Privacy Policy

1. Introduction and Scope

Summit Fundings, LLC (hereinafter referred to as “Summit Fundings,” “Company,” “we,” “our,” or “us”) is committed to protecting the privacy, confidentiality, and security of your personal and business information. This Privacy Policy (hereinafter referred to as “Policy”) describes in detail the types of information we collect from and about you when you visit our website located at summitfundings.com (the “Site”), submit an application, or otherwise interact with our business funding brokerage services (collectively, the “Services”). This Policy further describes how we use, disclose, store, retain, and safeguard such information, and the rights and choices available to you regarding your information.

This Policy applies to all information collected through the Site and Services, as well as any information collected through related email, text, or other electronic communications sent through or in connection with the Site and Services. By accessing or using the Site or Services, or by providing any information to us, you acknowledge that you have read, understood, and agree to the collection, use, disclosure, and processing of your information as described in this Policy. If you do not agree with the practices described herein, please do not access or use the Site or Services.

This Policy should be read in conjunction with our Terms of Service, which are incorporated herein by reference. Capitalized terms used but not defined in this Policy shall have the meanings ascribed to them in the Terms of Service.

2. Categories of Information We Collect

In the course of providing the Services and operating the Site, we may collect the following categories of information:

2.1 Personal Identifying Information

When you submit an application, request information, or otherwise communicate with us, we may collect personal identifying information including, without limitation: your full legal name; date of birth; Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN); residential address; email address; telephone number(s) (including mobile); driver's license or state-issued identification number; citizenship or immigration status; and any other information that directly identifies you as an individual.

2.2 Business and Financial Information

To evaluate, process, and facilitate your funding application, we may collect business and financial information including, without limitation: business legal name and “doing business as” (DBA) names; Employer Identification Number (EIN); business address(es); type of business entity (e.g., sole proprietorship, LLC, corporation, partnership); state and date of formation or incorporation; industry classification (SIC/NAICS codes); number of employees; monthly and annual gross revenue; net profit or loss; existing debt and financial obligations; accounts receivable and accounts payable; business bank account information (including account numbers, routing numbers, and bank statements); financial statements (including balance sheets, income statements, and cash flow statements); federal and state tax returns; merchant processing statements; credit card processing volumes; lease or mortgage agreements; and any other financial documentation or information reasonably necessary to evaluate your funding application.

2.3 Credit and Background Information

With your authorization, we and/or our Lending Partners may obtain personal and business credit reports from one or more consumer reporting agencies (such as Equifax, Experian, and TransUnion) and business credit reporting agencies (such as Dun & Bradstreet and Experian Business). Such reports may include your credit score, credit history, payment history, outstanding debts, public records (including liens, judgments, and bankruptcies), and other relevant financial information.

2.4 Technical and Usage Information

When you access the Site, we automatically collect certain technical and usage information, including but not limited to: your Internet Protocol (IP) address; device type, model, and operating system; browser type, version, and language settings; referring and exit URLs; pages viewed on the Site and the duration of each page visit; click patterns and navigation paths; date, time, and timestamp of access; unique device identifiers; geolocation data (derived from IP address); and other diagnostic and analytics data. This information is collected through cookies, pixel tags, web beacons, server logs, and similar tracking technologies as described more fully in Section 6 below.

2.5 Communications Information

We may collect and retain records of your communications with us, including emails, telephone call recordings (where permitted by law), chat transcripts, support tickets, and any other correspondence or communications you initiate or participate in with the Company.

3. Purposes and Legal Bases for Processing

We use the information we collect for the following purposes and on the following legal bases:

Performance of Services and Contractual Necessity: To process, evaluate, and facilitate your business funding application; to match you with appropriate Lending Partners; to communicate with you regarding the status of your application; to verify your identity and the accuracy of your Application Information; and to fulfill our obligations under our Terms of Service.

Legitimate Business Interests: To operate, maintain, improve, and optimize the Site and Services; to analyze usage patterns and trends; to develop new products, services, and features; to conduct internal audits, research, and analytics; to detect, prevent, and address fraud, security incidents, and technical issues; to enforce our Terms of Service and protect our rights, property, and safety and those of our users and the public.

Legal Compliance: To comply with applicable federal, state, and local laws, rules, regulations, and orders; to respond to lawful requests, subpoenas, court orders, or other legal process; to cooperate with regulatory authorities, law enforcement agencies, and governmental bodies; and to exercise or defend legal claims.

Consent: Where required by applicable law, we may process your information based on your prior express consent, including for purposes such as sending you marketing communications, conducting certain types of credit inquiries, or sharing your information with specific third parties. You may withdraw your consent at any time as described in Section 8 below, provided that such withdrawal shall not affect the lawfulness of processing based on consent before its withdrawal.

