Privacy Policy

Privacy policy

Your privacy is important to us.

Table of contents

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CTC Ledger Pty Ltd (ABN 53 655 951 812) trading as Summ (Summ, Summ Labs, we, us or our) is committed to protecting your privacy. This policy explains how we collect, use and protect your personal information. It applies to all personal information we handle, whether we collect it through our website, in person, or through other means.

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For individuals located in the European Economic Area (EEA), United Kingdom or Switzerland: Additional rights and protections apply to you under the General Data Protection Regulation (EU) 2016/679 (GDPR) and, for UK residents, the UK General Data Protection Regulation (as incorporated into UK law) and the Data Protection Act 2018 (UK GDPR). Please refer to Appendix 1 at the end of this policy for information specific to your additional rights and how we process your personal information in accordance with GDPR and UK GDPR requirements.

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For individuals located in California, please see Appendix 2 at the end of this policy for information specific to your additional rights.

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This policy is effective as of 15 September 2022. Last updated: 28 May 2026.

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Quick overview

We collect information you provide to us and information we gather when we interact with you
We use this information to provide our services and improve your experience
We protect your information using secure systems and processes
You have rights regarding your personal information, including access and correction rights
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Information we collect

Identity and contact details

Email address
Tax jurisdiction
Name and billing address (only collected when you subscribe to a paid plan)

Service related information

Payment and transaction details for services you've purchased from us or enquiries about our services
Your preferences for our services and your marketing preferences
Feedback and survey responses
Personal information contained in user-uploaded documentation (see User Documentation section below)

Cryptocurrency information

Cryptocurrency wallet addresses
Transaction IDs for cryptocurrency transactions
Cryptocurrency balances on centralised exchanges
List of exchanges you have traded on

Digital information

IP address and general location information derived from your IP address
Security tokens
Search and browsing behaviour
Website usage patterns
Cookie preferences and usage

Recordings

Records of chat interactions you have with our support team
Call recordings
Records of meetings and decisions

Professional information (for job applicants and workers)

Employment history
Professional experience
Required authorisations and licences
Professional registrations
Information about your right to work in the relevant jurisdiction

Connected App Integration Data

Your cryptocurrency transaction history
Your portfolio holdings
Your tax reports and capital gains or loss summaries
The wallets and exchanges you have connected to your account
Your tax settings and jurisdiction

Connection and session details generated when you authorise a third party application or AI tool to connect to your account

How we collect personal information

Directly from you when you: when you interact with us, contact us, fill out forms.
Automatically when you: visit our website, use our technologies, interact with our online services.
From third parties: service providers, business partners, public sources, government organisations and organisations or people authorised by you.

Why we collect, hold, use and disclose personal information

We collect and use your personal information to run our business and provide our services as set out below.

Business operations

To manage our relationship with you as a customer or supplier
To process and deliver our services
To handle your inquiries, support requests, and communications
To maintain accurate records for billing and administration
To verify your identity when required or permitted by law
To facilitate connections between yours account and any third-party apps or tools you choose to connect, including passing your personal information to those apps on your instructions and managing the access tokens that keep those connections running

Communication and support

To respond to your questions and support requests
To communicate important updates about our services
To handle inquiries made through our website or platforms
To manage your participation in surveys, feedback sessions, or events

Service improvement

To conduct analytics and market research
To improve our business operations and services
To develop and enhance our applications and platforms
To understand how our services are used

Marketing and promotions

To send you promotional information about our services and events
To inform you about products or services that may interest you
To manage your marketing preferences
To run competitions, promotions, and special offers
To provide additional benefits to our customers

Employment purposes

To assess employment applications
To evaluate candidate qualifications
To manage professional certifications and licences
To maintain employment records

Legal and compliance

To comply with our legal obligations
To respond to court orders or legal processes
To maintain required business records
To fulfill regulatory requirements or reporting obligations
To protect our legal rights and interests or as authorised by law

User Documentation

We actively minimise and strip unnecessary personal information from customer-uploaded documents like 1099-DAs, and only retain the data required to process the form and reconcile your transactions. Reducing our long-term data footprint is a deliberate design choice for Summ.

