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Privacy Statement

Effective Date: 6/27/19

We are committed to protecting your privacy when you interact with us. The purpose of this Privacy Statement (“Privacy Statement”) is to set forth the privacy practices of Primatech Inc. and its affiliated entities (“Primatech”, “Primacert”) (individually and collectively “Primatech”, “us”, or “we”) with respect to Personal Data which means any information relating to an identified or identifiable natural person) that we collect.


This Privacy Statement applies to Personal Data we obtain from and about our clients and customers and it applies to all methods of data handling (including online, offline, and through our website). If we obtain Personal Data about you from a client or customer, we will process such Personal Data in accordance with our agreement with that client or customer. This Privacy Statement does not apply to Primatech employees, but does apply to information collected about job applicants.

Please read the information below to learn about the Personal Data collected about you and how it is processed. Please note that there is a separate Terms and Conditions found in the “Terms and Conditions” hyperlink located at the bottom of our website.

If we make any changes to this Privacy Statement we will notify you by posting an updated Privacy Statement on our website prior to the change becoming effective, which will include the date last updated at the top of the page. The most current version of the Privacy Statement can always be reviewed by clicking on the “Privacy Statement” link located at the bottom of our website.

If you are visiting our website from the European Union (“EU”), or where applicable EU data protection laws apply, please see the section below titled, “Your EU and Swiss Privacy Rights”, for additional information. 

What Information Do We Collect?

The types of Personal Data Primatech collects include:

· Contact information (such as contact name, company name, email address, job title, mailing address, phone numbers, gender, product and service interests, source of information, events attended, correspondence and notes related to our business relationship with the customer),
· Payment information (including credit card information, billing address, and bank account information),
· Purchase or product/service use history,
· Account log-in credentials,
· Résumé and applicant information for those applying for a job, and
· Data gathered by technology when you visit our website or when you evaluate or purchase our software.

How Do We Process Personal Data?

We process your Personal Data for Primatech business purposes, including the provision of services, support related to the services provided, and internal operations. This includes implementing or developing software; providing consulting, training, certification, or technology services; and intra-company communications.

Specifically, we process your Personal Data to:

· Provide our products or services or process orders – this is necessary for the performance of a contract,
· Send administrative notices about important changes in our contractual relationship – this is necessary for the performance of a contract with you or for our legitimate interests to do so,
· Resolve disputes and to enforce our agreements, and to protect the rights, property and safety of Primatech and others, including enforcing our website Terms of Use and verifying that license restrictions are followed by validating use by device – this is necessary to defend our legitimate interests and claims,
· Provide a more efficient and customized educational and shopping experience; provide customized marketing and promotional services; provide information about our products, services, special offers and upcoming events; statistically analyze website use (for more information in this respect, see our separate Cookie Statement); analyze and improve our product and service offerings; and enhance our website content, layout, and services – this is necessary for our legitimate interests as set out herein or based on your consent (in which case we would ask you separately to provide your consent to a particular processing activity), and
· Consider résumés and applications received by applicants for jobs with Primatech entities, including all elements of the procedure leading up to making a decision whether to offer the applicant a position, subject to any appropriate background checks – this is necessary for our legitimate interests, and, if your application is successful, to enter into and/or perform the employment contract. Some job applicant data processing may also be necessary to comply with legal obligations.

With Whom Do We Share Personal Data?

Within the Primatech group of companies: Your Personal Data may be shared with other Primatech companies (i.e., intra-group) for all the purposes described above. We may also provide some of our services through contractual arrangements with other Primatech companies that process the Personal Data on our behalf, in particular for IT support, hosting and maintenance services, and mailing or delivery/transport services.

With third-party service providers: We need to share your Personal Data with other third parties in order to provide our products or services and for our internal business purposes. In particular, we must release your credit card information to the card-issuing bank or a payment provider to confirm payment for products and services you purchase from us. We also share your Personal Data with accounting and consulting firms and external counsel. We may share Personal Data with select third parties, such as our advertisers, for purposes of serving you with customized promotions. If you would like to learn more about the sharing of Personal Data for purposes of providing customized advertisements or promotions, please visit http://www.aboutads.info/consumers/.

Law enforcement or other legal reasons: Occasionally, we may be required by law enforcement or other public authorities, as well as judicial authorities, courts or tribunals, to share Personal Data with them or other parties. We will disclose Personal Data upon receipt of a court order, subpoena, warrant, or other legal process to the extent necessary to meet legal, national security, public interest, or law enforcement obligations, or defend our interests in legal, administrative or other proceedings, which may require us to share Personal Data with other parties to the proceedings and their external counsel. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

Business transactions or legal restructuring: If we or some or all of our assets are acquired by another company, including through a sale in connection with bankruptcy, we will share the information that we hold with that company. We may also buy or sell all or part of our business or the business of a third party. All or part of your Personal Data may be transferred to a new business or owner as a result of such transactions, in accordance with applicable laws.

We do not sell your Personal Data to third parties or otherwise disclose your Personal Data to third parties for the third parties’ direct marketing purposes. However, we may use or share your information with third parties in an anonymized or aggregate manner for any purpose.

Individual Rights of Access to Personal Data

Upon request, Primatech will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Data.

