Privacy Policy | Summit Real Estate Group

Effective Date: July 10, 2026

Last Reviewed on Date: July 10, 2026

Introduction

Summit Real Estate Group (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website, https://summitstl.com/, (our “Website”) or otherwise interact with us, whether online or in person, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

On this Website.
In email, text, and other electronic messages between you and this Website.
Offline or through any other means.

This policy does not apply to information collected by any third party, including any website or content that may link to or be accessible to, from or on the Website. Further, this policy does not apply to any Personal Data (defined below) collected from or about any of our employees. Personal Data collected from any such employees will be protected by our employment policies and handbook.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website, purchase our products or services, provide us with your Personal Data, or otherwise interact with us. By accessing or using this Website, providing us with Personal Data, purchasing our products or services, or otherwise interacting with us, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website, our products or services, provision of your Personal Data, or other interactions with us after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features on the Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data 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 info@summitstl.com.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, our investors and potential investors, and those individuals with whom we do business or that otherwise interact with us. We collect information: (i) by which you may be personally identified, such as name, birthdate, age, postal address, e-mail address telephone number, veteran status, personal preferences, or any other identifiers by which you may be contacted online or offline; (ii) that is about you but individually does not identify you, such as IP address or other online identifiers, zip code, age, gender, preferences, interests, and favorites; and/or (iii) about your internet connection, the equipment you use to access our Website and usage details (collectively, “Personal Data”).

We collect this information:

Directly from you when you provide it to us.
Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
From third parties, for example, our business partners.

Information You Provide to Us

The information we collect or receive may include:

Information that you provide to us. This includes information provided at the time of registering to use and using our Investor Portal.
Records and copies of your correspondence (including email addresses), if you contact us.
Details of transactions with you.
Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including information about your computer and internet connection, including your IP address, operating system, and browser type.

The technologies we use for this automatic data collection include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Our Website only uses essential cookies. You may refuse to accept browser cookies by activating the appropriate setting on your browser; however, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

For information about managing your privacy and security settings for these objects and cookies, see Choices About How We Use and Disclose Your Information.

Do Not Track (“DNT”) and Global Privacy Control (“GPC”) are privacy preferences that users can set in their web browsers. Our Website does not track you and we do not share or sell your Personal Data. Therefore, we do not recognize DNT or GPC signals from your browser.

There are additional disclosures for residents of certain states in the Special U.S. Privacy Information Section below.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Data:

To present our Website and its contents to you.
To provide you with information, products, or services that you request from us.
If applicable, to create, maintain, customize, and secure your account with us.
To operate our business.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your experience and to deliver content and product and service offerings.
To communicate with you.
To allow you to participate in interactive features on our services.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To help maintain the safety, security, and integrity of our assets, including our technology assets, and our business.
For testing, research, analysis, and development.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by the Company about our users is among the assets transferred.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To fulfill any other purpose for which you provide it.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

There are additional disclosures for residents of certain states in the Special U.S. Privacy Information Section below.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates.
To the contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them.
To the professional service providers, including financial services, accounting services and legal representation, including with regard to prevention harm to our company, its affiliates and subsidiaries, our products or services or a person or property (e.g., fraud or other illegal activity prevention).
To other third parties with whom we do business.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by the Company about our Website users is among the assets transferred.
We contractually require these third parties to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
To those third parties who are necessary to fulfill the purpose for which you provide it.
To third parties when required or permitted by law.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your Personal Data:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply any agreements we have with you.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

There are additional disclosures for residents of certain states in the Special U.S. Privacy Information Section below.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Data you provide to us.

We do not control third parties’ collection or use of your information to serve interest-based advertising or other targeted advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You may also delete your history, clear your cache and delete or manage cookies through your browser and device settings. Please note that you may continue to receive generic ads.

Accessing and Correcting Your Information

You may send us an email at info@summitstl.com to request access to, correct or delete any Personal Data that you have provided to us. We cannot delete your Personal Data except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

There are additional disclosures for residents of certain states in the Special U.S. Privacy Information Section below.

Special U.S. Privacy Information

Certain U.S. state laws may provide you with additional rights regarding our use of your Personal Data. As described in this Privacy Notice, some of the Personal Data we collect information constitutes “personal information,” “personal data,” or “sensitive personal information” or “sensitive data” under these state laws. Any such “sensitive personal information” or “sensitive data” is referred to as “Sensitive Data” herein.

