This Privacy policy of Summa Finland Oy ("Summa") applies to the Summa website located at summa.bio; the software applications we make available through our Website, which we refer to as ("Software Apps"); Summa Products ("Products") and our data services available through the internet made available to users of Summa Products or Software that provide and permit the access, collection, storage, processing, analysis and/or transmission of data generated by a Summa Product or Software App ("Data Services"); as well as any email messages that we send to you that link to this Privacy Policy (collectively, including the Website, the Software Apps, the Products, the Data Services, and the e-mail, the "Products and Services"). We refer to each user of our Products and Services as "you" or as a "User".

This Privacy Policy is subject to the Summa Terms of Use. Capitalized terms not otherwise defined in this Privacy Policy shall have the meaning ascribed to such terms in theSumma Terms of Use. By using any Summa Product or Service, you agree with the terms of this Privacy Policy.

1. Information We Receive

The information we receive about you, which we refer to collectively as your "Personal Information", includes Registration Information, Feedback Information, Data Services Information, Use Information and Derived Information.

‍1.1. "Registration Information"

Registration Information is information you are required to provide in order to register with us when you register with Summa in connection with your use of a Summa Product or Service or Software Apps. This information may include your name, address, telephone number, email, goals, personal and medical information, nutrition and activity level and other contact information, as well as information regarding your use of Summa Products and Services.

‍1.2. "Feedback Information"

Feedback information is information you submit to us in connection with your use of Summa Products and Services, whether through our Website, through our Data Services, or otherwise, regarding Summa Products and Services, or other matters relating to us and our business, including the metadata relating to that information.

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1.3. "Data Services Information"

Data Services Information is information we receive and transmit through our Products and Services, including:

• Hormone level readings from saliva samples;
• Heart rate metrics;
• Answers to questionnaires;
• Activity and training load data;
• Energy expenditure data;
• Fitness test results;
• Contextual information;
• Information associated with each hormone level reading, heart rate metrics and other data points, including date, time, and device identifier.

‍1.4. "Use Information"

Use Information is information we receive from the computer or smartphone you use in connection with Summa Products and Services, and information we receive from those Products and Services regarding your use, which may include your IP address and other information regarding your computer, your internet service, the browser you use, and your activities while using Summa Products and Services, such as how often you open Software Apps, your settings and other activity regarding your use of the components of Summa Products and Services;

In order to use Summa Products and Services optimally, you may opt to integrate Software Apps with the Apple HealthKit™ database. Software Apps cannot read or write to the HealthKit database without your explicitly granted permission. 

Data or Documents accessed from the HealthKit database will never be shared with third party service providers without your explicit permission. Your HealthKit sourced data or documents will only be used, with your permission, to display a wider range of health data in the Software App, to combine hormone level readings and questionnaire-derived information with other activity and health data, or for the purpose of health research, and will never be shared with advertisers or used for marketing purposes.

The information you provide directly from the Apple Health App (i.e., not through Summa) is governed by the Apple Terms and Conditions and Privacy Policy. Summa is in no way responsible for the protection of data and information stored within the Apple HealthKit database.‍

1.5. "Derived Information"

Derived Information is information that we create by combining and/or analyzing some or all of your Personal Information.

‍1.6 "Other information"

If any of the Personal Information described above does not reveal your specific identity or relate directly to an individual, we may use such "Other Information" for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.

‍2. Your Rights and Responsibilities

If you would like to review, correct, update, suppress, or delete Personal Information that you have provided to us, you may update such information maintained in your User Account on our Website or contact us at info@summa.bio. 

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database, or otherwise let us know what limitations you would like to put on our use of your Personal Information. 

For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. 

Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. ‍

3. Use of Information

3.1 Registration Information

‍We use Registration Information to manage your account and Summa Products and Services applicable to you, and as otherwise described below. We also use your email address to contact you regarding your account. We do not make any Registration Information public. We will use your User Account and Registration Information to link your use of Summa Services and Software Apps with your use of Summa Products, and it may be accessible by our personnel providing Summa Services.

3.2 Feedback Information

Feedback Information may be used by us and provided by us to our customers and third parties, in the form you provide as well as in excerpted, aggregated and anonymized forms, with or without attribution to you as the source. We may also use Feedback Information in our advertising, marketing and other communications with the public and in our business relationships, as well as in our internal communications, in each case with or without attribution to you as the source.

