Data Protection Policy

March 2021

Summar Financial Data Protection Policy refers to our commitment to treat the information of employees, customers, stakeholders, and other interested parties with the utmost care and confidentiality. With this policy, we ensure that we gather, store, and handle data reasonably, transparently, and with respect towards individual rights.

We may change this Data Protection Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. In some cases, we may provide you with additional notice (such as adding a statement to our website or providing you with a notification). We encourage you to review this Data Protection regularly to stay informed about our information practices.

Scope

This policy refers to all parties who provide any amount of information to us. Employees of our company must follow this policy. Contractors, consultants, partners, and any other external entity are also covered. Generally, our policy refers to anyone we collaborate with or acts on our behalf and may need occasional data access.

As part of our operations, we need to obtain and process information. This information includes any offline or online data that makes a person identifiable such as names, addresses, usernames and passwords, digital footprints, photographs, social security numbers, financial data, etc.

Summar Financial transparently collects this information and only with the full cooperation and knowledge of interested parties. Once this information is available to us, the following rules apply.

Our data will be:

• Accurate and kept up-to-date
• Collected fairly and for lawful purposes only
• Processed by the company within its legal and moral boundaries
• Protected against any unauthorized or illegal access by internal or external parties

In addition to how it handles the data, the company has direct obligations towards the people to whom the data belongs. Specifically, we must:

• Let people know which of their data is collected
• Inform people about how we’ll process their data
• Inform people about who has access to their information
• Have provisions in cases of lost, corrupted, or compromised data
• Allow people to request that we modify, erase, reduce, or correct data contained in our databases

Actions

To exercise data protection, we’re committed to:

• Restrict and monitor access to sensitive data
• Develop transparent data collection procedures
• Train employees in online privacy and security measures
• Build secure networks to protect online data from cyberattacks
• Establish clear procedures for reporting privacy breaches or data misuse
• Include contract clauses or communicate statements on how we handle data
• Establish data protection practices
• Our data protection provisions will appear on our website.

Disciplinary Consequences

All principles described in this policy must be strictly followed. A breach of data protection guidelines will invoke disciplinary and possibly legal action.