Last Modified: April 11, 2024

Primer Global, Inc. and its affiliates (the “Company”, “we”, “our”, or “us”) respects your privacy. This Privacy Notice (this “Privacy Notice”) describes (i) the type of information we may collect from you or that you may provide to us when you visit or use our Service (as defined in our Terms of Service), and (ii) our policies and practices regarding how we collect, use, and disclose such information. For purposes of this Privacy Notice, references to “you” and “your” mean, individually or collectively, as the context dictates, the individual user of our Service; or, if such individual accesses or uses our Service in the capacity as an employee or other service provider of a legally recognized entity, such legally recognized entity. 

If you engage or use our Service, you may be subject to other terms and conditions and disclosures relevant to our Service that are not included in this Privacy Notice.

1.     Acceptance of this Privacy Notice; Application.

This Privacy Notice applies to information we collect from: (i) visitors and users of our Service; (ii) you when you and us email, text, and/or exchange other electronic messages; and (iii) you when you use our Service or engage with us to request information about our Service.

By accessing, browsing, subscribing to, or using our Service, you (i) acknowledge that you have read and understood this Privacy Notice and (ii) consent to the collection and use of your information as described in this Privacy Notice, as modified from time to time by us, in our sole and absolute discretion. Effective immediately upon the earlier of your use of our Service or your clicking “accept” or “agree” to this Privacy Notice, you accept and agree to (a) be bound by this Privacy Notice, (b) abide by this Privacy Notice, and (c) comply with all applicable laws and regulations. 

IF YOU DO NOT WISH TO BE BOUND BY THE TERMS OF THIS PRIVACY NOTICE, PLEASE EXIT THE SERVICE NOW AND DO NOT CLICK “ACCEPT” OR “AGREE.”

2.     Modification to this Privacy Notice.

The date this Privacy Notice was last revised is identified at the top of the page. In our sole and absolute discretion, we may, at any time and without notice to you, add to, change, update, or modify this Privacy Notice. If we decide to change our Privacy Notice, we will post a new notice on our Service and change the date at the top of the Privacy Notice. Any change, update or modification will be effective immediately upon posting on our Service and will apply to any information you provide to us on or after that date, including, but not limited to, any Personal Information (as defined below) you share with us.

If we make a material change to our Privacy Notice that affects how we collect or use your Personal Information, we will notify you by email to the email address specified in your account and/or through a notice on our Service home page.  You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you and for periodically vising our Service and this Privacy Notice to check for any changes.

If we add to, change, update, or modify this Privacy Notice for any reason, your continued use of our Service after we make changes is deemed to be acceptance of those changes.

3.     Collection of Information.

a.     Personal Information.

We may collect Personal Information from you when you use or access our Service. “Personal Information” means information that can be used to identify you individually, including, but not limited to, your: (i) complete date of birth, age, sex, and marital status; (ii) full name, mailing address, email address, internet protocol address (“IP Address”), and other information that permits us to contact you either at a physical location, online, or by electronic communication, including telephone number, email, or text messages; and (iii) details on your personality, lifestyle, interests, biography, and other details.

You acknowledge and agree that you share Personal Information with us voluntary, and you determine the extent to which you provide Personal Information.

b.     Registration and Transactional Data.

If you are using or accessing our Service, you may be required to provide Access Credentials (as defined in our Terms of Service) and additional Personal Information to access or use our Service. We may collect and store such access information related to your account.

We may also track and retain the details of all transactions and communications between you and us, target audiences, and other visitors of our Service such as emails, feedback, ratings, sale and purchase of our Service, and any other forms of communications. We may use and display your name when you send an email or other communication through our Service.

c.     Payment Information.

If you use our Service, we may collect information related to your transaction. This information includes your payment information (such as credit or debit card information, checking or ACH information, or other similar financial or banking information), and billing information (such as your address).

To the extent our Service or any portion thereof is made available for any fee or through a Subscription (as defined in our Terms of Service), (i) your access will be granted following payment of the Fees (as defined in our Terms of Service), (ii) you agree to provide accurate and complete billing information, including valid credit card information, your name, mailing address, and email address, and to provide our third party processor with any changes in such information, and (iii) you may be subject to the terms and conditions of a third-party payment processor. Your account and access to our Service may be suspended in the event of non-payment of the Fees.

d.     Contact Us Information and Feedback.