In particular, within the last twelve (12) months, we collected (whether directly, indirectly (e.g., through cookies on the Website) or from third parties) the categories of Personal Data, which constitute “personal information” or “sensitive personal information” under certain state privacy laws, as described in this Privacy Policy. Any such collection has been for of the purposes included in the appropriate section of the How We Use Your Information Section above.

For the purposes of this Section, Personal Data does not include information specifically excluded from the scope of applicable data protection laws, such as publicly available information from government records, lawfully obtained, truthful information that is a matter of public concern, deidentified or aggregated consumer information or information specifically excluded from the scope of applicable data protection laws, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data or other biomedical research study or personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), the Federal Farm Credit Act of 1971, and the Driver’s Privacy Protection Act of 1994.

We have not sold any Personal Data or Sensitive Data of consumers in the last 12 months. We have not shared any Personal Data or Sensitive Data of consumers with third parties for cross-context behavioral advertising or targeted advertising in the last 12 months.

Company obtains the categories of Personal Data listed above from the following categories of sources:

Directly from you when you provide it to us.
Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
From third parties, for example, our business partners.

We may disclose your Personal Data or Sensitive Data to a third party for a business purpose. When we disclose Personal Data or Sensitive Data for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Data and Sensitive Data confidential and not use it for any purpose except performing the contract. We disclosed this Personal Data and Sensitive Data for a business purpose to the following categories of third parties:

To our subsidiaries and affiliates;
To contractors, service providers, and other third parties we use to operate or support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them;
To professional service providers, including financial services, accounting services and legal representation, including with regard to prevention harm to our company, its affiliates and subsidiaries, our products or services or a person or property (e.g., fraud or other illegal activity prevention);
To other third parties with whom we do business;
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by the Company about our Website users is among the assets transferred;
To those third parties who are necessary fulfill the purpose for which you provide it;
To third parties when required or permitted by law;
For any other purpose disclosed by us when you provide the information; and
With your consent.

As applicable, certain state privacy laws provide their residents, respectively, with specific rights regarding their Personal Data.

A. Access to Specific Information and Data Portability Rights. You may have the right to request that we disclose certain information to you about our collection and use of your Personal Data and Sensitive Data. Once we receive and verify your request (please see Subsection Exercising Access, Data Portability, Correction, and Deletion Rights below for more information), we will disclose to you, as applicable:

The categories of Personal Data and Sensitive Data that we collected about you.
The categories of sources for the Personal Data and Sensitive Data we collected about you.
Our business or commercial purpose for collecting or sharing that Personal Data and Sensitive Data.
The categories or a list of third parties to whom we disclose that Personal Data and Sensitive Data.
The specific pieces of Personal Data and Sensitive Data we collected about you (also called a data portability request).
If we disclosed your Personal Data and Sensitive Data for a business purpose, the Personal Data and Sensitive Data categories that we disclosed for a business purpose and for each category identified, the categories of third parties to whom we disclosed that particular category of Personal Data or Sensitive Data.

B. Correct Specific Information. You may have the right to request that we correct inaccurate Personal Data or Sensitive Data about you. Once we receive and verify your request (please see Subsection Exercising Access, Data Portability, Correction, and Deletion Rights below for more information), we will use commercially reasonable efforts to correct the information to comply with your request. Not all state privacy laws afford this right to their residents.

C. Deletion Request Rights. You may have the right to request that we delete any of your Personal Data or Sensitive Data that we collected from you and retained, subject to certain exceptions. Once we receive and verify your request (please see Subsection Exercising Access, Data Portability, Correction, and Deletion Rights below for more information), we will delete (and direct our service providers to delete) your Personal Data or Sensitive Data from our records, unless an exception applies. In responding to your request, we will inform you whether or not we have complied with the request, and, if we have not complied, provide you with an explanation as to why.

We may deny your deletion request as permitted by applicable law. For example, we may deny your deletion request if retaining the information is necessary for us, or our service provider(s), to:

Complete the transaction for which we collected the Personal Data or Sensitive Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Help to safeguard security and integrity of your Personal Data and Sensitive Data to the extent the use of your Personal Data or Sensitive Data is reasonably necessary and proportionate for those purposes.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise his/her free speech rights, or exercise another right provided for by law.
Comply with other applicable laws.
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.

