Privacy Policy

Your privacy is important to us. SummitView Texas LLC (“SummitView”) understands your concerns regarding how information about you may be used and shared, and we appreciate that you trust us to use and share information about you carefully and sensibly.

This Privacy Policy describes what Personal Information (defined below) SummitView and its parent companies, subsidiaries, affiliates, and sponsored investment programs (collectively, “us”, “our”, and “we”), may collect about you, how we may collect it, how we may use it, with whom we may share it, and what choices you may have regarding it.

This Privacy Policy applies to your use of our websites, mobile websites, mobile apps, any other platforms that link to this Privacy Policy (each, a “Site” and collectively, the “Sites”), and any other means by which we may collect information about you, including information you may provide to us on-site at our retail facilities (collectively, the “Facilities”), as well as in connection with applying to become an investor or franchisee of any SummitView supported brands.

This Privacy Policy does not apply to any websites or facilities operated by third parties. We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of other companies or other websites. We encourage you to seek out and read the privacy policy of each website that you visit.

HOW WE MAY RECEIVE YOUR PERSONAL INFORMATION

We may receive your Personal Information from various sources, including:

• We may collect information from you when you provide personal details to register on a Site, access a Site in connection with your use of our services, request information, send us email or postal mail, apply for a job with us, speak with us on the telephone, or otherwise interact with us.
• We may receive information about you from our Facilities, including information that you provide on-site at our Facilities.
• We may receive information about you from our third-party service providers who help us to provide services to you, including our Sites and social media providers. If you apply to become an investor or franchisee of a SummitView supported brand, we may also collect Personal Information from third party sources regarding your application.
• We may receive information about you automatically as you navigate the Sites. Information collected automatically may include usage details, email address, IP addresses, and information collected through cookies and other tracking technologies.
• As used in this Privacy Policy, the term “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you.

PERSONAL INFORMATION WE MAY COLLECT

When you register on a Site, you will be asked to provide us certain details such as your first and last name; e-mail address; physical address; phone number; and other information you provide through the registration form.

When you use our Sites, we and our third-party service providers may automatically collect information about how you access and use the Sites and information about the device you use to access the Sites. We typically collect this information through a variety of tools including cookies, web beacons, pixels, social media widgets, other tools to enable data recording and indexing, and similar technology. We and our third-party partners may automatically collect Personal Information, such as IP or MAC address; device type; unique device identifier (UDID)/other device identifier (IMEI); browser type; operating system or platform; name of Internet Service Provider (ISP); geolocation data; referring website; exiting website; clickstream data; search terms entered on the Sites; pages visited on the Sites; time, date, and duration of visit to the Sites; whether you open emails from us; links you click on in our emails and on our Sites, including ads; whether you access our Sites from multiple devices; and other interactions you may have on our Sites.

If you apply to become an investor or franchisee of a SummitView supported brand, we may also receive Personal Information about you from third parties including individuals you provide as references, financial and other institutions, schools, credit reporting agencies, professional and academic certification organizations, law enforcement agencies, former employers, and the military for purposes of evaluating your application. Such Personal Information may include information about your financial, educational, and criminal histories, as well as information concerning your character and reputation.

HOW WE MAY USE PERSONAL INFORMATION

We may use information we collect from you and information that we may collect automatically to manage and improve our Sites and our business. We may also use your Personal Information for the following purposes:

• To provide services to you.
• To provide our Sites and their functionalities to you.
• To provide you with location-specific services. If you elect to share your location information with us, we may use that information to tailor options, functionalities, or offers related to your location.
• To market our own services to you.
• To conduct data analytics to support our Sites and business.
• To manage our business needs, such as monitoring, analyzing, and improving the services and the Sites’ performance and functionality.
• To manage risk and protect the Sites and Facilities.
• Tailor our offerings to your apparent interests.
• To operate and improve our business.
• To maintain our records.
• Conduct internal monitoring and training.
• Develop new services and products.
• Conduct processing necessary to fulfill other contractual obligations for you.
• To comply with our legal and regulatory obligations. We may use your information as necessary to enforce the terms of our Sites and services to comply with all applicable laws and regulations.
• For other purposes for which you provide your consent. For other purposes which are disclosed to you at the time your information is collected or for purposes which can be inferred from or are obvious given the circumstances of collection.