We may collect information that identifies you personally when you submit comments, questions, or suggestions to us or to our Service using our “Contact Us” form, if any, or by email, including any attached files you send to us. Any comments and any emails we receive from you are subject to the terms of this Privacy Notice.

e.     Computer and Device Information.

We may collect the IP Address, domain name, browser type, operating system, device settings, location, web log files, and other code tracking devices from any device you use to access our Service. You can turn-off and adjust settings on your computers and devices that will not allow us to collect information. For example, in many cellular devices, you can turn off location settings by selecting the “Settings” feature, choosing “Privacy” and turning-off “Location.”

f.      Transactions & Communications with Third Parties.

Some content, email, or text message marketing campaigns on our Service may be served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use or access our Service. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We may enable third parties to serve advertisements available through our Service or on third-party websites or other media (e.g., social networking platforms) that enable us and third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors, or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third-party’s specific privacy statement, not this one. We may provide these third-party advertisers with Personal Information.

g.     Protecting Children’s Privacy.

We do not knowingly collect personal contact information from children under the age of 13. We may collect some information (like IP address, mobile device UDID, operating system, etc.) automatically and use technology like cookies to provide functionality and support our operations. We obtain consent where required.

If you suspect we have collected data from children under the age of 13, please email us immediately at info@primer.net.

h.     FERPA

We strive to adhere to the Family Educational Rights & Privacy Acts of 1974 and its implementing regulations (“FERPA”) when providing the Service to educational institutions in the United States that are subject to FERPA. To the extent that we have access to “education records,” as defined by FERPA, you agree that we are deemed and shall function as a “school official” with “legitimate educational interests.” This means that we are providing our Service on behalf of the educational institution, and only as authorized by such institution for legitimate educational purposes. Both parties agree that you have “direct control” over the use of “education records” as these terms are defined under FERPA.

We work with educational institutions to ensure compliance with FERPA and applicable privacy laws. This means that we require educational institutions that use our Service to notify student’s parents and/or guardians of the personally identifiable information that such educational institutions collects and that it will share with us, if any, and to obtain such consent before its students use the Service. One of the most important ways we strive to adhere to FERPA and restrict any disclosure is to encrypt and anonymize any student coursework information that is housed in our database. This information can only be decrypted and reviewed by the educational institution’s approved representatives within the applicable institution’s platform. We also train our employees on privacy and security, and ensure that only those with certain clearance levels have access to sensitive information.

4.     Use and Sharing of Information.

We do not control the third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

a.     Provide our Service.

We use Personal Information to provide you with the features available through our Service, to respond to requests that you initiate through our Service, to process requests and required actions pursuant to our Service that you may initiate through our Service, and to communicate with you. When we have location information, we may use it to tailor our services for you.

b.     Contact By Mobile Phone.

By providing us with your mobile phone number, you hereby expressly consent to receive automated text messages (including SMS and MMS) from us at the mobile phone number you provided. You represent that you are 18 years of age or older and you have the consent of the wireless account holder associated with the mobile phone number you provided.

You are responsible for all charges and fees associated with text messaging imposed by your wireless provider. Message and data rates may apply.

Text messages may be sent using an automatic telephone dialing system or other technology. Your consent to receive automated text messages is not required as a condition of purchasing, or utilizing, any of our Services. If you have opted in (this decision and others detailed further below), we may provide updates via text messages through your wireless provider to the mobile number you provided. Message frequency varies.

c.     Service Providers.

Organizations that perform services for us may have access to your information, including Personal Information, to help carry out the services they are performing for us, such as, but not limited to, creation, maintenance, hosting, and delivery of our Service, conduct marketing (as outlined below), handle payments, conduct research and analytics (as outlined below), or customer service.

We utilize YouTube API Services. You agree to be bound by the YouTube Terms of Service (https://www.youtube.com/t/terms), Privacy Policy (http://www.google.com/policies/privacy), and API Services Terms of Service (https://developers.google.com/youtube/terms/api-services-terms-of-service) when engaging with YouTube content, data, and services through our Service.

