If you view our website, enter into an easement or other contract with us, complete any online or hardcopy forms, or utilize any of the third-party systems or services that we use, you should be aware that we will collect certain personally identifiable data from you (“Personal Data”).  Summit Carbon Solutions respects your privacy and is committed to protecting your Personal Data and keeping it secure. This statement explains how and why we collect Personal Data from or about you, how we use it, when and why we share it with others, how we secure it, and what rights and choices you have in relation to your Personal Data.

Website

Information Collected From You

When you use our website, we may collect the following Personal Data from you: (i) personal information, such as your name, mailing address, email address, and phone number; and (ii) web analytical information collected automatically when you interact with our website, such as your IP address, browser type, internet service provider, and clickstream data. The Personal Data collected by us, or on our behalf, is collected: (i) to provide requested services; (ii) to respond to your inquiries; (iii) for our internal marketing purposes, which include, but are not limited to, sending you material that we think may be of interest to you; (iv) to analyze how sites and services are being accessed and used; (v) for investigation of information security and information asset protection-related incidents; (vi) to test, correct, and improve our content, applications, and services; (vii) to develop new applications, products, and services; (viii) to improve site and service performance and delivery; and (ix) for other purposes as described under “Other Uses of Personal Data” below. We process your Personal Data for the purposes described above to process transactions requested by you and meet our contractual obligations; on the basis of our legitimate interests (for example, website analytics); or on the basis of your consent. Where we have determined that the legal basis for processing your Personal Data is that it is necessary to serve our legitimate interests, we have concluded that our interests do not inappropriately impact your fundamental rights and freedoms with respect to your Personal Data.  

Cookies

Unless you take steps to browse the internet anonymously, or opt out, Summit Carbon Solutions, similar to most institutions and organizations on the internet, tracks web-browsing patterns to inform our understanding of how our website is being used. Generic information is collected through the use of “cookies,” which are text files placed on your computer, to evaluate usage patterns so that we can improve both content and distribution. You may refuse the use of cookies by selecting the appropriate settings on your browser; however, doing so may prevent you from using the full functionality of our website. If you would like to learn more about cookies, please refer to the following website: http://www.allaboutcookies.org/

In addition to our cookies, cookies may be set by an organization other than us. These “third-party cookies” may, for example, originate from websites such as YouTube, Twitter, or Facebook, or other social media services for which we have implemented “plug-ins” in our website.  Since the cookie policies of these sites change over time, you should determine their policies by visiting the privacy policy pages of these sites directly.

Children’s Privacy

Our website is not directed to children under 13 and we do not knowingly collect Personal Data from children under the age of 13. If we learn that we have collected Personal Data of a child under 13, we will take steps to delete that Personal Data as soon as possible. 

External Links

Our website may contain links to external websites not owned by, or officially affiliated with, us in any way. We are not responsible for the privacy practices or the content of such websites.

Site Access

We may terminate your account or access rights to our website at any time, without notice, for conduct that we believe violates this agreement or other policies or guidelines. We may terminate your account or your access rights to the websites for online conduct that we believe is harmful to other users, to us, or to other information providers.

Landowners/Tenants

When you enter into discussions with us regarding access to land you own or lease, we collect a significant amount of Personal Data from you. We may collect: (i) contact information, such as your name, address, email address, and phone number; (ii) payment information, such as the name of your bank and your bank account number. The Personal Data collected by us, or on our behalf, during the admissions process is collected for the primary purposes of negotiation right of way agreements and making payments to you. We process your Personal Data for the purposes described above on the basis of our legitimate interests (for example, to process the right of way agreements); to process transactions requested by you and meet our contractual obligations (for example, to process our payments to you); as necessary for compliance with our legal obligations (for example, regulatory reporting); or on the basis of your consent. Where we have determined that the legal basis for processing your Personal Data is that it is necessary to serve our legitimate interests, we have concluded that our interests do not inappropriately impact your fundamental rights and freedoms with respect to your Personal Data.

Employees

We collect your Personal Data when you apply to work for us, upon hiring, and throughout your employment with us. The following Personal Data collected by us, or on our behalf, is collected for the primary purpose of facilitating your employment with us: (i) contact information, such as your name, address, email address, and phone number; (ii) payment information, such as the name of your bank and bank account number for processing your compensation; (iii) tax information, such as your government identification number, wages, and tax filing status; (iv) personal information and history, such as your marital status and other information about your background, and, when relevant for your position or as required by law, credit history, driving record, self-reported and publicly-available criminal records, citizenship and work authorization status; (v) employment history, such as prior employers, titles, wages, and work experience; (vi) educational history, such as prior schools, transcripts, awards, and honors; (vii) information for family members included in any benefit plans; (viii) demographic information, such as your gender or gender identity, age, and date of birth; (ix) job performance information, such as performance reviews, training records, and disciplinary records; and (x) health information, such as medical conditions that may impact your ability to work.  We process this Personal Data: (i) to evaluate your application for employment; (ii) to administer human resources-related processes, including payroll processing and the provision of employee benefits; (iii) to satisfy legal, regulatory, and contractual obligations; and (iv) for other purposes as described under “Other Uses of Personal Data” below. We process your Personal Data for the purposes described above on the basis of our legitimate interests (for example, making hiring decisions, conducting performance reviews, making decisions about your compensation, and ensuring your well-being and safety); to process transactions requested by you and meet our contractual obligations (for example, paying you and providing you with employment benefits); as necessary for compliance with our legal obligations (for example, to provide required information to tax authorities); or on the basis of your consent. Where we have determined that the legal basis for processing your Personal Data is that it is necessary to serve our legitimate interests, we have concluded that our interests do not inappropriately impact your fundamental rights and freedoms with respect to your Personal Data.

