Privacy Policy

1. Introduction

Summer ApS ("we", "us", or "our") is committed to protecting your privacy . This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use Summer Engine, our AI-powered game development platform ("Service").

This Privacy Policy complies with the General Data Protection Regulation (GDPR) and Danish data protection laws. As a Danish company, we are subject to the jurisdiction of the Danish Data Protection Agency.

2. Information We Collect

2.1 Personal Information

We collect information you provide directly to us, including:

• Account information (name, email address, password)
• Profile information and preferences
• Payment information (processed by third-party payment processors)
• Communications with our support team
• Feedback and survey responses

2.2 Usage Information

We automatically collect information about your use of our Service:

• Device information (operating system, browser type, device identifiers)
• Usage patterns and feature interactions
• Performance data and error logs
• IP address and general location information

2.3 Code and Content

When you use Summer Engine, prompts you send and code snippets included with those prompts are transmitted to our model providers to generate responses. How we and our providers handle that content depends on whether Privacy Mode is enabled on your account — see How we use your prompts and code below.

3. How we use your prompts and code

We do not use your prompts, generated outputs, or code snippets ("Inputs and Outputs") to train our models, or permit third parties to use them for training, unless one of the following applies:

• (1) the content has been flagged for safety or security review;
• (2) you have explicitly shared the content with us as Feedback or as part of a bug report; or
• (3) you have not enabled Privacy Mode on your account.

Privacy Mode is available on all paid plans and disables training-data use for your account when turned on. Free accounts do not have access to Privacy Mode and are subject to (3) by default. You can read more about Privacy Mode at /security and at docs.summerengine.com/security/privacy-mode.

4. How We Use Your Information

We use your information for the following purposes:

• Service Provision: To provide, maintain, and improve Summer Engine
• AI Assistance: To generate relevant code suggestions and game development assistance
• Account Management: To manage your account and provide customer support
• Communication: To send important updates, security alerts, and respond to inquiries
• Analytics: To understand usage patterns and improve our Service
• Security: To detect and prevent fraud, abuse, and security incidents
• Legal Compliance: To comply with applicable laws and regulations

5. Legal Basis for Processing (GDPR)

Under GDPR, we process your personal data based on the following legal grounds:

• Contract Performance: To provide the Service you've subscribed to
• Legitimate Interest: To improve our Service, ensure security, and conduct analytics
• Consent: For marketing communications and optional features (where required)
• Legal Obligation: To comply with applicable laws and regulations

6. Information Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

• Service Providers: With trusted third parties who assist in operating our Service
• AI Model Providers: Anonymized data may be sent to AI model providers for processing
• Legal Requirements: When required by law or to protect our rights
• Business Transfers: In connection with mergers, acquisitions, or asset sales
• Consent: With your explicit consent for specific purposes

7. Data Security

We implement appropriate technical and organizational measures to protect your information:

• Encryption in transit and at rest
• Regular security assessments and updates
• Access controls and authentication measures
• SOC 2 certification (in progress)
• Privacy Mode for enhanced code protection

8. Data Retention

We retain your information for as long as necessary to provide our Service and comply with legal obligations:

• Account Data: Until you delete your account or request deletion
• Usage Data: Typically 2-3 years for analytics purposes
• Inputs and Outputs: When Privacy Mode is enabled, our model providers do not retain your prompts or generated outputs. When Privacy Mode is not enabled, we may retain Inputs and Outputs to operate and improve our models, as described in Section 3.
• Legal Requirements: As required by applicable laws

9. Your Rights (GDPR)

Under GDPR, you have the following rights regarding your personal data:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your personal data
• Restriction: Limit how we process your data
• Portability: Receive your data in a structured format
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent for consent-based processing

To exercise these rights, contact us at founders@summerengine.com. We will respond within 30 days.

10. International Data Transfers

We may transfer your data outside the European Economic Area (EEA) to provide our Service. When we do so, we ensure adequate protection through:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions by the European Commission
• Other appropriate safeguards as required by GDPR

11. Cookies and Tracking

We use cookies and similar technologies to:

• Remember your preferences and settings
• Analyze usage patterns and improve our Service
• Provide security features
• Enable certain functionality

You can control cookies through your browser settings. Some features may not work properly if cookies are disabled.

12. Children's Privacy

Summer Engine is not intended for children under 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected such information, we will delete it promptly.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via email or through our Service. The updated policy will be effective when posted.

14. Contact Information

For questions about this Privacy Policy or to exercise your rights, contact us at:

You also have the right to lodge a complaint with the Danish Data Protection Agency (Datatilsynet) if you believe we have not handled your personal data in accordance with applicable law.