Summit Carbon Solutions, LLC (“Summit” or “we”) respects your privacy and is committed to protecting your information and keeping it secure. This privacy policy explains our policies and procedures around collecting, using, processing and deleting your protected data and information.  

If you visit one of our websites, www.summitcarbonsolutions.com or www.summitcarbon.com (each, a “Website”), complete any online or hardcopy forms, enter into a services relationship with us, enter into an easement other contract with us, apply for employment or enter into an employment relationship with us, or utilize any of the third-party systems or services that we use, you should be aware that we will collect certain information from you. This information may include personal data and personal information that may be subject to protection under applicable data protection, data privacy and data security laws, such as the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020, the “CCPA”), the General Data Protection Regulation (EU) 2016/679 (the “GDPR”), and other state laws, as applicable (collectively, “Personal Data”).

Your use of a Website or the provision of Personal Data to us otherwise means you understand and agree to this privacy policy.

We may update this privacy policy from time to time. Your use of a Website or the provision of Personal Data to us otherwise after the effective date noted above indicates your understanding of and agreement to this privacy policy.

 

Information We Collect

We may collect Personal Data from you through a Website or otherwise, as indicated below. In particular, we have collected the following categories of Personal Data within the last twelve (12) months pursuant to this privacy policy:

• Identifiers, such as name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address (from which we may identify your geographic location), email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers;
• Personal information, such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, or any other financial information;
• Protected classification characteristics, such as age (40 years or older), race, color, ancestry, national origin, citizenship, marital status, sex (including gender, gender identity, gender expression), or veteran or military status;
• Commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• Internet or other similar network activity, such as browsing history, browser type, Internet service provider, information on interactions with our Websites, or other applications, or advertisements;
• Geolocation data, such as the general location of access to our services;
• Professional or employment-related information, such as current or past job history or performance evaluations;
• Non-public educational information, such as education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records;
• Inferences drawn from other Personal Data, such as a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; and
• Sensitive personal information, such as government identifiers (social security, driver’s license, state identification card, or passport number); precise geolocation; racial or ethnic origin, or union membership; or mail, email, or text messages contents (the information in this bullet is referred to as, “Sensitive Personal Information”).

If you are an employee or an applicant for employment, please also see “Special Provisions Applicable To Employees And Employment Applicants” below.

If you are a landowner or tenant who does business with us, please also see “Special Provisions Applicable To Landowners and Tenants” below.

How We Collect Your Personal Data

We obtain your Personal Data listed above from the following categories of sources:

• Directly from you. For example, from forms you complete, products or services you purchase from us or we purchase from you, contracts or easements we enter into, or other communications from you. This may include information you provide us in connection with your application for employment with us.
• Indirectly or passively from you. For example, from observing your actions on our Websites. This includes clickstream data we capture using cookies (see Section below entitled “Cookies”).
• Buy or obtain from other sources or third-party data aggregation services.

If you are an employee or an applicant for employment, please also see “Special Provisions Applicable To Employees And Employment Applicants” below.

If you are a landowner or tenant who does business with us, please also see “Special Provisions Applicable To Landowners and Tenants” below.

How We Use Your Personal Data

We may use your Personal Data for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use your Personal Data to respond to your inquiry. If you provide your Personal Data to purchase a product or service, or for us to purchase a product or service from you, we will use that Personal Data for payment processing and product or service delivery. We may also save your Personal Data to facilitate future transactions with you or in connection with the terms of any agreements between us.
• To provide, support, personalize, improve, and develop our Websites, products, and services, and to notify you about changes to our Websites, products, and services.
• To create, maintain, customize, and secure your account with us.
• To communicate with you, including responding to requests for information submitted by you through a Website or to notify you of services we provide, events that we are hosting, employment opportunities, or products or services that may be of interest to you.
• To evaluate and respond to your application for employment with us.
• To keep a record of your relationship with us.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• For internal marketing purposes, including to personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Websites, third-party sites, postal mail, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Websites, products and services, databases and other technology assets, and business.
• For testing, auditing, research, analysis, and product development, including to develop and improve our Websites, products, and services.
• To research and analyze users’ demographic characteristics, interests and behavior in an aggregated form in order to better understand and serve our users and improve our Websites, products, and services.
• For ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Data or as otherwise permitted under applicable law.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our customers is among the assets transferred.

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.  Please note that we may process your Personal Data for more than one legal basis depending on the specific purpose for which we are using your Personal Data. 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.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

If you are an employee or an applicant for employment, please also see “Special Provisions Applicable To Employees And Employment Applicants” below.

If you are a landowner or tenant who does business with us, please also see “Special Provisions Applicable To Landowners and Tenants” below.

You may opt-in to certain kinds of marketing communications by contacting us and you may unsubscribe to receiving further communications by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails or by using the Contact details in this privacy policy.

Sharing Your Personal Data

We may share your Personal Data by disclosing it to a third party for a business purpose, including third party suppliers and service providers (including vendors providing hosting, database management and development services related to the operation of our Websites, outsourcing providers of our back-office and internal functions, technology service providers, and/or email marketing services related to communications we may send to you). We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Data confidential, and prohibit using the disclosed Personal Data for any purpose except performing the contract.