We may process Personal Information to provide services to you and additional services you request, as well as to respond to communications from you.

We may collect, use, share, transfer, and otherwise process de-identified and aggregated information that we receive or create for any purpose in our sole discretion, in compliance with applicable laws. We are the sole and exclusive owner of such de-identified and aggregated information, including information we de-identifies such that it is no longer considered “Personal Information” under applicable laws.

If you apply to become an investor or franchisee of a SummitView supported brand, we may also use your Personal Information to evaluate and communicate with you regarding the prospects of becoming an investor or franchisee, including conducting interviews and performing background and reference checks.

DISCLOSURE OF PERSONAL INFORMATION

We do not rent, sell, or share Personal Information with unrelated third parties except as described in or reasonably inferable from this Privacy Policy. We may use or disclose your Personal Information in the circumstances described below:

• We may disclose your Personal Information with our employees and personnel (such as contractors) who have a need to know the information for our business purposes.
• We may disclose your Personal Information with our parent companies, subsidiaries, affiliates, sponsored investment programs, and supported brands to serve you, including for the activities listed above.
• We may disclose your Personal Information to our vendors and other service providers that help us provide services, support features on our Sites or in the Facilities, or otherwise market our brands.
• We may disclose or make available limited Personal Information (such as mobile device identifiers) with ad tech companies and other online service providers. When we share your Personal Information in this context, we follow applicable legal requirements, which may require that we provide opt-out rights or other individual rights.
• We may disclose your Personal Information: (i) if we are required to do so by law, legal process, statute, rule, regulation, or professional standard, or to respond to a subpoena, search warrant, or other government official requests; (ii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss; (iii) in connection with an investigation of a complaint, security threat, or suspected or actual illegal activity; (iv) in connection with an internal audit; or (v) in the event that we are subject to mergers, acquisitions, joint ventures, sales of assets, reorganizations, divestitures, dissolutions, bankruptcies, liquidations, or other types of business transactions. In these types of transactions, Personal Information may be shared, sold, or transferred, and it may be used subsequently by a third party.
• We may disclose your Personal Information to third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

RETENTION

We will retain your Personal Information for as long as necessary to fulfill the purposes described in this Privacy Policy and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies, unless otherwise required by applicable laws. Criteria we will use to determine how long we will retain your Personal Information include whether we need your Personal Information to provide you with our Sites, Facilities, or other services; you have requested information from us; we have a legal right or obligation to continue to retain your Personal Information; we have an obligation to a third party that involves your Personal Information; our retention or recordkeeping policies and obligations dictate that we retain your Personal Information; or we have another business purpose for retaining your Personal Information. We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

COOKIES AND TRACKING OTHER TECHNOLOGIES

We and our service providers may use cookies and similar technologies to collect usage and browser information about how you use our Sites. The technologies we use for this automatic data collection may include cookies and web beacons that permit us to verify system and server integrity and generate statistics around the popularity of certain content. A “cookie” is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of our Sites, to enhance your experience through personalization, and to help us better understand the features of our Sites that you and other users are most interested in.

We may use third-party providers to enable certain interaction opportunities, content delivery, and other service capabilities. We use also analytics and session replay services that use cookies and other technologies that collect your Personal Information to assist us with analyzing our Site traffic and usage to optimize, maintain, and secure our Sites and inform subsequent business decisions. We do not control these third parties’ collection or use of your information for these purposes, or the opt-out options they may individually offer you via their terms, conditions, and privacy policies. If you have any questions about any targeted content, you should contact the applicable provider directly.

You may change your cookie preferences by customizing your browser settings to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable certain cookies, please note that some parts of our Sites may not function properly. These settings may be lost and require reconfiguration if you delete your cookies.

SOCIAL MEDIA

We are active on various social media platforms, including, but not limited to, LinkedIn, Facebook, Instagram, YouTube, and Twitter/X (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Sites and our Social Media pages any comments or content that you post on our Social Media pages.

