Privacy Policy

Primo Apps ("us", "we", "our" or “the company”) operates the Primo mobile application (the "Service" or the “Mobile App”).

This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use the Mobile App.

Your information will not be used or shared with anyone else except as described in this Privacy Policy.

We use your Personal Information for providing and improving the Service. By using the Mobile App, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy page, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions page.

Information Collection and Use

While using our Mobile App, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, your email address, name, phone number, postal address, date of birth, or other information ("Personal Information").

We collect this information for the purpose of providing the proper Service, identifying and communicating with you timely, responding to your requests/inquiries in a good manner, and improving our services frequently.

Log Data

We collect information that your browser sends whenever you visit our Service ("Log Data"). This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type, browser version, the pages of the Mobile App that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this type of information in order to increase our Service's functionality. The third party service providers have their own privacy policies addressing how they use such information.

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, your location information and other statistics.

Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your device. We use cookies to collect information in order to improve our services for you.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie.

However, if you do not accept cookies, you may not be able to use some features of our Service and we recommend that you leave them turned on.

Remarketing

We use remarketing services to advertise on third party web sites to you after you visited our Service. We, and our third party vendors, use cookies to inform, optimize and serve ads based on your past visits to our Service.

Google AdWords remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: https://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to stop the data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://www.google.com/intl/en/policies/privacy/

Partners / Advertisers

Sometimes our partners may let us collect information when you use their services, or may share with us the information they collect. For example, online advertisers typically share information with the websites or apps where they run ads to measure and/or improve these ads. We also receive this information, which may include information like whether clicks on ads led to purchases or a list of criteria to use in targeting ads.

Communications and Marketing

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Information Share and Disclosure

We may disclose personally identifiable information in response to legal process, for example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, to verify or enforce compliance with the policies governing our service and applicable laws or as otherwise required or permitted by law or consistent with legal requirements.

In addition, we may transfer personally identifiable information about you if we are acquired by, sold to, merged with or otherwise transferred to another entity.

Security

The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure.

However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you.

International Transfer

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the information, including Personal Information, to United Kingdom and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy Policy

Only persons age 13 or older have permission to access our Service. Our Service does not address anyone under the age of 13 ("Children").

We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you learn that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a children under age 13 without verification of parental consent, we take steps to remove that information from our servers.

Non-Private or Non-Personal Information

We may share or disclose your non-private, aggregated or otherwise non-personal information, such as your public user profile information, public posts, the people you follow or that follow you, or the number of users who clicked on a particular link (even if only one did).

Changes to This Privacy Policy

This Privacy Policy is effective as of August 16, 2021 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page. We encourage you to periodically check back and review this statement so that you always will know what information we collect, how we use it, and with whom we share it.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

Contact Us

If you have any questions about this Privacy Policy, please contact us.

The way we collect and share your information is equally important. Our visitors expect us to manage their information privately and securely. If we don’t, they’ll lose their trust in us.

This policy tells you how we collect and process your personal information. Please take a few minutes to read it.

What does this policy cover?

This privacy policy relates to visitors who visit our site.

What is personal information?

When we talk about personal information we mean information about an individual that can identify them, like their name, address, e-mail address, telephone number and financial details. It can relate to customers, employees, shareholders, business contacts and suppliers. Any reference to “information” or “data” in this policy is a reference to personal information about a living individual.

What information do we hold?

We may collect and process the following personal information about you:

Where do we get our information from?

Information you give us directly (when you fill in forms or contact us by phone, e-mail etc.).

Information we collect about you or receive from other sources. This could be information you provide to us electronically (through our website or an online portal, for example), information we get from your online browsing activity, information from a third party or from publicly available sources such as social media platforms or the electoral register. For more information on how we use cookies, please refer to our cookie policy.

How do we use your information?

We use personal information that we hold about you:

• To carry out our responsibilities resulting from any agreements you’ve entered into with us or our business partners and to provide you with the information, products and services that you’ve asked from us.
• To provide you with marketing information about services and products we offer which may be of interest to you. Based on your marketing preferences, we may deliver this information by post, telephone, e-mail.
• We may also send marketing to you using our “legitimate interests”, please see below for further information.
• To tell you about changes to our services and products.
• For carrying out market research, statistical analysis and customer profiling to help us to improve our processes, products and services and generate new business (e.g. to understand digital behaviours, identify financial attitudes and develop more engaging communications).
• To run our business in an efficient and proper way. This includes testing our systems, managing our financial position, business capability, planning, communications, corporate governance, and audit.
• For any other purpose that we’ve agreed with you from time to time.

When you apply for a product or to receive a service from us, the application form you fill out or the resulting contract may contain additional conditions relating to the way we use and process your personal information. These will apply in addition to the above uses.

In some cases, we may use systems to make automated decisions (including profiling) based on the personal information we have, or collect from others. These may include:

• Personalising the content and design of communications and online services
• Determining when to provide tailored servicing communications (e.g. changes in your personal circumstances or lifestyle), and the appropriate channel(s) to use.

