Privacy Statement

1. Introduction

The Thompson Group ("we," "us," or "our") is committed to safeguarding the privacy of individuals who interact with our businesses. This Privacy Statement describes how we collect, use, disclose, and protect personal data when engaging with our companies, which include:

• Taidou LLC – A management consulting firm offering advisory services in government, healthcare, financial services, and technology.
• Summr – A systematic hedge fund leveraging data-driven models for trading in NYSE and NASDAQ equities and ETFs.
• Mavn Institute - Center of Excellence – A research and knowledge management platform designed for data-driven insights, compliance reporting, and strategic analysis.

This Privacy Statement applies to all clients, employees, contractors, partners, and vendors who engage with any of the above entities. We recognize that privacy laws differ across jurisdictions, and we take measures to comply with applicable laws such as the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and U.S. federal financial regulations.

By using our services, engaging with our business platforms, or providing us with personal information, you consent to the terms outlined in this Privacy Statement.

2. Information We Collect

We collect different types of personal and business data depending on the nature of our interaction with you. These data points help us provide personalized services, maintain security, and meet regulatory obligations.

A. Personal Information (collected when you sign up, interact, or engage with us)

• Full name, email address, phone number, mailing address
• Date of birth and nationality (for compliance verification)
• Employment history, business affiliations, and certifications
• Banking details (for investment transactions, payments, and consulting fees)
• Social Security Number (SSN) or Tax Identification Number (TIN) (if required for financial reporting)

B. Business & Financial Data (collected for advisory, investment, and consulting purposes)

• Investment details, portfolio allocation, and transaction history (for Summr clients)
• Business financials, contracts, and invoices (for Taidou consulting clients)
• Research data, academic publications, and technical reports (for Mavn users)

C. Technical & Usage Data (collected automatically through digital interactions)

• Website browsing activity, IP addresses, and cookies
• Device identifiers, authentication logs, and session data
• Behavioral analytics for fraud prevention and security monitoring

D. Communications & Preferences

• Customer support inquiries, email correspondence, and call logs
• Marketing preferences, feedback, and survey responses

We do not collect sensitive personal information (e.g., religious beliefs, genetic data, sexual orientation) unless explicitly required by law or regulatory compliance.

3. How We Use Your Information

We use your data for specific business, operational, and compliance purposes. Below is a breakdown of how each category of data is processed.

A. Business Operations & Service Delivery

• Summr: To execute algorithmic trading models, process investment deposits, and manage risk-adjusted returns.
• Taidou: To provide management consulting, risk assessments, and compliance solutions for clients.
• Mavn: To manage knowledge-based reporting, research analytics, and secure data storage.
• To personalize our services based on client needs, transaction history, or business objectives.

B. Compliance & Regulatory Obligations

• To verify client identities and conduct due diligence under Know Your Customer (KYC) and Anti-Money Laundering (AML) laws.
• To meet financial regulatory requirements set by SEC, IRS, and international financial governing bodies.
• To prevent fraud, identity theft, and unauthorized account access.

C. Marketing & Customer Engagement

• To send newsletters, investment updates, and industry insights.
• To conduct surveys for improving our services and offerings.
• To tailor promotional content based on preferences and past interactions.

D. Data Analytics & Security Enhancements

• To improve the accuracy of our trading algorithms in Summr.
• To refine consulting methodologies in Taidou through historical case study analysis.
• To enhance cybersecurity defenses, including multi-factor authentication (MFA) and AI-driven threat detection.

We will never use your data for automated decision-making without human oversight in areas where such decisions may have a legal or financial impact.

4. Data Sharing & Disclosure

We do not sell personal data to third parties. However, we may share data in the following scenarios:

A. Internal Business Operations

• Cross-sharing within The Thompson Group: Data may be shared across Summr, Taidou, and Mavn when services are interconnected (e.g., an advisory client at Taidou may opt to invest through Summr).

B. Third-Party Service Providers

We work with trusted partners to provide core services, including:

• Cloud service providers (Google Firebase, AWS, Microsoft Azure)
• Payment processors & banks (for transactions and payroll processing)
• Legal & regulatory firms (for audits, legal compliance, and contract management)

C. Legal & Regulatory Disclosures

• If required by law enforcement, court orders, or financial regulators, we will comply with disclosure requests.
• We reserve the right to share data in cases of fraud detection, cyber threats, or security investigations.

D. Mergers, Acquisitions & Business Transfers

• If The Thompson Group is involved in a corporate restructuring or merger, personal data may be transferred as part of the business transaction.

5. Data Retention & Security

We have a data retention policy based on regulatory and business requirements:

• Financial transactions: Stored for 7 years (regulatory requirement).
• Investment records: Retained for 5 years post-account closure.
• Research & consulting data: Retained as long as relevant to business needs.
• Marketing data: Retained until you opt out of communications.

A. Security Measures

We implement enterprise-grade security protocols to protect your information:

• End-to-end encryption: All sensitive financial data is encrypted.
• AI-driven fraud detection: Proactive monitoring of suspicious activity.
• Multi-layered authentication: MFA and biometrics for high-risk accounts.

While we take strong measures, no digital platform is 100% secure. Clients are advised to maintain strong passwords and report suspicious activity.

6. Your Rights & Choices

Depending on your jurisdiction, you have the following rights:

A. Data Access & Correction

• You may request a copy of your personal data or corrections to inaccurate details.

B. Right to Deletion

• You can request deletion of personal data, subject to regulatory obligations.

C. Marketing Preferences

• You may opt out of promotional emails at any time.

To make a request, email privacy@summr.tech.

7. Cookies & Tracking Technologies

We use cookies and similar technologies for website optimization. You can manage cookie settings through your browser.

8. Updates to This Privacy Statement

We may update this Privacy Statement periodically. The latest version will always be posted on our website.

9. Contact Us

For privacy-related inquiries, contact:

📧 privacy@summr.tech