SUMRRIA PRIVACY POLICY

Effective Date: September 13, 2026 Last Updated: October 8, 2026 This Privacy Policy explains how Sumrria (“Sumrria,” “we,” “us,” or “our”) collects, uses, stores, shares, and protects information when you use the Sumrria website, membership features, Partner Rewards, Coop, Surf, referral features, Solo Mailer, email subscriptions, third-party offers, reward redemption features, and related services (collectively, the “Services”). By using Sumrria, you acknowledge the practices described in this Privacy Policy.

1. Information We Collect

We may collect information that you provide directly to us, information generated through your use of Sumrria, and information received from third-party service providers.

Account Information

When you create or use a Sumrria account, we may collect information such as:

• Username
• Email address
• Account identifiers
• Referral or affiliate identifiers
• Profile or membership information
• Account status and activity history

Advertising Information

If you use Sumrria’s Coop or Surf advertising systems, we may collect and store:

• Advertising URLs you submit
• Advertisement titles
• Advertisement creation and expiration dates
• Advertisement view counts
• Advertising progress and qualification data
• Information associated with the account that submitted the advertisement

Email Subscriptions and Solo Mailer Information

If you subscribe to emails or use the Solo Mailer, we may collect and store:

• Your email address, subscriber identifier, account identifier, and relevant profile information
• Subscription lists, subscription status, signup source, and signup or opt-in records, including dates and policy acknowledgments where captured
• Unsubscribe requests, suppression records, and changes to your email preferences
• Email subjects, message bodies, HTML or plain-text format, and submitted offer URLs
• Campaign identifiers, submission dates, queue order, scheduled processing information, and campaign status
• Recipient allocation, delivery attempts, sending results, errors, and records used to apply sending limits
• Recipient-specific tracking tokens, click counts, click timestamps, and email-image loading records where available

We use these records to operate subscriptions, process campaigns, report activity, honor opt-outs, troubleshoot delivery, and prevent misuse. Technical information described below may also be processed by our website, hosting provider, or email delivery providers.

Rewards and Transaction Information

We may collect information relating to Partner Rewards and account activity, including:

• Partner Rewards credit balances
• Coop advertiser progress
• Surf advertiser progress
• Reward redemptions
• Commission or affiliate activity
• Offer completion information
• Purchase and order information
• Refund, reversal, or chargeback information

2. Automatically Collected Information

When you access Sumrria, certain technical information may be collected automatically. This may include:

• IP address
• Browser type
• Device or browser information
• User-agent information
• Pages visited
• Referral URLs
• Dates and times of visits
• Advertising interaction data
• Cookies and similar identifiers

This information may be used for security, fraud prevention, traffic measurement, advertising qualification, duplicate-view prevention, analytics, and operation of the Services.

3. Coop and Surf View Qualification

Sumrria may process technical information to determine whether advertising views qualify toward advertiser rewards. For example, Sumrria may use combinations of an IP address, browser or device information, advertisement identifiers, and time-based records to help prevent the same visitor from repeatedly generating qualifying views for the same advertisement within a restricted period. These measures are intended to reduce duplicate, automated, manipulated, or fraudulent traffic.

4. Cookies and Similar Technologies

Sumrria may use cookies, browser storage, sessions, and similar technologies to operate the website and provide features. These technologies may be used to:

• Keep users logged in
• Remember preferences
• Track referral information
• Maintain advertising progress
• Prevent duplicate activity
• Support security and fraud prevention
• Measure website performance
• Support analytics

Some third-party services used by Sumrria may also place their own cookies or similar technologies according to their own privacy policies.

5. Referral Tracking

Sumrria may use referral links, referral codes, cookies, account identifiers, and related tracking methods to determine whether a visitor or transaction is associated with a referring member. Referral information may be stored for a limited period and may be used to assign eligible commissions, bonuses, or other referral-related benefits. Referral tracking may be rejected or adjusted when Sumrria detects fraud, manipulation, duplicate activity, self-referral abuse, or other violations.

6. Email Subscriptions, Tracking and Choices

What You Subscribe To

The Member Promotions subscription covers promotional emails from Sumrria and participating members, including earning opportunities, member promotions, mailer ads, banner ad placements, Surf traffic rotator offers, and Co-op traffic rotator offers. Entering your email and pressing the subscription button, which may be labeled Claim Access or Subscribe, requests this subscription as described on the signup form. The current signup process normally activates the subscription automatically without requiring a second confirmation email. A welcome email or redirect to an offer page does not mean that a purchase has been made or that paid membership has been granted. The Solo Mailer requires an active Member Promotions subscription to send or resend campaigns. Members may submit several campaigns in advance. A sender’s default 24-hour interval is a limit on that sender’s campaigns; it is not a promise that a recipient will receive only one email per day. Recipients may receive promotions from multiple members, subject to the limits applied by the service.