We utilize (i) YouTube API Services, (ii) Edlink API, Inc, and (iii) Deepgram. Accordingly, when engaging with our Service, you agree to be bound by (A) YouTube’s Terms of Service (https://www.youtube.com/t/terms), Privacy Policy (http://www.google.com/policies/privacy), and API Services Terms of Service (https://developers.google.com/youtube/terms/api-services-terms-of-service), (B) Deepgram's Terms of Service (https://deepgram.com/terms) and Privacy Policy (https://deepgram.com/privacy), and (C) Edlink’s General Terms of Use (https://ed.link/docs/legal/terms) and Privacy Policy (https://ed.link/docs/legal/privacy).

Our service incorporates the Google Calendar API to enhance your experience. By using features integrated with Google Calendar, you agree to adhere to the Google Terms of Service (https://policies.google.com/terms), the Google Privacy Policy (https://policies.google.com/privacy), and the Google APIs Terms of Service (https://developers.google.com/terms). These terms govern your interaction with Google Calendar data and services accessed through our Service.

Primer's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

d.     Analysis.

We may use Personal Information, non-personal, and aggregate information to evaluate and improve our Service, and for our own internal statistical, design, or operational purposes, or, for example, to estimate our audience size, measure aggregate traffic patterns, and understand demographic and other trends among our users. We may transfer information to certain vendors and service providers who provide technical infrastructure services and other content, analyze our Service, and measure the effectiveness of our Service.

We may outsource all (or some) of the tasks described in this Privacy Notice to third parties on a confidential basis, and would only share your Personal Information as needed for performance of those tasks, and only pursuant to appropriate confidentiality agreements. You agree that we may use your Personal Information, including your email address, to improve our Service, and to customize our Service content and layout. These uses improve our Service and better tailor it to meet your needs, so as to provide you with a smooth, efficient, and safe experience while using our Service.

e.     Marketing Purposes.

If you provide us with feedback, we will collect that information and we may use it in our marketing materials, use it on our Service or to improve or enhance our Service, or disclose it for any purpose we choose. Your Personal Information will not be disclosed or associated with any feedback that we use or disclose unless you have given us permission to use your Personal Information for this purpose. We may use computer and device information for marketing purposes, to examine traffic to our Service and improve our Service to provide you a better experience.

f.      Compliance.

We may use or disclose Personal Information, non-personal information, and aggregate information:

i.      to comply with the law, cooperate and respond to requests and claims or comply with legal process served on us (e.g., a lawful subpoena, warrant, or court order);

ii.     to enforce or apply policies or agreements, including, but not limited to, our Terms of Service;

iii.   to initiate, render, bill, and collect for amounts owed to us;

iv.    to protect and defend us or our user’s rights or property, our Service, our employees, visitors, or the public, (including protecting and defending from fraudulent, abusive, or unlawful use of our Service); and

v.     if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.

g.     Company Sale.

Information collected through our Service is considered our trade secret or proprietary information. As the owner of such information, we may disclose or sell such information as an asset of the company in a business transaction, such as in the sale of our company or a portion of our assets, including if we or one of subsidiaries or our relevant assets are acquired by, sold to, or merged with another entity or as part of a bankruptcy proceeding or a business reorganization.

h.     Legal and Law Enforcement Purpose.

We may disclose your information, including Personal Information, in response to legal process, for example in response to a court order or a subpoena, or in response to a law enforcement agency's request. We also may disclose such information to third parties: (i) in connection with fraud prevention activities, (ii) where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, (iii) in situations that may involve violations of our terms of use or other rules, (iv) to protect our rights and the rights and safety of others, and (v) as otherwise required by law.

5.     You Control Your Information.

You acknowledge and agree that you share your information, including Personal Information, with us voluntarily. Accordingly, you may choose not to provide us with any information, including Personal Information. However, to use our Service, you must provide us with Personal Information, and therefore, if you choose not to give us Personal Information, you may visit our Service, but you will not have access or be able to use the services we provide via our Service.