3.3 Data Services Information

‍We collect Data Services Information and store it on our backend, process it using Data Services, and transmit it to the User and each Designated Recipient, where applicable. We may use Data Services Information in connection with our provision of Data Services and for our operations, administration and product development, maintenance and support. We may remove information that identifies you from Data Services Information, and we may use such de-identified data for our business purposes as we determine, such as research and development, product improvements, business operations and process improvements, marketing purposes, including disclosing such de-identified data to third parties for their use as we determine.

3.4 Use Information

We collect Use Information and store it on our servers, process it using our systems, and analyze it for our business purposes. We do not disclose to third parties any Use Information that can identify you (except as permitted in this Privacy Policy), but we may remove information that identifies you from Use Information, and we may provide such de-identified Use Information to third parties as we determine for their use.

‍3.5 Derived Information

‍We may use Derived Information to determine information, including Solicitations, as defined in the next section, to be sent to you, the public or to targeted groups, and for our business purposes in accordance with the applicable provisions of this Privacy Policy.‍

3.6 Personal Information and Solicitations

‍As permitted by applicable law, we may use Personal Information of you and your Designated Recipients, if applicable, to determine which emails and notices we send to you and your Designated Recipients, if applicable, including emails and notices regarding opportunities relating to our Products and Services (we refer to these emails as "Solicitations"). 

You may opt out of Solicitations by contacting us by email at info@summa.bio or by mail at the address listed in the "Contact Us" section below, and you may opt in again through one of those contacts. We will try to comply with your request as soon as reasonably practicable. 

Please keep in mind that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out. As permitted by applicable law, we may share your email address or other Registration Information with third parties with which we contract for the purpose of providing you with Solicitations we think may be of interest to you. You may opt out of our sharing of your information with third parties for these purposes by contacting us by email at info@summa.bio or by mail at the address listed in the "Contact Us" section below.‍

3.7 Personal Information and Summa

‍We may use Personal Information to manage our Products and Services, including the Website, to improve our business and provide new website and product and service features, and to otherwise manage our business, but without disclosing your Registration Information except as necessary for such purposes.‍

3.8 Other Third Parties

‍In the ordinary course of our business, we will share Personal Information with companies we hire to perform services or functions on our behalf. We will not authorize those third parties to keep, use or disclose your Personal Information except for providing the services we have asked them to provide. We may provide your Personal Information to another company in conjunction with a corporate sale, merger, acquisition or dissolution involving Summa.‍

3.9 Law Enforcement and Legal Proceedings

‍We will use and disclose Personal Information as we are required to do by applicable law, including laws outside your country of residence, and may disclose Personal Information when requested by law enforcement authorities or regulatory agencies, including public and government authorities outside your country of residence, or when we determine that such disclosure is appropriate under the circumstances. 

We may use and disclose Personal Information to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; to protect our operations or those of any of our affiliates; to enforce this Privacy Policy; and to allow us to pursue available remedies or limit the damages that we may sustain.

3.10 Obfuscation

‍We may "obfuscate" your Personal Information by removing information that could identify you, and we may use such de-identified information for any purpose, except where we are required to do otherwise under applicable law.‍

3.11 Other Uses

‍We may use your Personal Information for purposes other than those permitted in this Privacy Policy but only after you consent to such use.

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4. Cookies and Other Technologies

If you are a resident of the European Union, please visit About Cookies for information about our use of cookies and other tracking technologies with respect to your use of our Products and Services.

If you are a resident of the United States or any other jurisdiction outside of the European Union, below is a description of how we use cookies and other similar technologies in connection with our Products and Services.‍

4.1 Cookies

‍Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience while using the Services. 

We also use cookies to gather statistical information about use of the Products and Services in order to continually improve their design and functionality, to understand how they are used, and to assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you use the Products and Services. 

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to click here for more information. If, however, you do not accept these cookies, you may experience some inconvenience in your use of the Products and Services. For example, we may not be able to recognize your computer, and you may need to log in every time you visit.

Our Products and Services do not currently have the ability to recognize or honor browser do-not-track signals.