Tracked Links and Email Images

Offer links may contain a unique tracking token associated with a particular campaign and recipient record. When a tracked link is requested, the mailer can record the click and redirect the visitor directly to the submitted offer URL without a separate offer-interstitial page. The sender dashboard displays aggregate unique-click and total-click statistics. Unique clicks represent recipient records with at least one tracked click; total clicks include repeated tracked requests. Forwarded emails, security scanners, automated software, and shared devices may affect attribution and counts. These figures do not prove that a particular person read an email, purchased something, or intentionally clicked. HTML emails may also contain a small tracking image. Loading it may create an estimated open record or timestamp, even when open statistics are not displayed in the sender dashboard. Image blocking, privacy protections, caching, and automated loading can make these records incomplete or inaccurate. Plain-text messages do not load an HTML tracking image. Tracking tokens do not need to display your email address in the URL, but they can still be linked to your subscriber record in our systems. Website and delivery-provider logs may also contain technical information about requests. External offer websites process visits under their own policies.

Unsubscribing and Email Preferences

You can opt out of Member Promotions using the unsubscribe facility in a promotional email. You do not need to pay or log into your account to request this opt-out. We honor valid requests promptly and within applicable legal deadlines. Contact Sumrria through the website if you need help or want to stop other marketing communications from us. The mailer’s unsubscribe action removes you from Member Promotions. If you separately subscribed to another newsletter, use its unsubscribe facility or contact us to update those preferences too. We retain necessary opt-out records to avoid sending future promotions contrary to your request. Account access, a migration, or a queue reset does not by itself authorize renewed marketing consent. Unsubscribing may make you ineligible to send campaigns and may prevent your queued campaigns from proceeding unless you actively opt in again. Messages already being processed may still arrive. Necessary account, security, purchase, or service communications may continue where permitted by law.

7. How We Use Information

We may use collected information to:

• Create and manage user accounts
• Manage email subscriptions, consent records, and unsubscribe preferences
• Process Solo Mailer queues, deliver campaigns, apply sending limits, and report tracked activity
• Operate the Coop and Surf advertising systems
• Calculate advertiser progress and Partner Rewards credits
• Process reward redemptions
• Track referrals and commissions
• Provide access to third-party offers
• Prevent fraud and abuse
• Investigate suspicious activity
• Maintain website security
• Improve the Services
• Respond to support requests
• Process purchases and orders
• Comply with legal obligations
• Enforce Sumrria’s Terms of Service and other policies

8. Partner Rewards and Credit Records

Sumrria may maintain records of Partner Rewards credits, qualification progress, reward redemptions, and related activity. These records may be used to determine whether a member qualifies for a reward, to prevent duplicate redemptions, and to correct technical or administrative errors. Sumrria may also retain records needed to investigate suspected manipulation, fraud, abuse, or disputes involving credits or rewards.

9. Third-Party Offers and Affiliate Networks

Sumrria may work with third-party advertisers, affiliate networks, survey providers, app providers, merchants, and similar services. When you interact with a third-party offer, information may be transmitted to or received from the applicable third party for tracking, attribution, validation, commission, and reward purposes. Depending on the third party, this may include account identifiers, transaction identifiers, offer identifiers, referral information, completion status, commission information, or other tracking data. Third-party websites and services operate under their own privacy policies. Sumrria does not control how independent third parties collect or process information on their own websites or platforms.

10. WooCommerce and Purchases

Sumrria may use WooCommerce or other ecommerce technology to process products, orders, and reward redemptions. Information related to purchases or orders may include:

• Order number
• Products ordered
• Order status
• Billing information
• Shipping information, where applicable
• Payment status
• Refund or chargeback status
• Reward-credit redemption information

Payment information may be processed by third-party payment providers. Sumrria may not directly receive or store complete payment-card information when payments are handled by an independent payment processor.

11. How We Share Information

Sumrria does not need to sell personal information in order to operate the Services. We may share information when reasonably necessary with:

• Website hosting providers
• Email delivery, SMTP, and newsletter service providers that process addresses, message content, delivery information, or interaction records to operate the mailer
• Payment processors
• Ecommerce providers
• Affiliate networks
• Advertising partners
• Survey and offer providers
• Analytics providers
• Security and fraud-prevention providers
• Technical service providers
• Professional advisers
• Government authorities when legally required

Information may also be disclosed when reasonably necessary to investigate fraud, protect users, enforce agreements, respond to legal process, or protect the rights, property, or security of Sumrria or others.

