Privacy Policy

Last updated: December __, 2025

At Primer, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of Primer’s Services is subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use. 

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Table of Contents

• Personal Data
  
  • Categories of Personal Data We Collect
  • Categories of Sources of Personal Data
  • Our Commercial or Business Purposes for Collecting Personal Data
• How We Share Your Personal Data
• Tracking Tools, Advertising and Opt-Out
• Data Security and Retention
• Personal Data of Children
• Other State Law Privacy Rights
• Changes to this Privacy Policy
• Contact Information

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What this policy covers

This Privacy Policy covers how we treat Personal Data. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “personal data” under applicable data privacy laws, rules or regulations. 

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

Primer Technologies, Inc. 

225 S Lake Ave Suite M260 Pasadena, CA 91101

Email: privacy@primer.ai

(415) 629-5013

We will not disclose Personal Data to third parties for their direct marketing purposes without your consent.  If, after providing consent, you want to opt out of having your personal information disclosed to third parties for their direct marketing purposes, please contact us as described above.  Please be sure to include your full name, the e-mail address and your mailing address and specifically state that you do not want your personal information shared with third parties for their direct marketing purposes. 

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Personal Data

We collect Personal Data about you from the following sources:

• From You:
  
  • When you provide such information directly to us.
    
    • When you use our interactive tools and Services.
    • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
    • When you send us an email or otherwise contact us.
• Automatic collection:
  
  • Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
  • If you use a location-enabled browser, we may receive information about your location.
  • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device.
  • We may collect information about the computer or device you use to access our Service, including the hardware model, operating system and version, MAC address, unique device identifier (“UDID”), phone number, International Mobile Equipment Identity (“IMEI”) and mobile network information.
  • We may also automatically collect and use the data contained in log files, which may include your IP address, your ISP, the Web browser you used to visit the Services, the time you visited the Services, which pages you visited within the Services, and other usage data.

• From Third Party Sources:
  
  • Vendors
    
    • We may receive Personal Data from third party data aggregators.
  • Other Third Parties
    
    • We may obtain Personal Data that is available on social media sites and other publicly accessible sources. 

Our Commercial or Business Purposes for Collecting Personal Data

• Providing, Customizing and Improving our products and services
  
  • Providing you with the products, services or information you request.
  • Meeting or fulfilling the reason you provided the information to us.
  • Providing support and assistance.
  • Improving our products and services, including testing, research, internal analytics and product development.
  • Personalizing the Services, website content and communications based on your preferences.
  • Fraud protection, security and debugging.

• Marketing the Services
  
  • Marketing and selling the Services.
  • Showing you advertisements, including interest-based or online behavioral advertising.

• Corresponding with You
  
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Primer or the Services.
  • Sending emails and other communications according to your preferences.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

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How We Share Your Personal Data

Service Providers. We may sometimes use other businesses to perform certain services for us, e.g., to provide certain services on our behalf, such as analytics, payment processing, hosting and maintenance, data storage and management services (“Service Providers”).  We provide our Service Providers with the information reasonably necessary for them to perform the services on our behalf. They may include:

• Hosting, technology and communication providers.
• Security and fraud prevention consultants.
• Support and customer service vendors.
• Product fulfillment and delivery providers.

• Companies that track how users found or were referred to the Services.
• Companies that track how users interact with the Services.

• Businesses that you have a relationship with.
• Companies that we partner with to offer joint promotional offers or opportunities.

Each Service Provider must agree (a) to implement and maintain reasonable security procedures and practices appropriate to the nature of the information involved in order to protect your information from unauthorized access, destruction, use, modification or disclosure and (b) not to retain, use, or disclose the information for any purpose other than for the specific purpose of performing the services for us, or as otherwise permitted by law.

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We use Google Analytics, a web analytics service of Google, Inc. (“Google”), to collect and summarize data regarding usage of the Service.  Google uses cookies to obtain this information.  We use the information obtained from Google Analytics to improve the Service.   To learn more about Google Analytics and Google’s privacy practices, please visit: www.google.com/policies/privacy/partners/. For information on how to opt out of data collection by Google Analytics visit:   https://tools.google.com/dlpage/gaoptout?hl=en.