Other Uses of Personal Data

In addition to the uses described above, we may use your Personal Data to: (i) contact you to respond to your requests or inquiries; (ii) provide you with newsletters, articles, service alerts, announcements, event invitations, or other information that we believe may be of interest to you; (iii) prevent, investigate, or provide notice of fraud, unlawful or criminal activity, or other misconduct, security, or technical issues, including unauthorized access to or use of your Personal Data, our website, or our data systems; (iv) respond to subpoenas, court orders, or other legal process; (v) enforce our contractual agreements; (vi) protect the health, safety, rights, or property of you, us, or others; and (vii) meet any other legal obligations that we may have.

How We Share Your Personal Data

Where there is a legitimate reason for doing so, we may share your Personal Data with certain third parties that we work with, including: (i) third parties who work with us to provide services to you; (ii) third parties who provide services to us, including information technology and a web analytics services; (iii) auditors, attorneys, and other professional service providers; (iv) government entities to whom we have a statutory obligation to provide information; and (v) law enforcement agencies. We also may release your Personal Data when we believe such release is appropriate to comply with the law, enforce our website policies, or protect our or others’ rights, property, or safety. We do not sell, trade, or otherwise transfer your Personal Data to third parties, except as explained herein; provided, however, that non-personally identifiable website visitor information may be provided to other third parties for marketing, advertising, or other uses without restriction.

Retention of Your Personal Data

We will retain your Personal Data for as long as is necessary for the purposes set out herein unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights, or otherwise to comply with our legal obligations.  Where we are processing your Personal Data based on your consent, we will retain your Personal Data for the period of time necessary to carry out the processing activities to which you consented, subject to your right, under certain circumstances, to have certain of your Personal Data erased. Where we are processing your Personal Data based on a contract, we will retain your Personal Data for the duration of the contract plus any additional period of time that is necessary to comply with the law or that represents the statute of limitations for legal claims that could arise under the contract. Where we are processing your Personal Data based on a public interest, we will retain your Personal Data for the period of time that serves that underlying public interest. Where we are processing your Personal Data based on our legitimate interests, we will retain your Personal Data for a reasonable period of time based on the particular interest in question, taking into account your fundamental rights and freedoms with respect to your Personal Data. Where we are processing your Personal Information pursuant to a right of way easement on the property you own or lease, we will retain your Personal Data for so long as we have an easement on the property you own or lease. 

Transfer of Your Personal Data

Your Personal Data will be stored on the servers of cloud-based services Summit Carbon Solutions engages. If you are outside of the United States, you should understand that we may transfer your Personal Data to the United States.  Because the United States has not sought or received an adequacy decision under the European Union’s General Data Protection Regulation (GDPR), we rely on appropriate safeguards and on derogations for specific situations that are recognized under GDPR when transferring your Personal Data to the United States.

Your Rights with Respect to Your Personal Data

To the extent required by and in accordance with applicable law, upon your request, we will provide you with information about the Personal Data of yours that we possess.  In addition to obtaining that information from us, you may have a right to: (i) correct any of your Personal Data that is inaccurate; (ii) restrict or limit the ways in which we use or process your Personal Data; (iii) request that we delete your Personal Data; and (iv) obtain a copy of your Personal Data in an easily accessible format. You have the right to withdraw your consent to our processing of your Personal Data where our processing is solely based on your consent, subject to certain limitations at law; provided, however, that in certain cases, we may continue to process your Personal Data after you have withdrawn your consent and requested that we delete your Personal Data, if we have a legal basis to do so.  For example, we may retain Personal Data that is needed to comply with our legal obligations, if we still need the Personal Data for the lawful purposes for which we obtained it, or if it is necessary to retain the Personal Data to pursue our legitimate interest in keeping our services and operations safe and secure.

Questions/Concerns/Complaints

If you have questions, concerns, or complaints about how we are using your Personal Data or wish to make any requests regarding your Personal Data, we ask that you contact our Privacy and Legal teams using the information listed below. If you reside in the European Economic Area, you also may have the right to lodge a complaint with your national data protection authority (i.e., supervisory authority), which varies depending on your location, but which can be found online here

Contact Information:

Privacy and Legal team at Summit Carbon Solutions

2321 North Loop Drive, Suite 221

Ames, IA, 50010

privacy@summitcarbon.com

Summit Carbon Solutions may update or change this policy notice at any time.

Effective Date:  11/17/2021

Last revision date:  11/17/2021