Our Sites allow you to connect and share data with Social Media platforms. These features may require us to use cookies, plug-ins, and APIs provided by such Social Media platforms to facilitate those communications and features. Our Sites may use advertising networks and services offered by Social Media platforms to deliver advertising content. Use of these services requires Social Media platforms to implement cookies or pixel tags to deliver ads to you while you access the Sites.

INTERNATIONAL USE

If you are visiting our Sites from outside of the United States, please note that our Sites are hosted in the United States. Where permitted by applicable law, we may transfer the Personal Information we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Privacy Policy.

For individuals in the European Union, European Economic Area, Switzerland, and United Kingdom: We will only transfer Personal Information to third parties located outside of these regions when we have ensured appropriate safeguards for such Personal Information through use of the standard contractual clauses or other lawful and approved methods. Our legal basis for processing Personal Information depends on the Personal Information concerned and the context in which we process it. We may process Personal Information from you where we need it to perform a contract with you, where the processing is in our legitimate interests (including the purposes described in this Privacy Policy), where the processing is necessary for us to meet our applicable legal obligations, or if we otherwise have your consent. We do not intend to collect any Special Category Data, which is any data that reveals your racial or ethnic origin, political opinions, religious, moral, or philosophical beliefs, trade union membership, political views, genetics, biometrics for the purpose of identifying a person, and health or a person’s sex life and/or sexual orientation. Please refrain from sending us any Special Category Data.

THIRD-PARTY COLLECTION OF INFORMATION

This Privacy Policy addresses only the use and disclosure of information we collect from you. This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy.

Occasionally, at our discretion, we may include or offer third-party products or services on our Sites. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. These third-party sites have separate and independent privacy policies. We have no responsibility or liability for the content and activities of these linked sites. We therefore encourage you to read the terms and conditions and privacy policy of each third party to which you choose to disclose information before submitting any information.

SAFEGUARDING OF INFORMATION

We have implemented reasonable physical, technical, and administrative security standards to protect Personal Information from loss, misuse, alteration, or destruction. We strive to protect your Personal Information against unauthorized access, use, or disclosure, using security technologies and procedures, such as encryption and limited access. However, we cannot guarantee the security of Personal Information during its transmission or storage on our systems and cannot be responsible for the acts of those who gain unauthorized access or abuse our Site. We make no warranty, express, implied or otherwise, that we will prevent such access.

HOW TO EXERCISE YOUR PRIVACY RIGHTS

Depending on where you live, you may have the following rights with respect to your Personal Information under applicable data protection laws:

• You may have the right to request access to and obtain a copy of any Personal Information we have collected about you.
• You may have the right to delete your Personal Information that we have obtained, subject to certain exceptions.
• You may have the right to correct inaccuracies in your Personal Information.
• You may have the right to: (a) opt out of the processing of your Personal Information for purposes of targeted or cross-context behavioral advertising, (b) opt out of the sale of your Personal Information, and (c) limit the use of your sensitive Personal Information (if applicable). We do not collect or process sensitive Personal Information outside of purposes permitted by law, so we do not offer the option to limit its use.
• You may have the right to object or restrict us from processing your Personal Information in certain circumstances.
• You may have the right to withdraw your consent where we are relying on your consent to process your Personal Information.
• You may have the right to know when you are subject to automated decision-making, the Personal Information used to render the decision, the principal factors and parameters involved in the decision, and human review or correction of the decision (or its underlying data, where appropriate). You may also have the right, depending on your location, to consent or opt out of (a) this automated decision-making or (b) any profiling in furtherance of decisions that produce legal or similarly significant effects. We do not profile you or other individuals in a manner that would result in legal or similarly significant effects, or engage in automated decision-making, so we do not offer an opt out of such activity.
• You may have the right to lodge a complaint with a supervisory authority or other regulatory agency if you believe we have violated any of the rights afforded to you under applicable data protection laws. We encourage you to first reach out to us, so we have an opportunity to address your concerns directly.

To exercise any of the privacy rights afforded to you under applicable data protection laws, please submit a request to us at investor.relations@summitviewtx.com

You will not be discriminated against in any way for exercising your rights listed in this Privacy Policy, which means we will not deny goods or services to you, provide different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you. Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your Personal Information.