Our disclosures of personal information to third parties

We may disclose personal information to:

Service providers

IT service providers
Data storage providers
Web hosting and server providers
Payment processors
Marketing and advertising providers
Analytics providers

Professional advisers

Bankers
Auditors
Insurers and insurance brokers
Legal advisers

Business partners

Our existing or potential agents
Our business partners or contractors

Corporate transactions

If we merge with or are acquired by another company, or sell our business assets:

Your information may be disclosed to our advisers
Your information may be disclosed to the potential purchaser's advisers
Your information may be included in the transferred assets

Legal and regulatory bodies

Courts and tribunals
Regulatory authorities including as required for reporting obligations
Law enforcement officers

Other parties

A parent, subsidiary, or affiliate of our company
Third parties you have authorised
Emergency services when necessary
Any other parties as required or permitted by law

Third parties we currently use include, but are not limited to:

Amazon Web Services
Anthropic
CookieBot
FirstPromoter
Google Marketing Platform
Intercom
Meta
Microsoft Advertising
OpenAI
Ortto
PostHog
SendGrid
Stripe
VWO
X (Twitter)

Third Party Tools You Connect Your Account To

If you choose to connect a third-party app or AI tool to your Summ account (for example Claude.ai, Claude Desktop, Cursor, or any other third-party application), we will share your information with that app to the extent you allow when you set up the connection. When you do this:

the third-party provider will receive and process your information, including your prompts and the responses our platform returns. This is governed by that provider's own privacy policy and terms, not ours
your prompts and the outputs from our platform are processed by the third-party provider's systems. We have no control over how they handle, store or use your information once it has been passed to them
the third-party app operates as a separate, independent business in respect of your information. We are not responsible for how they handle it
we only share what is necessary to carry out the connection you have set up
you are responsible for reading the privacy policy and terms of any app before connecting it to your account

Overseas disclosure

Storage and access

We store your personal information in Australia and the United States of America. However, your information may be accessed from or transferred to other locations in these circumstances:

When our service providers are located overseas
When we work with overseas business partners
When using cloud-based services or data storage solutions

If you connect a third-party app to your account, your information may be sent to and processed by that app in countries outside Australia, including the United States. That processing is covered by the third-party provider's own privacy policy. We are not responsible for how they handle your information once it has been passed to them.

Our approach to overseas disclosure

Before disclosing your personal information overseas, we take reasonable steps to ensure that the recipient treats your information in accordance with applicable law by only sending what is necessary, requiring recipients to protect your information through contractual agreements which require the recipient to comply with the privacy standards in applicable law or through other mechanisms that provide comparable safeguards and by monitoring how recipients handle your information.

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Your privacy rights and choices

Providing information

You can choose whether to provide personal information to us, however, if you don't provide certain information, we may not be able to provide some services. Let us know if you don’t want to provide information and we will let you know when information is required versus optional.

Access to your information

You can request access to the personal information we hold about you and we will respond to your request within a reasonable time. We may charge a reasonable administrative fee for providing access and if we cannot provide access, we will explain why and explore alternative ways to share relevant information.

Correction rights

You can ask us to correct any information that is inaccurate, out of date, incomplete, irrelevant or misleading and we will take reasonable steps to correct your information promptly. If we cannot make the correction, we will explain why and discuss alternatives. You can ask us to add a statement to your information noting your requested correction.

Marketing communications

You can opt-out of receiving marketing communications at any time. Each marketing communication will include an unsubscribe option. You can change your marketing preferences by contacting us. We will process your request as soon as practicable.