Primatech takes steps to make sure that the Personal Data it uses is correct. Subject to certain legally permissible exceptions, we will allow individuals reasonable access to Personal Data about themselves during normal working hours and upon reasonable request, and they will be allowed to update, delete and/or correct any inaccurate information by emailing our Customer Support at info@primatech.com. We will respond to your request to access Personal Data within 30 days.
Security of Personal Data

Primatech will take reasonable precautions to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, no method of transmission over the Internet or method of electronic storage is 100% secure; therefore, we cannot guarantee its absolute security.
Retention of Data

We will keep your Personal Data as reasonably necessary to fulfill the purposes for which Personal Data is collected as stated herein; for as long as is necessary for the performance of the contract between you and us, if any; and to comply with legal and statutory obligations, such as tax, trade and corporate laws. When we no longer need your Personal Data for our purposes, we will destroy, delete, or erase that Personal Data, or convert it into an anonymous form.

Children’s Privacy

We do not use Primatech’s website to knowingly collect Personal Data from children under the age of thirteen (13), nor is Primatech’s website designed for or directed at children. By using Primatech’s website, you represent that you are age thirteen (13) or over. If you are a child under thirteen (13) years of age, you are not permitted to use Primatech’s website and should not send any Personal Data about yourself to us through Primatech’s website. If you believe that a child may have provided his or her Personal Data to us, please contact us using the contact information at the end of this Privacy Statement. In the event that we become aware that we have collected Personal Data from a child under the age of thirteen (13), we will dispose of that Personal Data immediately.
Your Choices

You may sign-up/opt-in to receive marketing campaign emails, newsletters, or other communications from us.  If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in the communications, by emailing back “unsubscribe”, or by contacting us at info@primatech.com.
Links to Third-Party Websites

Primatech’s website includes links to other websites whose privacy practices may differ from those of Primatech. If you submit Personal Data to any of those websites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.
Social Media

Primatech’s website includes social media features, such as the Facebook Like button, and LinkedIn and Twitter widgets. These features may collect Personal Data about you such as your IP address and which page you are visiting on our website. They may set a cookie or employ other tracking technologies to accomplish this. Social media features and widgets may be hosted by a third party. The Personal Data provided to those third parties is governed by the privacy statements of the companies that provide them.

Onward Transfer

Primatech may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.  

Your EU and Swiss Privacy Rights

If you are visiting the website from the EU or Switzerland, or where applicable EU and Swiss data protection laws apply, you may exercise, subject to certain limitations, the following rights regarding your Personal Data:

You have the right to confirm with us whether your Personal Data is being processed and, if so, obtain certain information about that processing.

You have the right to request the rectification of inaccurate Personal Data and to have incomplete Personal Data completed.

When we process Personal Data on the grounds of legitimate interests, you have the right to object to the processing of your Personal Data for compelling and legitimate reasons relating to your particular situation, except in cases where legal provisions expressly provide for that processing. In addition, you have the right to object at any time where your Personal Data is processed for direct marketing purposes.

You may receive Personal Data that you have provided to us in a structured, commonly used and machine-readable format, and have the right to transmit the Personal Data to other data controllers without hindrance. This right only exists if the processing is based on your consent or a contract and the processing is carried out by automated means.

You may request that we restrict the processing of your Personal Data if: (i) you contest the accuracy of it – for the period of time we need to verify the accuracy of the Personal Data; (ii) the processing is unlawful and you oppose the erasure of it and request restriction instead; (iii) we no longer need it, but you tell us you need it to establish, exercise, or defend a legal claim; or (iv) you object to processing based on public or legitimate interests – for the period of time we need to verify whether there are legitimate grounds to process the Personal Data.

You may request erasure of your Personal Data if it is no longer necessary for the purposes for which we have collected it, you have withdrawn your consent and no other legal grounds for the processing exist, you objected and no overriding legitimate grounds for the processing exist, the processing is unlawful, or erasure is required to comply with a legal obligation.

Right to refuse or withdraw consent
Please note that if we seek your consent for certain processing, you are free to refuse to give consent and you can withdraw your consent at any time without any adverse negative consequences. The lawfulness of any processing of your Personal Data that occurred prior to the withdrawal of your consent will not be affected.

Right to lodge a complaint
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

If you have questions about exercising any of these rights, or their applicability to any of our particular processing activities, you may contact us at info@primatech.com

International Transfers of Your Personal Data

Subject to this Privacy Statement, Primatech may transfer Personal Data outside of the jurisdiction in which it was collected, including to a jurisdiction whose laws may be less protective of Personal Data. In particular, Personal Data may be transferred to the United States. Transfers will take place using an acceptable data transfer mechanism. Please contact info@primatech.com if you want to receive further information, or, where available, a copy of the relevant data transfer mechanism.

For EU & Swiss Individuals: Transfers of Your Personal Data to the U.S. Under Privacy Shield
Primatech Inc. complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Primatech has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

The U.S. Federal Trade Commission has investigative authority and enforcement jurisdiction over Primatech compliance with the Frameworks.

Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to info@primatech.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to info@primatech.com.

Primatech’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Primatech remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Primatech proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Primatech commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Primatech at: 

Email: info@primatech.com

Primatech Inc./ Primacert
50 Northwoods Blvd.
Columbus, OH 43235
Effective Date: June 27, 2019

Primatech has further committed to refer unresolved Privacy Shield complaints to BBB EU Privacy Shield, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.bbb.org/EU-privacy-shield/file-a-complaint/ for more information or to file a complaint. The services of BBB EU Privacy Shield are provided at no cost to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

Primatech Inc.
50 Northwoods Blvd.
Columbus, OH 43235

Effective Date: June 27, 2019