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Parties You Authorize, Access or Authenticate

• Third parties you access through the services.
• Social media services.
• Other users.

Primer Customers

• These are parties that use our products and services. 

Meeting Legal Requirements and Enforcing Legal Terms

• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property or safety of you, Primer or another party.
• Enforcing any agreements with you.
• Resolving disputes.

Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Aggregated Data. 

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

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Tracking Tools, Advertising And Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

Types of Cookies

We use the following types of Cookies:

• Necessary Cookies. Necessary Cookies are required to enable core functionality and for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Analytical Cookies.  Analytical Cookies allow us to understand how visitors use our Services and helps us optimise and improve the experience we provide. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. 
• Marketing Cookies. Marketing Cookies help measure the performance of advertising campaigns in order to help improve campaigns and, for our purposes, the Services’ content for those who engage with our advertising. Marketing Cookies may be placed by our advertising partners who use those Cookies to build a profile of your interest in order to show you relevant adverts on other sites. See Information about Interest-Based Advertisements section below for further information. If you do not allow for these Cookies, you will experience less targeted marketing. 

How to change your Cookies preferences

You can decide whether or not to accept Cookies through our Cookies Banner. You can also change your preferences at any time through our Cookies Settings, by clicking "Cookie Control" found in the footer of the website.

You can also delete all Cookies placed on your device by using your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

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Data Security And Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

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Personal Data Of Children

We do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at privacy@primer.ai.

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European Union And United Kingdom Data Subject Rights

EU AND UK RESIDENTS

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

Under the GDPR, you have the right to request a copy of your personal data stored at Primer (Article 15 GDPR). You also have the right to request corrections (Article 16 GDPR), deletion (Article 17 GDPR) or restriction (Article 18 GDPR) of your personal data stored at Primer.

To meet these requests, we will ask you to provide a contact email address. This allows us to send you the information you requested, or to confirm completion of any requests to correct, delete or restrict data (Article 19 GDPR).

If you are a European resident and are dissatisfied with the handling of your personal data by Primer, you have the right to object to processing of your personal data at any time (Article 21 GDPR). You may send your concerns or objections about the processing of your personal data to privacy@primer.ai.

If you are a resident of the United Kingdom, Primer will comply with the UK Data Protection Act of 2018, and you may exercise your rights thereunder as described above for residents of the EU.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Primer and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Primer in the U.S. and will be hosted on U.S. servers, and you authorize Primer to transfer, store and process your information to and in the U.S., and possibly other countries.

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State Law Privacy Rights

These additional notices are provided under the California Consumer Privacy Act (“CCPA”) and apply to California residents in addition to the other provisions of this Privacy Policy. Other states have similar requirements, and we will honor those requirements where required to do so.

If you are a California resident, you have the following rights:

• You may request, no more than two times each year, that we disclose to you the following for the 12-month period preceding our receipt of your request:
  
  • The categories of personal information we have collected about you; 
  • The categories of sources from which the personal information is collected;
  • The business or commercial purpose for collecting your personal information;
  • The categories of third parties with whom we share personal information; and
  • The specific pieces of personal information we have collected about you.
• You may request that we delete any personal information that we have collected from or about you.  Except as provided under the CCPA, we will delete such information in response to your request.

To make a request, you may contact us via mail, email, or phone:

Primer Technologies, Inc. 

225 S Lake Ave Suite M260 Pasadena, CA 91101

Email: privacy@primer.ai

800-XXX-XXX

In order to respond to your requests, we may need to verify your identity. We will not discriminate against you in the provision of the Services in response to your exercise of these privacy rights. We will respond to your request within 45 days of receipt of your request, after verification, unless we need additional time, in which case we will let you know and may extend the period an additional 45 days as permitted by the CCPA.

We collect information in the following categories for the following purposes:

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Changes To This Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Primer website, by sending you an email and/or by some other means. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

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