6.     Account Settings.

When you set up an account with us, you  may elect to receive or stop receiving general and/or informational emails from us or any third-party as described by this Privacy Notice. If you receive email communications from our Service, you may use the unsubscribe link contained in the email. Please note that if you are currently receiving services from us and you have decided to opt-out of such general/informational emails, this will not impact the messages we send to you for purposes of delivering such services.

Please contact us at info@theprimer.ai if you need assistance, or if you have any questions about the different types of emails.

a.     Request Changes.

You may also review and request changes to your Personal Information and obtain removal of content or information you have publicly posted to our Service by sending an email with a detailed description of the specific content or information to info@theprimer.ai. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Please be aware that we cannot always delete records of past interactions and transactions. For example, we are required to retain records relating to record retention laws, for financial reconciliations and reporting, and other legal compliance reasons.

b.     Manage Your Security Settings.

You may manage how your browser handles cookies and related technologies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. You can opt-out of being targeted by certain third-party advertising companies online at http://www.networkadvertising.org/choices/.

You may manage how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative’s (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and your choices regarding having information used by NAI members. The NAI’s main webpage is located at www.networkadvertising.org.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Service. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt-out on the DAA or NAI websites, your opt-out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

7.     Links to Other Websites.

Please be aware that we may provide links to third-party websites as a service to our visitors, and that we are not responsible for the content or information collection practices of those pages. Please note that these websites’ privacy policies may differ from our Privacy Notice. We encourage you to review and understand the privacy practices at third-party websites before providing them with information.

8.     Opt Out.

In the event we contact you by emails or text messages, you may opt out of receiving emails or text messages from us at any time either by texting the word “STOP” to any text message using the mobile device that is receiving the messages, by using the unsubscribe link contained in the email, or by contacting us. If you are unable to resolve this through these means, contact us at info@theprimer.ai. Despite your election to opt-out, if you are still receiving services from us or using our Service, we may send you emails or contact you by other means regarding your account, transactions, and your activities with our Service.

9.     Changes to our Service.

We may change any short code or telephone number we use to operate the texting services at any time and will notify you of these changes. You acknowledge that any messages, including any STOP requests, you send to a short code or telephone number we have changed may not be received and we will not be responsible for honoring requests made in such messages. Please contact us at info@theprimer.ai if you need assistance.

10.  What Else Should You Know About Our Privacy Practices.

a.     AI.

We utilize artificial intelligence (“AI”), including Chat GPT, which is powered through Open AI, to process the information that you provide to us, including your Personal Information. You should look to their terms regarding privacy, available at https://openai.com/policies/privacy-policy. The AI we utilize may process your Personal Information for various purposes, including but not limited to:

i.      Personalization: AI analyzes your Personal Information to provide personalized recommendations, content, and experiences based on your preferences, interests, and usage patterns.

ii.     Analytics and Insights: We use AI to analyze aggregated and anonymized data to gain insights, improve our Service, and understand consumer behavior.

Information provided to you through our Service may be generated by AI, and we cannot guarantee the accuracy, completeness, or usefulness of such information. You rely on the information provided to you through our Service at your own risk and agree that we shall not be liable to you for any such information for any damages arising out of or from your use and/or reliance on such information.

b.      Security.

We follow generally accepted industry standards to protect Personal Information, submitted to us, both during transmission and once we receive it. We encrypt your Personal Information at rest and provide our team members with training and policies regarding data privacy and security. Despite our best efforts, no method of transmission over the Internet, or method of electronic storage, is one hundred percent secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Service.

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

c.     Children.

We will not generally collect information from children under age 18. Our Service are for general audiences and are not designed nor intended to collect Personal Information from children under the age of 18. We require that registrants affirm that they are 18 years or older, prior to creating an account on or using our Service. If we learn that a person under the age of 18 has submitted personally identifiable information to us, we will delete that information from our Service.  If you believe that a person under the age of 18 has directly provided us with their personal information, please contact us immediately at info@theprimer.ai.

d.     California Consumer Privacy Act/California Privacy Rights Act (“CCPA”/”CPRA”), Colorado Privacy Act (“CPA”), Nevada Privacy of Information Collected on the Internet from Consumers Act (“NPICICA”), Virginia Consumer Data Protection Act (“VCDPA”), Connecticut Data Privacy Act (“CTDPA”) Disclosures.

i.     Categories of Personal Information Collected

Under the CCPA, as amended by the CPRA, you have the right to know what personal information we have collected about you, including the categories of Personal Information, the categories of sources from which the personal information is collected, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of Personal Information we have collected about you.

