protected asset. Security measures include:

  • Industry-standard safeguards
  • Protections against unauthorized internal and external access

Advertising Compliance & Third-Party Standards

  • Summitones is a member of the Network Advertising Initiative (NAI) and adheres to its Code of Conduct.
  • We do not conduct retargeting for prescription drugs, but may for non-prescription consumer health products (e.g., fitness gear, calorie trackers).
  • We may work with third-party NAI members for data enhancement.

TRUSTe Certification

Summitones participates in the TRUSTe Ads Program. For unresolved privacy concerns, contact TRUSTe at:
🔗TRUSTe Watchdog

Your Rights & Choices

Emails:

  • Business-related emails cannot be opted out of.
  • Promotional emails include an opt-out link in the footer.

Account Holders:

  • Update your info via your account representative.

Opting Out of Ads:

  • Summitones Ads:Opt-out link places a cookie to stop retargeting. Clear cookies or change browsers/devices to reapply opt-out.
  • Connected TV Ads:NAI CTV Opt-Out
  • Mobile Apps:
    • Android: Enable “Opt out of Interest-Based Ads”

iOS: Enable “Limit Ad Tracking”

Children’s Privacy

Our services are for users 21+. We do not knowingly collect data from children under 16.
If you believe we have collected such data

California Privacy Rights

Shine the Light

California users may request info on personal data disclosures to third parties for marketing by emailing: 

California Consumer Privacy Act (CCPA)

We collect and use the following categories of personal information:

Category

Examples

Collected From

A. Identifiers

Name, email, IP, cookie ID

Website, ValidClick, IntentKey

B. Customer Records Info

Name, email, address

Website

F. Internet Activity

Browsing history, ad interactions

All

G. Geolocation Data

Location (from IP)

Website, ValidClick

Note: No collection of biometric, education, or sensory data.

Use of Data

Personal data may be used to:

  • Provide services, fulfill requests, personalize content
  • Prevent fraud, maintain security
  • Research and develop new services
  • Comply with laws and regulatory requests
  • Support potential mergers, acquisitions, or business transfers

We do not sell your information for materially different purposes without prior notice.

Sharing of Personal Information

We may disclose your Personal Information to third parties for a business purpose under written contracts that:

  • Specify the purpose of disclosure,
  • Require the recipient to keep the information confidential,
  • Prohibit use for purposes other than performing the contract.

In the past 12 months, we have disclosed or sold Personal Information as outlined below.

CCPA “Sale” Disclosure

The CCPA defines a “sale” broadly as any exchange of Personal Information for value. Based on this definition, we may sell your Personal Information to third parties. You have the right to opt out of such sales.

Summary of Disclosures and Sales

Personal Information Category

Disclosed for Business Purpose

Sold to Third Parties

A. Identifiers

Website Users, ValidClick, IntentKey

Website Users, ValidClick, IntentKey

B. Customer Records (California Civil Code § 1798.80(e))

No

No

C. Protected Classification Characteristics

No

No

D. Commercial Information

No

No

E. Biometric Information

No

No

F. Internet or Network Activity

Website Users, ValidClick

Website Users, ValidClick

G. Geolocation Data

No

No

H. Sensory Data

No

No

I. Professional or Employment Information

No

No

J. Non-Public Education Information

No

No

K. Inferences Drawn from Other Personal Information

IntentKey

IntentKey

Your Rights Under the CCPA

If you are a California resident, the CCPA grants you specific rights:

  1. Right to Know / Data Portability

You have the right to request:

  • What categories of Personal Information we collected about you,
  • The sources of that information,
  • The purpose of the collection or sale,
  • Third parties with whom we shared it,
  • Specific pieces of Personal Information we have collected.

We do not offer this right to B2B data subjects.

  1. Right to Delete

You may request deletion of your Personal Information, subject to certain legal and business-use exceptions (e.g., fraud prevention, regulatory compliance, product recall support, internal uses).

We do not offer this right to B2B data subjects.

How to Exercise Your Rights

Submit your request through one of the following methods:

 

You may only make two verifiable consumer requests within a 12-month period. Your request must:

  • Allow us to verify your identity and California residency,
  • Clearly describe the request.

We will respond within 45 days (or 90 days with notice). Our response will cover the prior 12 months and be provided in a portable, readily usable format.

Opt-Out of the Sale of Personal Information

To opt out of the sale of your Personal Information, visit:
👉https://optout.networkadvertising.org/

Non-Discrimination

We will not discriminate against you for exercising your CCPA rights. This means we will not:

  • Deny goods or services,
  • Charge different prices or rates,
  • Provide a different level of quality,
  • Suggest you might receive different pricing or service levels.

We may offer financial incentives permitted under the CCPA, based on the value of your Personal Information. Participation in such programs is voluntary and requires opt-in consent.

International Users

If you access our services from outside the U.S., your data will be transferred to and stored in the U.S. By using our website, you consent to this transfer and processing.

Your Rights Under the GDPR (EEA, UK, Switzerland)

If you are in the EEA, UK, or Switzerland, you have the following rights:

  • Access, rectification, or erasure of your data,
  • Restriction or objection to data processing,
  • Data portability,
  • Withdrawal of consent at any time.

Legal Bases for Processing

We may process your data based on:

  • Your consent,
  • Our legitimate interests (e.g., security, fraud prevention),
  • Contractual necessity,
  • Legal obligations.

When transferring data outside the EEA, we ensure proper safeguards are in place.

Exercising Your GDPR Rights

To exercise any of the above rights, contact us:

 

We may require verification of your identity. If we are processing data on behalf of a client, we may direct you to that client as the primary data controller.

You also have the right to lodge a complaint with your local data protection authority.

Controller and Processor Roles

Depending on context, we may act as:

  • A Data Controller (e.g., when you directly use our services), or
  • A Data Processor (e.g., when acting on behalf of partners like publishers).

If your data was collected by a third-party publisher using our technology, please direct your request to them.

Policy Updates

We may modify this Privacy Policy at any time. Any changes will be posted to our site and reflected with a new “Effective Date.” Continued use of our site indicates your acceptance of the changes.

Contact Us

If you have any questions about this policy or your rights, contact us at: