Privacy Policy

At Summer, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy.

Remember that your use of Summer's Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any capitalized terms we use in this Policy without defining them have the definitions given to them in the Terms of Use. Additionally, we will use and share any Non-Public Information as defined by the Gramm-Leach-Bliley Act (“GLBA”) that we collect from or about you in accordance with our Consumer Privacy Notice.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies, relates to, or describes a particular individual or household and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. 

This Privacy Policy does not cover the practices of third parties, people we don’t manage, or Personal Data that we handle solely as a service provider/processor for the organizations that sponsor your access to the Services, such as your employer, the company that employs a member of your household or someone referred by you, your retirement plan provider, your insurance provider, third-party administrators, or other business customers (each a “Business Partner”) in which case such Business Partner may direct our processing activities. In those cases, the Business Partner’s privacy notices would govern how your information is used. For questions about that processing, please contact the Business Partner through which you receive access to the Services. If we receive Personal Data from both a Business Partner and from you directly, or from another source described in Categories of Sources of Personal Data below, this Privacy Policy will  apply to any Personal Data obtained from you directly or such other sources, as applicable.  

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we may collect or have collected over the past 12 months:

Sensitive Personal Data

 Certain categories of Personal Data are classified as sensitive under applicable state privacy laws and collected by Summer, including social security numbers, financial account information, precise geolocation data (if relevant). Where we collect sensitive Personal Data, we obtain your affirmative opt-in consent before processing such data for purposes beyond what is strictly necessary to provide our Services, as required by applicable law. We do not sell sensitive Personal Data.

Categories of Sources of Personal Data

We collect only the Personal Data that is reasonably necessary to provide the Services and we retain it as long as necessary to fulfill the purposes described in this Policy or as required by law. We collect Personal Data about you from the following categories of sources:

• You
  
  • When you provide such information directly to us.
    
    • When you create a Summer account or use our interactive tools and Services.
    • When you voluntarily provide information in free-form text boxes or upload documentation (such as receipts, grades, and student loan records) through the Services or through responses to surveys or questionnaires.
    • When you send us an email or otherwise contact us.
    • When you authorize a third party (e.g. your student loan servicer) to provide information regarding your student loans via TransUnion or otherwise.
    • When you use or interact with a chat feature on or in our Services.
    • When you use the search features on our website or in our Services.
  • When you use the Services and such information is collected automatically based on the settings and configurations on your device(s).
    
    • Through Cookies (defined below).
    • If you use a location-enabled browser, we may receive information about your location.
    •  If applicable, if you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

•  Government Records‍
  
  • From the government or other public sector sources (e.g. the Department of Education, Federal Student Aid) when the government or other public sector source makes the information available to the public and/or with your authorization.

•  Third Parties Sources‍
  
  • Vendors/Service Providers
    
    • You may be offered the option to authorize us to obtain information about you from third party sources as you navigate the website. For example, for some of our products, you may have the option to authorize us to obtain information from a consumer reporting agency. Although the credit report we obtain may contain a broad range of information about your credit history, we are obtaining your credit report to identify and verify the details of your student loan(s), verify other data points for eligibility for certain programs and if applicable, provide you with a view of your overall debt. If we have the ability to limit the information we receive we will do so; otherwise, if we receive a broader range of information, we will not use any other information contained in your credit report to make any lending decisions. You have the right to withdraw your consent to our ongoing or periodic acquisition of your credit reports on Summer’s platform at any time; however, withdrawal of consent will limit your full use of certain Services. 
    • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
  • Your Employer or other organization sponsoring Services to you
    
    • Your employer may provide information to authorize an account for you, including but not limited to attributes about your identity or employment relevant to Summer’s provision of the Services.
    • Your employer may provide information certifying your employment.
  • Social Media Authentication
    
    • As applicable, if you provide your social network account credentials to us or otherwise sign into the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

Our Business Purposes for Collecting Personal Data

• Providing, Customizing and Improving the Services
  
  • Creating and managing your account or other user profiles.
  • Providing you with the products, services or information you request.
  • Meeting or fulfilling the reason you provided the information to us.
  • Providing support and assistance for the Services.
  • Improving the Services, including testing, research, internal analytics and product development.
  • Personalizing the Services, website content and communications based on your preferences.
  • Doing fraud protection, security and debugging.

• Marketing the Services
  
  • Marketing the Services to you, including making you aware of updated offerings that may be of interest to you.

• Corresponding with You
  
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Summer or the Services.
  • Sending emails and other communications, such as in-app chats, according to your preferences or that display content that we think will interest you.

• Meeting Legal Requirements and Enforcing Legal Terms
  
  • Fulfilling our legal and compliance obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
  • Protecting the rights, property or safety of you, Summer or another party.
  • Enforcing any agreements with you and/or your sponsor.
  • Responding to claims that any posting or other Content violates third-party rights.
  • Resolving disputes.
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How We Disclose Your Personal Data

We do not sell your Personal Data. We disclose your Personal Data to the categories of service providers and other parties listed in this section.

• Vendors/ Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
  
  • Hosting, technology and communication providers.
  • Security and fraud prevention tools.
  • Customer support vendors.
  • Product fulfillment and delivery providers.
  • Consumer reporting agencies.
  • Certain Services are  enabled by our bank partner, OMB Bank. By using these Services you agree to having your Personal Data collected, used by and transferred to our bank partner pursuant to its Consumer Privacy Notice.  
  • Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
    
    • Companies that track how users found or were referred to the Services.
    • Companies that track how users interact with the Services.‍
• Business Partners. These parties partner with us in offering various Services to you. They include:
  
  • Businesses that you have a relationship with, including your employer and other organizations that may sponsor your access to Summer. Summer will need to share some of the information you provide to us with your employer in order to provide certain Services and will only share the information necessary to provide our Services. In addition, certain business partners request that we share usage and other data with them. We will ask you for your consent before sharing your information with a business partner. If you do not agree to having your information shared or wish to withdraw your prior consent, you may dis-enroll from Summer’s platform. Please note that Summer will not be able to provide you with Services once you leave the platform. ‍
• Law Enforcement and in response to Legal Requests. They include:
  
  • Law enforcement, governmental authorities or other third parties if we believe in good faith that such disclosure is necessary to comply with applicable law or regulation, court order or other legal process. Where permitted and feasible, we will make reasonable efforts to notify you before disclosing your Personal Data in response to a legal request, unless doing so is prohibited.
• Parties You Authorize, Access or Authenticate‍
  
  • Third parties whose products you choose to access through the Services.
  • Current and former employers, as applicable to provide the Services to you.
  • U.S. Department of Education and its affiliates.
    
    • If you decide to submit a Financial Program Application (as defined in the Terms of Use), we disclose your Financial Program Application materials, including your Student Loan Information, to the U.S. Department of Education, which may further disclose your Financial Program Application materials, including your Student Loan Information, to its affiliates, such as student loan servicers. We encourage you to visit the U.S. Department of Education website to learn more about how it treats your Personal Data  when you apply for PSLF or an IDR plan.‍
  • We may also disclose Personal Data to our affiliates, contractors, and personnel, solely as necessary to provide Services and subject to confidentiality and data protection obligations.

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‍Legal Obligations

We may disclose any Personal Data that we collect to third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Business Purposes for Collecting Personal Data” section above. We do not disclose nonpublic personal information about our customers or former customers to non-affiliated third parties, except as permitted by law. If we intend to share such information for purposes not permitted by law, we will provide you with an opportunity to opt out of such sharing as required by GLBA.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). 

Data that is Not Personal Data

We may create de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such de-identified or anonymized data and disclose it to third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.

Cookies and Similar Technologies

The Services use cookies and similar technologies such as pixel tags, web beacons, transparent GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Our Services may support certain automated opt-out controls such as Global Privacy Control (GPC), which is a specification designed to allow Internet users to notify businesses of their privacy preferences. If your browser or device is enabled to transmit a GPC signal which our systems are able to detect and it points to your Personal Data in our systems, we will treat it as a valid opt-out request for the sharing of such Personal Data.

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and disclose information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

• Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.”
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You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

Session Replay Technology. We may use session replay technology for a variety of reasons including, identifying and resolving customer issues, monitoring and analyzing how you use our Services to better understand user behavior, and improving our Services. This technology may record your interactions with the Services, including searches, chat features, keystrokes, mouse movements, and page navigation. By continuing to use the Services, you consent to the use of session replay technology and the sharing of data collected using such technologies with third parties.

Data Security and Retention

We maintain a comprehensive written information security program designed to protect the confidentiality and integrity of your personal information, and comply with applicable laws. We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You can help protect your information by selecting strong, unique passwords, enabling multi-factor authentication when available, installing reputable anti-virus and anti-malware software, regularly applying operating-system and browser updates, and declining to download or activate unverified software, plug-ins, or extensions. Please remain vigilant against phishing emails, texts, or calls that request credentials or redirect you to counterfeit websites, and verify any communication that purports to originate from us before responding. Always limit access to your device and browser and sign off when finished. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure. We will provide notifications of security incidents as required by applicable law.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services or operate our business. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. If you request that we remove your Personal Data from our systems, we will do so within 30 days, if permitted by our legal and regulatory obligations. We may further retain information in an anonymous or de-identified form where that information would not identify you personally. 

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 13 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at support@meetsummer.com.

Where prohibited by state law, we do not process Personal Data of consumers between the ages of 13 and 17 for purposes of targeted advertising or profiling without the consumer's affirmative opt-in consent.

U.S. State Law Privacy Rights. In the United States, depending on your state of residence, and subject to certain exceptions, you may have some or all of the following rights:  

• Know and Access: The right to request that we disclose to you the Personal Information we collect, use, or disclose, and to access the same. 
• Correction: The right to request that we correct inaccurate Personal Information that we maintain and manage about you.
• Deletion: The right to request that we delete Personal Information that we have collected from or about you.
• Portability: The right to obtain a copy of your Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format.  
• Opt Out: The right to opt out of the processing of your Personal Information for purposes of targeted advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

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To submit a request to exercise your rights set forth in this section, and as applicable, to appeal a consumer rights action, you may contact us at support@meetsummer.com. We may require that you verify your identity to respond to your request. You may make a request up to twice during a 12-month period. We will not discriminate against you for exercising your rights pursuant to applicable state laws. If you designate an authorized agent to submit privacy requests on your behalf, we reserve the right to validate the agent's authority and your identity before processing such requests.

We will respond to verifiable consumer requests within 45 days of receipt. This period may be extended by an additional 45 days where reasonably necessary, with notice to you. If we decline to take action on a request, you may appeal that decision by contacting us at support@meetsummer.com, and we will respond to your appeal in accordance with applicable law. Where a state law provides protections that differ from or exceed this Policy, those additional protections apply to residents of that state.

Updates to this Privacy Policy

We’re constantly improving our Services, so we may need to update this Privacy Policy from time to time. We will alert you to any material updates by sending you an email. For non-material updates, the Privacy Policy will be updated with a new date on the Summer website. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your current email address) we will be unable to provide you with email notice. The updated Privacy Policy will still govern your use of the Services, and you are still responsible for reading and understanding it. If you use the Services after any updates to the Privacy Policy have been posted, that means you agree to all of the updates. 

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

• https://www.meetsummer.com●      support@meetsummer.com
• support@meetsummer.com
• 199 Water St., 34th Floor, New York, NY, 10038