4.2 Analytics

We may use third-party analytics, such as Google Analytics, in connection with the Products and Services. Such third-party services may use cookies and similar technologies to collect and analyze information about use of the Products and Services and to report on activities and trends. Such services may also collect information regarding the use of other websites, apps and online services.

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4.3 Using pixel tags and other similar technologies

Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some of our Products and Services to, among other things, track the actions of users (including email recipients), measure the success of our marketing campaigns, and compile statistics about use and response rates.

‍4.4 Interest Based Advertising

We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Products and Services and other websites or online services, based on information relating to your access to and use of the Products and Services and other websites and services. 

These companies may place or recognize a unique cookie on your browser (including through use of pixel tags). If you would like more information about this practice and to learn about your choices in connection with it, please visit the Network Advertising Initiative opt out site and the Digital Advertising Alliance Self-Regulatory Program.‍

5. HIPAA

We may receive certain health information of yours that is "protected health information" under the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"). When we receive protected health information, such information will be subject to the requirements under HIPAA and the HITECH Act, and the regulations effective under each of those Acts.

‍6. More on Privacy

6.1 Children's Online Privacy Protection

‍Summa does not permit any person under 18 to subscribe directly to Summa Services or Software Apps or to directly purchase Summa Products. A parent or legal guardian may subscribe for a User who is under 18, but no person under 18 is permitted to use Summa Products or Services without the express agreement of a parent or legal guardian to the terms of the Agreement which require, among other things, that the parent or legal guardian is responsible for designating Designated Recipients, connecting the User Device to Summa Services or Software Apps, interacting in all ways with Summa Services and Software Apps, and ensuring that all communications with us come from the parent or legal guardian and not from the person under 18.

6.2 Adults With Guardians or Other Legal Supervision

Summa does not permit any person to subscribe directly to Summa Services, or Software Apps or to directly purchase Summa Products, if that person lacks the legal competence to enter into a contract and be bound to the terms of the Agreement. A legal guardian, conservator or other person with the legal right to do so may subscribe for a User who lacks the legal competence to enter into a contract and be bound to the terms of the Agreement, but no such User is permitted to use Summa Services or Software Apps without the express agreement of a legal guardian, conservator or other person with the legal right to provide such agreement to the terms of the Agreement, which require, among other things, that such legal guardian or other person is responsible for designating Designated Recipients, connecting the User Device to Summa Services and Software Apps, interacting in all ways with Summa Services and Software Apps, and ensuring that all communications with us come from the such legal guardian or other person and not from the User who lacks legal competence.

6.3 Phishing

We do not and will not, at any time, request Registration Information in a non-secure or unsolicited email or telephone communication. Safeguarding information to help protect you from identity theft is a priority for us. For more information about phishing, visit the Federal Trade Commission website.

‍6.4 Security

Summa uses commercially reasonable standards of technology and operational security to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you feel that your interaction with us is no longer secure, please immediately notify us in accordance with the "Contact Us" section, below.

‍6.5 Links to Third Party Sites

Summa Products and Services may contain links to third-party websites, applications or other items. We assume no responsibility for the information practices of those websites, applications or other items, and the inclusion of a link does not imply our endorsement of the linked site or service. 

In addition, this Privacy Policy does not apply to the privacy, information, or other practices of any third parties, including any third party operating any site or service to which our Products or Services link or any third-party provider of an app, social media platform, operating system, wireless service or device. We encourage you to review each third-party's privacy policy before disclosing any personal information to any third party or using its products or services.

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7. Terminating Your Account

You may terminate your Summa account by following the instructions in the Summa website, or by sending us a message at info@summa.bio‍

8. Changes

We may change this Privacy Policy by posting a new version of this Privacy Policy summa.bio website. When we update this Privacy Policy, we will update the legend at the top of this page to indicate the date that this Policy was last updated. Any changes will become effective when we post the updated Policy on our Website. Your use of our Products and Services following these changes means that you accept the updated Policy. If you do not agree with any change, you may terminate your account as provided above and may choose not to submit any further Personal Information.

‍If you have any questions about this Privacy Policy or wish to "opt-out" of Solicitations, please send us an email at info@summa.bio. Because email communications are not always secure, please do not include credit card information or sensitive information in your emails to us.

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