Visarity Technologies GmbH
Visarity Technologies GmbH (“Primo,” “we,” “us,” or “our”) respects your privacy, and we take our responsibility of caring
so we encourage you to read it carefully. The information we collect depends on what products or services
(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.
This is what we collect:
“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.
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.
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.
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.
I. Cookies. Usually, you can stop your browser from accepting cookies in general or from accepting
cookies from a particular website. All modern browsers allow you to change your cookie settings. You can
typically find these settings in the “options” or “preferences” section of your browser. Please visit our
Website. In some areas of the world, cookies and other identifiers may be Personal Data. Where this is the
case, we comply with applicable laws regarding our use and processing of Personal Data. Except in the case
of residents of the European Economic Area, by accessing and using our Website, you consent to the use of
the cookies and other technologies described above. Residents of the European Economic Area will be able
to accept or reject cookies each time they access the site.
II. Marketing Communications. You may choose to sign-up for marketing or other communications from Primo on the Website. Should you choose to unsubscribe from any lists for which you registered, you may do so by following the instructions on how to unsubscribe provided in all Primo communications or by emailing firstname.lastname@example.org.
We are committed to GDPR compliance when enforcement begins on May 25, 2018. If you are a resident of the European Economic
Area, you have the following rights with respect to data for which Primo is the Data Controller:
Primo uses reasonable technical and organizational security measures to safeguard Personal Data that is submitted to us voluntarily
through our Website or the Primo Services or collected through interactions with the Primo Services. However,
no security measures are perfect or impenetrable. We cannot control the actions of third-parties with whom
you elect to share your Personal Data and we cannot accept liability for for improper access to that data.
We cannot guarantee that only authorized persons will view your Personal Data. We cannot ensure that information
you share on our Website and/or through the Primo Services will not become publicly available.
Our Website may use social media features, such as “Like” and “Share” buttons, which are operated by third parties such as
Facebook, Instagram, LinkedIn, Twitter, etc. These features may collect your IP address, which page you are
visiting on our Website, and may set a cookie or employ similar technologies to enable the feature to function
properly. If you are not logged into your account with the third-party, then the third-party might not know
your identity. If you are logged into your account with the third-party, then the third-party might be able
to link information about your visit to our Website to your account with them. Similarly, your interactions
with these features may be recorded by the third-party. Your interactions with these features are governed
the third-party used such data.
The Website is not intended for children under 13 years of age. You must be at least 13 years old to use the Website and/or
the Primo Services. We do not knowingly collect Personal Data from any child under 13 years of age. If you
are under 13 years of age, do not use the Primo Services and do not provide any Personal Data to us. If you
are a parent of a child under 13 years of age and become aware that your child has provided Personal Data
to Primo, please contact us at
email@example.com and you may request access, correction, deletion, and/or objection rights.
Our Website and the ads we serve on behalf of customers may, from time to time, contain links to external websites. Primo
encourages you to review the privacy and security policies of any externally linked websites whose information
practices may be different from ours. Primo assumes no responsibility or liability for the information, collection,
and disclosure practices of any external websites that a Visitor can access through the Website or the Primo
Services. Please check the privacy policies of these external websites before you submit any Personal Data
or other information to them.
processing, retention and/or disclosure of your Personal Data, you may contact us as indicated below:
Visarity Technologies GmbH Lerchenstraße 28a, Hamburg, Germany
A note to data subjects residing in the European Economic Area: If you are not satisfied with our response, or believe we are processing your personal data not in accordance with the law, data subjects covered under the GDPR framework have the right to lodge a complaint with a supervisory authority in the Member State of their habitual residence, place of work, or place of the alleged infringement.
via a notice on our home page (www.primo.design). In some cases, we will notify you in advance, and your
you are updated as to any changes.