We must verify your identity before fulfilling your requests and, if we cannot verify your identity, we may request additional information from you. If you are an authorized agent making a request on behalf of another person, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney. We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.

MINORS

Our Sites are not designed or intended for children under 18 years of age. No one under age 18 may provide any information to or on the Sites. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information on the Sites or on or through any of its features, including your name, address, telephone number, email address, or any username you may use. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at investor.relations@summitviewtx.com

NOTICE TO CALIFORNIA RESIDENTS

This California Consumer Privacy Statement (“Statement”) supplements the above Privacy Notice and applies only to California residents. This section applies to our collection and use of Personal Information if you are a resident of California, as required by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (collectively, “CCPA”), where “Personal Information” has the definition set forth in the CCPA.

COLLECTION AND USE OF PERSONAL INFORMATION

We may collect Personal Information from the sources described in the “How We May Receive Your Personal Information” section above, which may include the following:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, e-mail address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers.
• Additional Data Subject to Cal. Civ. Code § 1798.80: includes signature, state identification card number education, and financial information.
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, age, sex, gender, gender expression, sexual orientation, medical condition, citizenship status, and military and veteran status.
• Commercial Information: commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
• Online Activity: internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications, or advertisements.
• Sensory Information: information including audio, electronic, visual, thermal and similar information.
• Employment Information: Professional or employment-related information, such as information relating to your job position (e.g., job title, job description and office location), work authorization status, talent management information (e.g., résumé information, current or past employment history, performance evaluations, education history, professional designations and qualifications, and other information about your background).
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use your Personal Information for the business and commercial purposes described in the “How We May Use Personal Information” section above, which may include the following:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services.
• Providing advertising and marketing services to you, except for cross-context behavioral advertising.
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.
• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us.
• Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes.
• Debugging to identify and repair errors that impair existing intended functionality.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

We do not collect or process sensitive Personal Information with the purpose of inferring characteristics about California residents covered by this Statement.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Disclosure of Personal Information

We do not sell your Personal Information in exchange for monetary compensation. We may disclose your Personal Information by allowing certain third parties (such as online advertising services) to collect Personal Information via automated technologies on our websites and apps for cross-context behavioral advertising purposes. Under California law, these kinds of disclosures may be considered a “sale” when the Personal Information is exchanged for non-monetary consideration, or “sharing” when the Personal Information is disclosed for cross-context behavioral advertising purposes. You have the right to opt out of these types of disclosures of your information.

We do not knowingly sell or share the Personal Information of minors under 16 years of age.

California Consumer Privacy Rights

If you are a resident of California, you have certain choices regarding your Personal Information, as described below:

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the Personal Information we have collected, used, disclosed, and sold about you during the past 12 months.
• Correction: You have the right to request that we correct the Personal Information we maintain about you, if that information is inaccurate.
• Deletion: You have the right to request that we delete certain Personal Information we have collected from you.
• Opt-Out of Sale or Sharing: You have the right to opt-out of the sale of your Personal Information or the sharing of your Personal Information for cross-context behavioral advertising purposes.

To submit a request for access, correction, deletion, or opting out, please submit a request to us at investor.relations@summitviewtx.com For questions or concerns about our privacy policies and practices, contact us at investor.relations@summitviewtx.com

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your Personal Information or complying with your request. If you request access to, correction of or deletion of your Personal Information, we may require you to verify your e-mail address or certain of your information in our records, such as your name, e-mail address, mailing address, phone number, company name and job-details, or other information about your interactions with us. In addition, if you ask us to provide you with specific pieces of Personal Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.

If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

Changes To This Privacy Policy

We may periodically change, amend, or revise this Privacy Policy from time to time, and we will post any changes on this page. Each version of this Privacy Policy is identified at the top of the page by its Effective Date. If we make material changes to how we treat our users' Personal Information, we may notify you by email to the primary email address specified in your account and/or through a notice posted on the home pages our Sites. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting our Sites and this Privacy Policy to check for any changes. Your continued use of the Sites following the posting of such amendments, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How To Contact Us

For any questions, or to request further information regarding this Privacy Policy, please contact us at investor.relations@summitviewtx.com