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How to contact us about your rights or to make a complaint and what happens next

Step 1: Contact our privacy officer

Email: [email protected]

What to include:

Your full name, contact details, clear details about your request or complaint, and any relevant dates or reference numbers.
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Step 2: Our response

We will:

Verify your identity before processing your request
Investigate thoroughly (for complaints) or process your request (for rights)
Respond to you in writing within reasonable timeframes and as required by law
Explain what actions we will take and keep you updated on progress
Not charge you for making a request (except for reasonable access fees if applicable)
Help you understand and exercise your rights

Step 3: If you're not satisfied (complaints only)

If you're not satisfied with our response to your complaint, you can:

Ask for a review by our senior management, or
Contact external bodies:

Australian residents: Office of the Australian Information Commissioner (Phone: 1300 363 992, Website: www.oaic.gov.au)
NZ residents: Office of the Privacy Commissioner (Phone: 0800 803 909, Website: www.privacy.org.nz)
EU residents: Your local Data Protection Authority (DPA). Each EU member state has its own supervisory authority. You can find your local DPA through the European Data Protection Board website: https://edpb.europa.eu/about-edpb/about-edpb/members_en
UK residents: Information Commissioner’s Office (Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, helpline number: 0303 123 1113, website: https://www.ico.org.uk/make-a-complaint)
Any other country: your local authority which regulates data protection issues.

You don't have to contact us first before going to the regulatory authority, but we'd appreciate the opportunity to try to resolve your concerns directly with you.

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This is the same process whether you want to access your information, correct mistakes, change marketing preferences, or make a complaint about our privacy practices.

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Protecting your information

We use multiple layers of security to protect your information.

Technical safeguards

Enterprise-grade encryption for data storage and transmission
Regular security testing and monitoring
Automated threat detection systems

Operational security

Staff training on security and privacy
Strict access controls based on job requirements
Regular security audits and incident response procedures testing

Physical security

Secure premises with controlled access
Secure disposal of physical documents
Equipment security protocols

Public information

Please note that any information you choose to share publicly on online platforms (such as comments or reviews) can be accessed and used by others. We cannot control or protect information that you make publicly available.

How long we keep your information

We keep your personal information only as long as we need it for the purposes we collected it, or as required by law. When we no longer need it, we securely destroy or de-identify it.

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When you connect a third-party app to your account, we create an access token to keep that connection running. These tokens expire automatically after a set period, after which the app will need to reconnect. You can also cancel a token at any time by disconnecting the app through your account settings. Once a token expires or is cancelled, the app can no longer access your account.

Cookies and Analytics

What We Use

We use cookies, tracking pixels, and similar technologies on our website and in our emails to improve your experience and our services.

Cookies

Small text files stored on your device
Help remember your preferences
Enable certain website functions
Make your interactions with our website more efficient

Tracking Pixels

Tiny, invisible images in web pages and emails
Help us understand how you interact with our content
Allow us to measure email engagement
Enable more relevant content delivery

How we use these technologies

Essential Functions:

Remember your login status
Maintain your session security
Store your preferences
Enable core website features

Analytics and Performance:

Understand how our website is used
Measure page views and traffic
Analyse user navigation patterns
Identify areas for improvement

Personalisation:

Remember your preferences
Tailor content to your interests
Improve your browsing experience
Provide relevant recommendations

Your control

You can manage these technologies by:

Adjusting your browser settings to block or delete cookies
Using privacy-focused browser extensions
Configuring your email client to block images
Using our cookie preference settings

Note: Blocking all cookies may affect website functionality and your user experience.

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Google Analytics

We use Google Analytics to understand how people use our website. This involves cookies that collect information about your browsing activity. You can opt out of Google's advertising features through your Google account settings, browser add-ons, or your device's privacy settings. Google provides various tools and options to control how your data is used for advertising purposes. You can learn more about how Google uses your data and your available options on Google's privacy pages.

Meta advertising tools

We use Meta's advertising tools (such as Meta Pixel) to understand how our ads perform and to show you more relevant advertisements on Meta platforms like Facebook and Instagram when you visit our website or app. You can manage whether we connect information from our website with your Meta account for advertising purposes by adjusting your settings within your Meta account preferences.

When you sign in with another account (like Coinbase or Google)

What we collect

When you use single sign-on to connect with us, we'll receive personal information from that provider based on your privacy settings with them. This may include your name, username, profile picture, and other details you've chosen to share.

How we use it

We use this information to create your profile on our platform and give you access to our services.