We collect the following categories of information: identifiers (such as your name and email address), Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (such as your name and contact information), internet or other similar network activity, geolocation data, and inferences drawn from the collected Personal Information. This information is collected directly from you when you provide it to us (for example when you submit a form requesting more information) or automatically as you navigate through our Service. We use this information for one or more legitimate business purposes, including to improve our Service, offer information about our Service to you, and allow you to purchase our Service. We disclose the Personal Information to third parties who are providing services to you, including AI. The specific pieces of information we have collected about you vary depending on the ways you use our Service.

We do not sell Personal Information as defined by the CCPA. We share Personal Information, as defined by the CCPA, to our AI. We have not sold any of your Personal Information to third parties in the past 12 months.

ii.     Rights of California, Colorado, Nevada, Virginia, and Connecticut Residents

If you are a resident of California, Colorado, Nevada, Virginia, or Connecticut you have other rights under your respective states’ consumer privacy statutes:

• Right of Access: You can access your collected Personal Information by contacting us at info@theprimer.ai.

• Right to correct, update, or delete: You can correct, update, or request deletion of your Personal Information by contacting us at info@theprimer.ai. We can’t make changes to or delete your information in some situations where it is necessary for us to maintain your information, for example if we need the information to comply with applicable law.

• Right to Request Disclosure of Information Collected: Please contact us at info@theprimer.ai to request further information about the categories of Personal Information we have collected about you, where we collected your Personal Information, and for what purpose we use your Personal Information.

• Right to Disclosure of Information Sold or Shared and Right to Opt-Out of the Sale or Sharing of your Personal Information: You have the right to know what information of yours we have sold, the categories of Personal Information shared, and you have the right to opt-out of any sale or sharing of your information. Opt-out is only available by not utilizing our Service. If you have any questions about these rights, please contact us at info@theprimer.ai.

• Rights to Disclosure of Sensitive Information (California): If you are a resident of California, you have a right to know how we collect, process, and disclose “Sensitive Personal Information” (SPI). SPI includes highly sensitive data such as: social security number; driver’s license; passport number; financial account information, and log-in credentials; precise geolocation data; genetic data; and ethnic origin. We collect and process the following types of SPI: financial account information and log-in credentials, and precise geolocation data through IP Address. We use the SPI to provide our Service to and process payments from those who use and access the Service. If you have any questions about the disclosure of SPI, please contact us at info@theprimer.ai.

• Right to Retention Details (California): If you are a resident of California, you have a right to know the length of time we to retain each category of Personal Information or if that is not feasible, the criteria we will use to determine that retention period. If you have any questions about this right or our data retention protocol, please contact us at info@theprimer.ai.

• Right to Disclosure of Targeted Advertising and Right to Opt-Out (Colorado, Virginia, and Connecticut): If you are a resident of Colorado or Virginia, you have the right to know what information of yours we have processed for targeted advertising. We do not engage in targeted advertising. If you have any questions about these rights, please contact us at info@theprimer.ai.

• Right to Disclosure of Profiling (Colorado, Virginia, and Connecticut): If you are a resident of Colorado or Virginia, you have the right to know what information of yours we have processed for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. If you have any questions about these rights or wish to opt-out of any processing of your Personal Information as it relates to profiling, please contact us at info@theprimer.ai.

• Right to Non-Discrimination: We do not and will not discriminate against you if you exercise your rights under the CCPA, CPA, NPICICA, VCDPA, and CTDPA.

When you contact us regarding any of your rights under the CCPA, CPRA, CPA, NPICICA, VCDPA, and CTDPA, we will verify your identity before we provide any information. If you have any questions or comments about your rights under the CCPA, CPRA, CPA, NPICICA, VCDPA, and CTDPA, please contact us at info@primer.net.

11.  Contact Us.

If you have any questions about this Privacy Notice or our use of your information, you can email us at info@primer.net.