D. Right to Limit Use and Disclosure of Sensitive Data. You may have the right, at any time, to direct the Company to limit our use and disclosure of your Sensitive Data to use which is necessary for certain purposes enumerated in applicable law (“Enumerated Purposes”). To the extent we use or disclose your Sensitive Data for purposes other than the Enumerated Purposes, you have the right to limit such use or disclosure. To the extent applicable, you may also have the right to withdraw consent you provided for our use and disclosure of your Sensitive Data.

Currently, we do not use Sensitive Data for purposes other than the Enumerated Purposes above.

E. Exercising Access, Data Portability, Correction and Deletion Rights. To exercise the access, data portability, correction, and deletion rights described above, please submit a consumer request to us through one of the following:

Email at info@summitstl.com
Mail at 135 North Meramec Avenue

Suite 600

St. Louis, MO 63105

When you use a request method above, we will request certain information for verification purposes, such as your name, address, and e-mail address. We will use this information to verify this is a permitted request, such as by matching your name and address with information in our records. Depending on the type of request, we may require a certain number of data points to allow for verification.

Only you, or a person properly authorized to act on your behalf, may make a verifiable consumer request related to your Personal Data. You may also make a verifiable consumer request on behalf of your minor child.

An authorized agent may make a request on your behalf using the request methods designated above. Additionally, if you use an authorized agent to submit a consumer request, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to verify your own identity directly with us or directly confirm with us that you provided the authorized agent with permission to submit the request.

You may only make a consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized agent of such person.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Data associated with that specific account.

We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

If we deny your request, you may have the right to appeal our decision. Further, if you appeal and your appeal is denied, you may have the right to complain to your state’s attorney general. You may appeal your decision by contacting us at

Email at info@summitstl.com
Mail at 135 North Meramec Avenue

Suite 600

St. Louis, MO 63105

G. Response Timing and Format. In accordance with applicable law, we endeavor to respond to consumer requests within forty-five (45) days of their receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing. We will also notify your account following the correction of inaccurate information, or the deletion of Personal Data.

The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

You may make a consumer request for access or data portability free of charge twice within a 12-month period. Additional requests may be subject to a fee. We may charge a fee to process or respond to your consumer request if it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

H. Non-Discrimination. We will not discriminate against you for exercising any of your rights. Unless permitted by applicable laws, in connection with you exercising your rights, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by applicable laws that can result in different prices, rates, or quality levels. Any legally-permitted financial incentive we offer will reasonably relate to your Personal Data’s value to us and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

I. Other California Privacy Rights. To the extent applicable, California Civil Code Section § 1798.83 permits California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make these requests, please send an email to info@summitstl.com or by mail to 135 North Meramec Avenue, Suite 600, St. Louis, MO 63105.

Data Security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Information Received from Third Parties

If you choose to connect your investor account to your account on another service, we may receive information from the other service. You may also choose to grant us access to your data from another service. You can stop sharing the information from the other service with us by removing our access to that other service.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about any third party’s policies or procedures, you should contact the responsible provider directly.

Other Sites

Our Website may contain links to other sites, including those of our business partners. While we seek to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or privacy and security practices and policies of these websites or any other sites that are linked to from our Website, or any damage to, or viruses that may infect your computer equipment or other property, or for any loss or corruption of data resulting from any third party website navigated to or accessed from links hosted on or contained in our Website. If you decide to access any website linked to or on our Website, you do so entirely at your own risk. We do not guarantee that you will receive an alert when you leave our Website, and it is your responsibility to determine when you have left the Website. Any Personal Data you provide on linked pages or applications is provided directly to that third party and is subject to that third party’s privacy policy. We encourage you to learn about their privacy and security practices and policies before providing them with Personal Data.

Governing Law

Our Website is intended for use by residents of the United States only. All matters relating to this Privacy Notice will be governed by the laws of the State of Missouri, U.S.A.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy from time to time. To the extent required by applicable law or regulation, we will contact individuals whose Personal Data is within the scope of such law or regulation and then currently being processed to obtain prior affirmative express consent to any material changes to how we collect, use, and/or process such individual’s Personal Data or to this privacy policy. In addition, if we make any material changes to this privacy policy, including any material changes to how we collect, use, and/or process your Personal Data, we will prominently post notice that changes have been made on this page of the Website. We encourage you to periodically review this page for the latest information on our privacy policy.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Email: info@summitstl.com

Postal Address: 135 North Meramec Avenue

Suite 600

St. Louis, MO 63105