Privacy Policy

Last Updated: 17 July 2025

This Privacy Policy provides our privacy policy regarding the nature, purpose, use, and sharing of personal data or other information collected from the users of the summer.fi website and other websites which use subdomains of summer.fi (the "Site"). We are committed to protecting and respecting your privacy. Please read this carefully as this Privacy Policy is legally binding when you use the Site.

As used in this Privacy Policy, "we", "us" or "our" refers to Oazo Apps Limited, a company incorporated and registered in England, United Kingdom. We are the controller and responsible for your personal data. You can reach us with any requests relating to this Privacy Policy via the contact details set out in the Contact us section of this Privacy Policy.

The types of personal data we collect about you:

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, date of birth and gender.
• Contact Data includes email address and delivery address.
• Financial Data includes information on your cryptocurrency wallet account balance and virtual currencies.
• Transaction Data includes details about your blockchain transaction history and information relating to your use of the services on our website.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, Ethereum blockchain data, wallet address, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Profile Data includes your preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a referral programme; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, Browse actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy https://summer.fi/cookie for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third party sources including third parties we provide services to, analytics providers and the Ethereum blockchain where we may collect public Ethereum addresses and email addresses to identify and document a user’s journey through our products.

How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Blockchain Data

Note that we are not responsible for your use of the Ethereum blockchain and your data processed in this decentralized and permissionless network.

Direct marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us using the details set out in the Contact us section of this Privacy Policy.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to updates to our Terms and Conditions, checking that your contact details are correct.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see https://summer.fi/cookie.

Disclosures of your personal data

We may share your personal data where necessary with the parties set out below.

• Service providers acting as processors who provide services including IT and system administration services, online form management, hosting services, payment processing, fraud and identity verification providers, service support, email delivery and administration, and data storage and analysis.
• Our professional advisors including lawyers, auditors, insurers, consultants and who provide legal, accounting and insurance services.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Please note that we may transfer your personal data outside the EU/EEA/UK to third parties for the purposes of the data processing and external access by you of services provided by those third parties including to jurisdictions not offering the same level of data protection as the UK. In such circumstances, we ensure that such transfers are subject to appropriate safeguards which give the transferred personal data the same protection as it has in the UK.

To obtain a copy of these contractual safeguards, please contact us using the details set out in the Contact us section of this Privacy Policy.

Data security

We use appropriate technical and organizational security measures to protect your personal data. Our security measures are continuously improved in line with technological developments.

Please note that any data transmission on the Internet (e.g. communication by email) is generally not secure and, subject to any liability which cannot be excluded under applicable law, we accept no liability for data transmitted to us via the Internet.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Data retention

We will retain your personal data only for as long as reasonably necessary to achieve the purpose of the processing we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your rights

Right to access

As a data subject, you have the right to obtain from us information about your personal data processed at any time and a copy of this information. Furthermore, you will have access to the following information: the purposes of the processing; the categories of personal data concerned; where possible, the envisaged period for which the personal data will be processed, or, if not possible, the criteria used to determine that period; the existence of the right to request from us rectification or erasure of personal data, or restriction of processing of personal data concerning you, or to object to such processing; the existence of the right to lodge a complaint with a supervisory authority; where the personal data are not collected directly from you, any available information as to their source; and the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for you.

Right to rectification

You have the right to obtain from us, without undue delay, the rectification of inaccurate personal data concerning you however we may need to verify the accuracy of the new data you provide to us. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to be forgotten

You have the right to obtain from us the erasure of personal data concerning you as soon as possible, and we shall have the obligation to erase personal data without undue delay where required by the law, including when:

• the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• there is no longer a legal ground for the processing;
• you object to the processing and there are no overriding legitimate grounds for the processing;
• the personal data has been unlawfully processed;
• the personal data must be erased for compliance with a legal obligation in accordance with the applicable law to which we are subject.

Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Right to restriction of processing

You have the right to obtain from us the restriction of processing where one of the following applies:

• the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
• we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims; and/or
• you have objected to processing pursuant to applicable laws.

Right to object

You have the right to object at any time, to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data. We shall no longer process the personal data in the event of the objection unless we can demonstrate reasonable grounds for the processing, which override the interests, rights and freedoms of you, or for the establishment, exercise or defense of legal claims.

You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting out of marketing above for details of how to object to receiving direct marketing communications).

Right to withdraw data protection consent

You have the right to withdraw your consent to the processing of your personal data at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the details set out in the Contact us section of this Privacy Policy.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Conflict or Inconsistency

In the event of any conflict or inconsistency between this Privacy Policy and any non-English language translation thereof, the terms and provisions of this Privacy Policy shall control.

Contact us

Please contact us with questions, comments, or concerns regarding our Privacy Policy as well as with any requests at legal@summer.fi.

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Amendments to this Policy

We may amend this Privacy Policy at any time by posting the amended version on the Site including the effective date of the amended version. The current version of the Privacy Policy, as published on the Site, is applicable.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.