Using your information in accordance with data protection laws

Data protection laws require us to meet certain conditions before we’re allowed to use your personal information in the way we describe in this privacy policy. We take these responsibilities extremely seriously. To use your personal information, we’ll rely on the following conditions, depending on the activities we’re carrying out:

• Providing our services to you: We’ll process your personal information to carry out our responsibilities resulting from any agreements you’ve entered into with our business partners on your behalf and to provide you with the information, products and services you’ve asked from us, which may include online services.
• Complying with applicable laws: We may process your personal information to comply with any legal obligation we’re subject to.
• Legitimate interests: To use your personal data for any other purpose described in this privacy policy, we’ll rely on a condition known as "legitimate interests". It’s in our legitimate interests to collect your personal data as it provides us with the information that we need to provide our services to you more effectively.

We may use your information to:

• Carry out market research and product development, which can include creating customer demographics and/or profiling. We may sometimes work with carefully selected business partners to do this.
• Develop and test the effectiveness of marketing activities.
• Develop, test and manage our brands, products and services.
• Study and also manage how our customers use products and services from our business partners.

This requires us to carry out an assessment of our interests in using your personal data against the interests you have as a citizen and the rights you have under data protection laws.

The outcome of this assessment will determine whether we can use your personal data in the ways described in this privacy policy (except in relation to marketing, where we’ll always rely on your consent). We’ll always act reasonably and give full and proper consideration to your interests in carrying out this assessment.

• Consent: We may provide you with marketing information about our services or products where you’ve provided your consent for us to do so. You may opt out of marketing at any time by e-mailing or telephoning your customer servicing team. Alternatively, you can also use the Contact Us section of our website.

Please be aware that the personal information you provide to us, and which we collect about you, is required for us to be able to provide our services to you and without it we may not be able to do so.

How long do we keep your information for?

We’ll keep your personal information in accordance with our internal retention policies. We’ll determine the length of time we keep it for based on the minimum retention periods required by law or regulation. We’ll only keep your personal information after this period if there’s a legitimate and provable business reason to do so.

Who do we share your personal information with?

We’ll only disclose your information to:

• Third-party suppliers, contractors and service providers for the purposes listed under “How do we use your information” above.
• Selected third parties, so that they can contact you with details of the services that they provide, where you have expressly opted-in or consented to the disclosure of your personal data for these purposes.
• Our regulators, government

Additionally, we may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we’ll disclose your personal data to the prospective seller or buyer of such business or assets.
• If we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
• In order to enforce or apply the terms of any contract with you.
• If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.

If you’ve been introduced to us by another company we may share your information with them to enable them to:

• Carry out market research, statistical analysis and customer profiling.
• Where you have consented, send you marketing information by e-mail about their products and those of carefully selected third parties.

Transferring your data outside the EU

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") to third- party suppliers, delegates or agents. We’ll take all reasonably necessary steps to make sure that your data is treated securely and in accordance with this privacy policy.

We’ll only transfer your data to a recipient outside the EEA where we’re permitted to do so by law (for instance, (A) where the transfer is based on standard data protection clauses adopted or approved by the European Commission, (B) where the transfer is to a territory that is deemed adequate by the European Commission, or (C) where the recipient is subject to an approved certification mechanism and the personal information is subject to appropriate safeguards, etc.).

Unfortunately, sending information via e-mail is not completely secure; anything you send is done so at your own risk. Once received, we will secure your information in accordance with our security procedures and controls.

Your Rights

You have rights under data protection law that relate to the way we process your personal data. More information on these rights can be found on the Information Commissioner’s website. If you wish to exercise any of these rights, please get in touch with your customer services team. Alternatively, you can also use the Contact Us section of our website.

Your Rights:

1. The right to access the personal data that we hold about you
2. The right to make us correct any inaccurate personal data we hold about you
3. The right to make us erase any personal data we hold about you. This right will only apply where for example:
   • We no longer need to use the personal data to achieve the purpose we collected it for
   • You withdraw your consent if we're using your personal data based on that consent
   Where you object to the way we use your data, and there is no overriding legitimate interest
4. The right to restrict our processing of the personal data we hold about you. This right will only apply where for example:
   • You dispute the accuracy of the personal data we hold
   • You would like your data erased, but we require to hold it in order to stop its processing
   • You have the right to require us to erase the personal data but would prefer that our processing is restricted instead
   Where we no longer need to use the personal data to achieve the purpose we collected it for, but you need the data for legal claims.
5. The right to object to our processing of personal data we hold about you (including for the purposes of sending marketing materials to you)
6. The right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to make us transfer this personal data to another organisation.
7. The right to withdraw your consent, where we're relying on it to use your personal data (for example, to provide you with marketing information about our services or products).

Contacts and complaints

If you have any questions about this privacy policy or wish to exercise any of your rights, including changing your marketing preferences, please get in touch with the customer services team via email at [email protected]. Alternatively, you can also use the Contact Us section of our website.

If you have any concerns about the way we process your personal data, or are not happy with the way we’ve handled a request by you in relation to your rights, you also have the right to make a complaint to the Information Commissioner's Office. Their address is:

First Contact Team
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF

Data Protection Officer

Primogif.com has appointed a Data Protection Officer to provide independent expert advice and monitor compliance with data protection laws:
Name: Mr. Husam Alkarnaz
E-mail address: [email protected]
Address: 3 Axis Court, Mallard Way, Swansea, SA7 0AJ