Introduction

Visarity Technologies GmbH (“Primo,” “we,” “us,” or “our”) respects your privacy, and we take our responsibility of caring for it seriously. This Privacy Policy helps you make informed decisions about your relationship with us, so we encourage you to read it carefully. The information we collect depends on what products or services you use and how you use them. This Privacy Policy applies to visitors of our website located at www.primo.design (the “Website”), who view only publicly-available content (the “Visitors”); users of Primo’s advertising and creative management platform and related documentation (“Platform Users”) provided through our web sites and applications (the “Primo Services”), and end users of digital advertisements created and/or trafficked through the Primo Services (the “End Users”). By using or accessing our Website or using the Primo Services (as defined below), you agree to our privacy practices outlined herein.

We designed this Privacy Policy with these key principles in mind:

1. To explain important disclosures about the way we use information that you share with us as Visitors, Platform Users, and End Users.
2. To ensure that you understand what information we collect with your permission, and what we do and, most importantly, do not do with that information.
3. To hold us accountable for protecting your rights and your privacy under this policy.

End Users / Ad Viewers what do we collect and what not:

This is what we collect:

1. Hostname
2. User-Agent of the Browser
3. All kind of interaction inside the Ad canvas: hover, clicks etc.
4. Overal interaction time
5. Location: country and city - derrived from IP address
6. Video Completion Rate

1. IP address
2. Device Id
3. GPS Coordinates
4. Advertiser Id

1. live.visarity.com - Ad content delivery
2. ibv.visarity.com - Ad content delivery. Specifically for In-Banner-Video formats
3. io/io2.visarity.com - Used for reporting

IAB Transparency and Consent Framework

Highlights of what you’re consenting to (not applicable for End Users):

1. The use of cookies and other tracking technologies.
2. The transfer of your information outside of the country where you live.
3. collection, use, processing and retention of your information by the entities described in this Privacy Policy, including Primo, as Data Controller (where applicable), as indicated at the bottom of this document.

For purposes of this policy:

“Personal Data” for non-residents of the European Economic Area means any information that can be used to identify, contact, or precisely locate a person, including name, email, address, and telephone number.
“Personal Data” for residents of the European Economic Area means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. This includes IP address.
“Non-Personal Data” means information not included in the definition of Personal Data, such as pages or ads visited, time spent on pages, browser and device type, and referring and exit pages. For non-residents of the European Economic Area, IP address and advertising IDs (IDFA/AAID) are Non-Personal Data.

1. Information We Collect/Receive and How We Use that Information

In general, there are three categories of information we collect: (1) information that we can use to provide additional features and improved experiences if you choose to share that information; (2) information that we must have for you to use the Primo Services; and (3) information collected from your interaction with the Primo Services as an End User of a digital advertisement (hereinafter referred to as “ad” or “ads”). When you provide Personal Data directly to us, this information is used by Primo solely for the purposes identified at the point you provide it. Information we collect may be transferred, stored, used, and/or processed as follows:
I. Contact Information. When you contact us through the “Contact Us” page on the Website or become a Platform User of the Primo Services, you will be asked to provide us with certain Personal Data about yourself which may include your name, email address, job title, name of your organization, mailing address, or telephone number. Consistent with any permissions you may have communicated to us, we may use this information to directly communicate with you for marketing and promotional purposes via emails, notifications, or other messages, and to communicate with you for research purposes including via emails, notifications, or other messages. Platform Users may also receive communications concerning Primo product updates, training sessions, or events or webinars. If you want to stop receiving such materials from Primo, you can change your profile settings within the Primo Services or follow the unsubscribe instructions at the bottom of each email.
II. Billing Information. In certain circumstances, to use the Primo Services, you may be required to provide additional information which may include a credit card number, expiration date, billing zip code, activation code, and similar information (“Billing Information”). Primo uses this information to process payments. In certain circumstances, Primo uses third-party service providers to manage credit card processing. These service providers are not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing.
III. User Activity Data (Website, Platform). In an ongoing effort to improve the Website and the Primo Services, we automatically collect certain information when Visitors visit the Website and when Platform Users use the Primo Services (collectively, the “User Activity Data”). This information may include IP address, browser and device type and language, referring and exit pages and URLs, date and time, amount of time spend on pages, what sections of the Website Visitors visit, and other, similar aggregate user data concerning your use of the Website and the Primo Services. We may use this data to manage and improve your experience using the Website and the Primo Services. In some areas of the world, certain User Activity Data may be Personal Data. Where this is the case, we comply with applicable laws regarding our use and processing of Personal Data.
IV. Ad Interaction Data (End Users). When End Users interact with ads generated using the Primo Services, we may collect information on behalf of Primo’s customers which may be the advertiser, publisher, advertising agency, and/or their agents. Data collected through interaction with the Primo Services may include time spent viewing an ad, page views, video views, number of ads clicked and other information about your interaction with the ads (“Ad Interaction Data”). We are no storing the IP address, device ID, GPS coordinates or any Advertising ID at all. With respect to End User data, Primo is acting as a “Data Processor” on behalf of our customers, which may include the advertiser, publisher, and/or their agents who are the Data Controller of your data who may use this information for their lawful advertising purposes to provide you with a more tailored online advertising experience. We may also use the information internally to improve the functionality of the Primo Services.
V. Cookies and similar technologies. A cookie is a small text file that is placed on your computer or device when you visit certain websites. When we refer to “cookies” we include other technologies with similar purposes. In resepect to "End Users" Primos customers may use cookies to serve appropriate ads to you and to help track results or measure effectiveness of those ads. These third-parties may combine information collected in the context of delivering an ad to you with other information they have independently collected over time across different websites, including syncing or connecting behavior across different websites, mobile apps or devices. These third-parties collect and use information under their own privacy policies. As far as "End Users" are concerned Primo is not reading nor writing any cookies at all.

2. Sharing and Disclosure of your Personal Data

We may share your information at your direction or as described below at the time of sharing.
I. Customers. We share Ad Interaction Data with our customers who may use this information for their lawful advertising purposes to provide you with a more personalized online advertising experience.
II. Third-Party Service Providers. Primo may share your information with Third-Party Service Providers that support us in delivering the Primo Services to our customers. We may also share your information with companies that help us operate and market the Primo Services, such as to bill our customers, analyze our Website Visitors, provide customer and technical support, database, analytics, and hosting services, and other operational support. We ensure that such service providers are contractually required to protect your Personal Data at all times.
III. Safety and Compliance with the Law. Primo may disclose your information to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required to do so by law.
IV. Business Transfers. If Primo undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer, or share some or all our assets, including your Personal Data. In this event, we will notify you before your Personal Data is transferred and becomes subject to a different privacy policy.
V. Other. Primo may also may disclose your information under circumstances not mentioned here with prior consent of the person or third-party that submitted the information to us.