4. Disclosure of Information to Third Parties

We may disclose the information we collect to the following categories of third parties, for the purposes described herein:

4.1 Lending Partners

We share your Application Information, including personal, business, and financial information, with one or more Lending Partners in our network for the purpose of evaluating, underwriting, and processing your funding application. Each Lending Partner is an independent entity with its own privacy practices and policies. We strongly encourage you to review the privacy policy of any Lending Partner before entering into a funding agreement. Summit Fundings is not responsible for the privacy practices or the content of any Lending Partner's privacy policy.

4.2 Service Providers and Contractors

We engage third-party service providers and contractors to perform functions on our behalf, including but not limited to: website hosting and infrastructure; data storage and cloud computing; customer relationship management (CRM); email and communication delivery; identity verification and fraud prevention; credit reporting and background screening; analytics and data analysis; payment processing; legal, accounting, and auditing services; and information technology and security services. These service providers are granted access to your information only to the extent necessary to perform their designated functions and are contractually obligated to maintain the confidentiality, security, and integrity of the information they receive.

4.3 Legal and Regulatory Disclosures

We may disclose your information if we believe in good faith that such disclosure is reasonably necessary to: (a) comply with any applicable law, regulation, rule, order, subpoena, court order, or legal process served on the Company; (b) protect and defend the rights, property, or safety of Summit Fundings, our users, or the public; (c) detect, prevent, or address fraud, security, or technical issues; (d) enforce our Terms of Service or other agreements; or (e) respond to claims that any content violates the rights of third parties.

4.4 Business Transfers

In the event of a merger, acquisition, reorganization, restructuring, dissolution, sale of assets, or other business transaction involving all or a portion of the Company's assets, your information may be among the assets transferred or disclosed in connection with the due diligence or completion of such transaction. In such event, we will use reasonable efforts to notify you before your information becomes subject to a different privacy policy.

4.5 With Your Consent

We may disclose your information to additional third parties with your prior express consent or at your direction.

We do not sell, rent, lease, or otherwise commercially distribute your personal information to third parties for their own direct marketing purposes without your explicit prior consent.

5. Data Security Measures

We implement and maintain commercially reasonable administrative, technical, and physical security measures designed to protect the confidentiality, integrity, and availability of your information against unauthorized access, alteration, disclosure, destruction, or loss. Such measures include, without limitation:

• Encryption of data in transit using industry-standard Transport Layer Security (TLS/SSL) protocols
• Encryption of sensitive data at rest using AES-256 or equivalent encryption standards
• Access controls and role-based permissions limiting access to information on a need-to-know basis
• Multi-factor authentication (MFA) for internal systems and administrative access
• Regular security assessments, vulnerability scans, and penetration testing
• Employee training on data privacy, security awareness, and incident response procedures
• Secure server infrastructure hosted in SOC 2 Type II certified data centers
• Incident response and breach notification procedures

Notwithstanding the foregoing, no method of transmission over the Internet or method of electronic storage is completely secure, and the Company cannot guarantee absolute security.

6. Cookies, Tracking Technologies, and Online Analytics

The Site uses cookies, pixel tags, local storage objects, and similar tracking technologies to collect information about your browsing activities, personalize your experience, analyze Site traffic and usage patterns, and serve targeted advertisements.

9. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you are entitled to additional rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA”), including:

• Right to Know
• Right to Delete
• Right to Correct
• Right to Opt Out of Sale or Sharing
• Right to Limit Use of Sensitive Personal Information
• Right to Non-Discrimination

10. Other State Privacy Rights

Residents of certain other states, including but not limited to Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and other states with enacted comprehensive privacy legislation, may have additional or similar privacy rights under their respective state laws.

11. Third-Party Websites and Services

The Site may contain hyperlinks, integrations, or references to third-party websites, platforms, applications, or services that are not owned, operated, or controlled by Summit Fundings. This Policy does not apply to, and we are not responsible for, the privacy practices of any third-party website or service.

12. Children's Privacy

The Site and Services are not directed to, intended for, or designed to attract individuals under the age of eighteen (18). We do not knowingly collect personal information from any person under the age of eighteen (18).

13. Contact Information

Summit Fundings, LLC
Attn: Privacy Officer / Data Protection Department
Email: privacy@summitfundings.com

14. Changes to This Privacy Policy

The Company reserves the right to update, amend, revise, or otherwise modify this Privacy Policy at any time. Any changes will be effective immediately upon posting the revised Policy on the Site with a revised “Last Revised” date.