In addition to the foregoing, where there is a legitimate reason for doing so, we may share your Personal Data with certain third parties, including (i) auditors, attorneys, and other professional service providers, (ii) government entities to whom we have an obligation to provide information, (iii) law enforcement agencies, and (iv) entities to whom we may transfer, or merge parts of our business or our assets in a restructuring or in connection with a corporate transaction. 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, health, or safety.

Note that Personal Data does not include non-personally identifiable information, which may be provided to third parties for marketing, advertising, or other uses without restriction.

We do not sell Personal Data to third parties.

Within the last twelve (12) months, we have shared with affiliates and service providers each of the categories of Personal Data described above in the Section entitled “Information We Collect.” Please contact us using the details in the Contact section of this privacy policy for more details on the third parties with whom we share your Personal Data.

If you are an employee or an applicant for employment, please also see “Special Provisions Applicable To Employees And Employment Applicants” below.

If you are a landowner or tenant who does business with us, please also see “Special Provisions Applicable To Landowners and Tenants” below.

Retaining Your Personal Data

We will retain your Personal Data for as long as is necessary for the purposes set out in this privacy policy, or such longer period of time as is required under applicable law, as is required to comply with our legal obligations, or as is needed to resolve disputes or protect our legal rights. 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 Data 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.

Cookies

Unless you take steps to browse the Internet anonymously, or opt out, we, similar to most institutions and organizations on the Internet, track web-browsing patterns to inform our understanding of how our Websites are being used. “Cookies” are text files placed on your computer, to evaluate usage patterns so that we can improve both content and distribution. Cookies automatically collect information regarding how you access our Websites (e.g., browser type, access times, IP address) and information regarding the hardware and software that you use to access our Websites.

You can confirm your Website cookie preferences through the interface in the cookies banner provided on the homepage of our Websites. You can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence, or refuse all cookies by turning them off in your browser. Refusing the use of cookies may prevent you from using the full functionality of our Websites. 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 Websites.  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.

Special Provisions Applicable To Employees And Employment Applicants

In addition to the provisions set forth elsewhere in this privacy policy, the following provisions apply to our employees and applicants for employment with us.

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.

Special Provisions Applicable To Landowners And Tenants

In addition to the provisions set forth elsewhere in this privacy policy, the following provisions apply to landowners and tenants who do business with us.

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.

Special Provisions Applicable To Certain Individuals Outside Of The United States

In addition to the provisions set forth elsewhere in this privacy policy, the following provisions apply to certain individuals located outside of the United States.

Your Personal Data will be stored on the servers of cloud-based services we engage. 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 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.

External Links

We may provide links to third party websites for your information or convenience. Such websites are independently operated and are not under our control, and the privacy practices of such third party websites are not governed by this privacy policy. We are not responsible for the content or privacy practices of such third party websites or any products or services offered through them or the confidentiality, use, processing and security of any Personal Data that you provide to such websites.

Children’s Access

Our Websites are 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. 

Site Access

We may terminate your account or access rights to our Websites at any time, without notice, for conduct that we believe violates this privacy policy or other policies or guidelines. For example, we may terminate your account or your access rights to our Websites for online conduct that we believe is harmful to other users, to us, or to other third parties.

Your Rights and Choices

This section describes rights available to certain individuals under applicable law and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your Personal Data over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights), we will disclose to you:

• The categories of Personal Data we collected about you.
• The categories of sources for the Personal Data we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Data.
• The categories of third parties with whom we share that Personal Data.
• If we sold or disclosed your Personal Data for a business purpose, two separate lists disclosing:
  • sales, identifying the Personal Data categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained.
• The specific pieces of Personal Data we collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with other applicable law.
6. 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify Personal Data not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights

To exercise your rights described above, or if you have questions, concerns, or complaints about how we are using your Personal Data, we ask that you contact us using one of the methods 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 us by regular mail at:

Summit Carbon Solutions, LLC

Attn: Privacy and Legal Team

2321 North Loop Drive, Suite 221

Ames, IA, 50010

 

Contact us by e-mail at:

privacy@summitcarbon.com

 

Contact us by phone at:

1-800-863-6684

 

Or click here:

https://summitcarbonsolutions.com/privacy-policy/

 

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Data.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative, which may include:
  • email address and phone number.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you.

We will only use Personal Data provided in the request to verify the requestor’s identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within that timeframe, please contact 1-800-863-6684.

We endeavor to substantively respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance, specifically Excel or CSV.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your legal rights. Unless permitted by applicable law, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Contact Information

As indicated above, if you have questions, concerns, or complaints about how we are using your Personal Data or want to exercise your rights under this privacy policy, we ask that you contact us using one of the methods listed below.

Contact us by regular mail at:

Summit Carbon Solutions, LLC

Attn: Privacy and Legal Team

2321 North Loop Drive, Suite 221

Ames, IA, 50010

 

Contact us by e-mail at:

privacy@summitcarbon.com

 

Contact us by phone at:

1-800-863-6684

 

Or click here:

https://summitcarbonsolutions.com/privacy-policy/

If you need to access this privacy policy in an alternative format due to having a disability, please contact privacy@summitcarbon.com or 1-800-863-6684.