12. Public or Member-Visible Information

Certain information may be visible to other users as part of Sumrria’s advertising system. For example, an advertisement may display information such as an advertising URL, advertisement title, advertiser username, or view statistics. Solo Mailer recipients see the message content and offer links submitted by the member. The standard sender dashboard provides campaign statistics rather than a downloadable subscriber address list. Authorized administrators and relevant service providers may access subscriber and campaign records when necessary to operate, secure, or support the service. You should avoid submitting personal or confidential information as part of an advertisement unless you intend for that information to be visible to others.

13. Data Security

Sumrria uses reasonable technical and organizational measures intended to protect information against unauthorized access, loss, misuse, alteration, or disclosure. However, no website, database, internet transmission, or storage system can be guaranteed to be completely secure. Users are responsible for maintaining the confidentiality of their account credentials and should notify Sumrria if they believe their account has been compromised.

14. Data Retention

Sumrria may retain information for as long as reasonably necessary to provide the Services, maintain account and transaction records, prevent fraud, resolve disputes, enforce agreements, satisfy legal obligations, and protect legitimate business interests. Different categories of information may be retained for different periods. Email subscription, campaign, delivery, and tracking records may be retained for service operation, reporting, troubleshooting, disputes, and compliance. Displaying only the last seven sent campaigns does not mean older records are automatically deleted. Clearing a queue or resetting sending history is not necessarily a deletion of subscriber records, archived campaigns, tracking tokens, or backups. Necessary unsubscribe and suppression records may remain to respect your preferences. Where the mailer was previously operated through Retifact, Sumrria may receive migrated subscriber, subscription-status, campaign, delivery, and tracking records to continue the same service. Legacy tracking or unsubscribe links may be forwarded from Retifact to Sumrria. A transfer does not constitute a new opt-in, and recorded opt-outs must remain respected. Temporary technical records used for duplicate-view detection or security purposes may be retained for shorter periods than account, transaction, or reward records.

15. Account Closure

If account closure is available, users may request closure through the contact method provided by Sumrria. Closing an account does not necessarily require Sumrria to immediately delete all information. Certain records may be retained where reasonably necessary for legal compliance, fraud prevention, accounting, dispute resolution, security, or enforcement purposes.

16. Your Privacy Rights

Depending on where you live, applicable law may provide you with rights concerning your personal information. These rights may include the ability to request:

• Access to certain personal information
• Correction of inaccurate information
• Deletion of certain information
• Restriction of certain processing
• A copy of certain information
• Information about how personal information is used

These rights are subject to applicable legal exceptions and verification requirements.

17. United States Privacy Rights

Residents of certain U.S. states may have additional rights under applicable state privacy laws. Where required by law, Sumrria will provide eligible users with applicable rights concerning access, correction, deletion, portability, or certain uses of personal information. Sumrria will not unlawfully discriminate against a user for exercising privacy rights provided by applicable law.

18. Children’s Privacy

Sumrria is not intended for children who are legally unable to consent to the use of the Services under applicable law. Sumrria does not knowingly seek to collect personal information from children in violation of applicable law. If Sumrria becomes aware that information was collected from a child in circumstances where parental consent or another legal basis was required but not obtained, Sumrria may take appropriate steps to delete or restrict that information.

19. External Links

Sumrria may contain links to websites or services operated by third parties. This Privacy Policy does not govern the privacy practices of independent third-party websites. Users should review the privacy policies of external websites before providing information to them.

20. International Users

Sumrria may be accessible from multiple countries. Information may be processed in jurisdictions different from the country in which a user resides, depending on the location of Sumrria’s hosting providers, service providers, affiliate partners, and other technical infrastructure. Where required by applicable law, appropriate safeguards may be used for international data transfers.

21. Fraud Prevention and Security

Sumrria may use account information, technical identifiers, transaction records, referral data, IP addresses, device or browser information, advertising activity, and reward information to detect and investigate suspicious or abusive activity. Information associated with suspected fraud may be retained for a reasonable period to prevent repeated abuse and protect the integrity of the Services.

22. Changes to This Privacy Policy

Sumrria may update this Privacy Policy when the Services, technologies, business practices, or applicable laws change. The “Last Updated” date at the top of this page identifies the latest revision. Where required or appropriate, Sumrria may provide additional notice of material changes.

23. Contact Sumrria

If you have questions about this Privacy Policy or wish to make a privacy-related request, please contact Sumrria through the contact method provided on the website. Website: Sumrria.com