Artificial Intelligence (AI) Technologies

Overview

We use artificial intelligence and machine learning technologies in our business operations and services, including AI tools provided by third parties. We only use these technologies when legally permitted and necessary for our business.

How we use AI

We may use AI technologies to:

Conduct analysis and data processing
Generate and modify content and coding
Improve and optimise our services and operations
Automate routine tasks and communications
Personalise your experience with our services
Support quality assurance processes
Assist with customer support and queries

Data protection and security

When we work with third-party AI providers, we ensure they handle your personal information in accordance with privacy laws through contractual requirements and appropriate safeguards.

Your rights and our commitments

Any information generated or inferred about you by AI technologies is treated as personal information, and you maintain all the rights outlined in this privacy policy. When using AI with your personal information, we commit to:

Transparency and control

We'll inform you when AI is used to make decisions that may significantly affect you
We maintain human oversight and review of significant AI-generated decisions
Our staff are trained to understand AI limitations and verify outputs before relying on them
We implement processes to verify the accuracy of AI-generated outputs

Security

We use appropriate technical and organisational measures to maintain the security and integrity of your personal information
We do not permit the AI providers we use to use any information to train their large language models
We regularly test and monitor AI outputs for accuracy and reliability

Risk mitigation

We regularly assess and document risks associated with using AI to process personal information
We implement appropriate measures to address these risks
We continuously monitor AI performance and regularly review their impact

Third party AI tools you connect to your account

As well as our own use of AI described above, you can connect third-party AI tools to your Summ account. If you do:

depending on the permissions you grant, the tool may access your transaction history, portfolio, tax reports, connected wallets and exchanges, and tax settings. If you also turn on write access, the tool may be able to add or change information in your account
we do not store the prompts you send to the third-party tool or the responses it gives you. That information passes through in transit and is not kept by us
your account information accessed through the connection is stored in the same systems we use for the rest of your Summ data
we do not guarantee the accuracy of anything a third-party AI tool produces, including any tax-related outputs like capital gains summaries or tax reports. You should check these with a qualified accountant before relying on them
you can disconnect a third-party tool at any time through your account settings. This will stop it from accessing your account going forward, but we cannot retrieve or delete any information it has already received

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Amendments

We may update this policy at any time by posting the revised version on our website. We recommend that you review our website regularly to stay current with any policy changes.

Appendix 1: additional rights and information for individuals located in the eu or uk

Under the General Data Protection Regulation (EU) 2016/679 (GDPR) and, for UK residents, the UK General Data Protection Regulation (as incorporated into UK law) and the Data Protection Act 2018 (together, the European Data Protection Laws), individuals located in the EU and UK have additional rights which apply to their personal information. Personal information under these Data Protection Laws is often referred to as personal data and is defined as information relating to an identified or identifiable natural person. This Appendix 1 sets out the additional rights we give to individuals located in the EU and UK, as well as the lawful basis on how we process the personal information of individuals located in the EU and UK.

Legal bases for processing personal information

European Data Protection Law requires us to have proper legal reasons for using your personal data. We can only use your information when we have one or more of these legal bases.

Consent - You have clearly agreed to us using your personal data for a specific purpose.
Performance of a contract - We need to use your information to fulfil a contract with you, or because you've asked us to do something before entering into a contract.
Legal duty - We must use your information to comply with the law.
Vital interests - We need to use your information to protect someone's life.
Public interest - We need to use your information to perform a task in the public interest or carry out official functions that have a clear legal basis.
Legitimate interests - We have a genuine business reason to use your information, or a third party does, but only if this doesn't unfairly override your rights and interests. Where we rely on legitimate interests as our legal basis, we have conducted balancing tests to ensure our interests do not override your fundamental rights and freedoms. These assessments consider:
- The nature of our legitimate interest
- The impact on you
- Any safeguards we can implement
- Your reasonable expectations
- The broader context of our relationship

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 data. We have listed the reasons we process your data and the legal basis below. Please reach out to us if you need further details about the specific legal basis we are relying on to process your personal data.

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The full purposes of processing are set out in the policy above under “Why we collect, hold, use and disclose personal information” and the legal basis for this processing is set out below