Last updated: December 2025
Primis
Video Platform Privacy Notice
Introduction
We, at M.D. Primis Technologies Ltd. (the “Company”, “we”, “us”, “our”), develop and operate a video advertising solution (the “Solution”). The Solution is used in websites and mobile applications (“Online Properties”) by the operators of those Online Properties (“Publishers”).
In accordance with privacy laws (such as with your consent or after providing you with a right to opt-out), we will collect and share your personal data to display advertisements tailored to your interests.
This Privacy Notice (the “Notice“) describes the personal information we collect and the policies and procedures we use regarding your personal data processed through our Solution.
This Notice may be amended periodically. We will post any changes to this Notice on our Website a reasonable time in advance of the effective date of such changes.
Contact us
If you have any questions, comments, or concerns regarding this Notice or our processing of your personal information, please contact us at privacy@primis.tech or by mail at M.D. Primis Technologies Ltd., 2 Raoul Wallenberg St., Tel Aviv, 6971902 Israel, Attention: Privacy Team.
Persons under 16
We do not knowingly collect information from individuals under 16 years of age.
What we collect and how
When you access an Online Property that uses the Solution, we will collect and process the following information:
- A unique user ID that we generate and retrieve when you access various Online Properties where our Solution is deployed.
- Information regarding your engagement with our video player (or content slider) on the Online Property, such as clicking ‘Play’, the duration of your visit to the webpage, etc.
- The IDFA (Identifier for Advertisers), if the Online Property is an iOS native application.
- The AAID (Android Advertising Identifier), if the Online Property is a native Android application.
- The IP address of the device you use to access the Internet. We process this momentarily and do not retain it.
- Your approximate (city-granular) location derived from your IP address. This does not constitute precise geolocation.
- Contextual information: the content on the Online Property you are accessing, the URL, and keywords and tags associated with the content on the Online Property.
- Analytics information: the browser type, language, and operating system you use. We process this momentarily and do not retain it.
The source of this information is the device you use to access the Internet and the Online Property you are accessing.
Data Minimization: We collect only the personal information that is necessary for the specific purposes described in this Notice and retain it only for as long as necessary to fulfill those purposes.
Some of this information is stored and accessed via a cookie saved on the device you use to access the Internet.
What we use this information for
We use the information explained above for several purposes:
- Select advertising that we aim to tailor to your interests, based on your information.
- Create and improve user profiles to present more relevant advertising based on your assumed interests. This includes combining the data we collect with other information about the user or similar users.
- Measure advertising performance based on the user’s interaction with the advertisement (e.g., saw the ad, clicked), to inform our business development and allow our advertising partners to understand the relevance of advertising campaigns.
- Ensure the technical compatibility of the content or advertising and facilitate the transmission of the content or ad to your device.
- Ensure security, prevent and detect fraud, and fix errors so that systems and processes operate properly and securely.
Sharing your personal information
We share your information with third parties in the circumstances listed below. All service providers and partners are required to implement appropriate security measures consistent with data protection and information security requirements.
| Scenario | Purposes | Examples of Third parties involved |
| We will share your personal information with our service providers who assist us with the internal operations of our business and the Solution. These companies are authorized to use your personal information in this context only as necessary to provide these services to us and not for their own promotional purposes. | Operating the Solution | Amazon Web Services |
| Preparing to select advertising that aims to be tailored to your interests, according to your information. | Recognize the user each time they interact or connect with Online Properties. | Providers of device and user identity mapping services |
| The ongoing operation of the Solution |
|
Advertising technology partners, demand-side platforms, supply-side platforms, ad networks, data management platforms, measurement and analytics providers, and other entities in the programmatic advertising ecosystem, as detailed in the cookie consent banner presented to you. |
Opting out
If you wish to opt out from the sharing of your personal data with third parties for the purpose of cross-contextual interest-based advertising, there are several ways to do so. Please note that even if you opt out, you may still see personalized ads based on information other companies and ad networks have collected about you, if you have not opted out of sharing with them. For opt-out options on desktop and mobile websites, please visit:
Digital Advertising Alliance (US) https://www.aboutads.info/choices/
Digital Advertising Alliance (Canada) https://youradchoices.ca/en/tools
Digital Advertising Alliance (EU) https://www.youronlinechoices.com/
Network Advertising Initiative https://optout.networkadvertising.org/?c=1
Data retention and security
Whenever you visit an Online Property that uses the Solution, we retain the personal information associated with an identifier of your visit to that Online Property for 25 days from your last visit to the Online Property. Once 25 days have passed from the day of your last visit to the Online Property, we delete the identifier, andthe associated information from those past visits are no longer tied to you.
Information Security Governance. The Company maintains an information security management framework aligned with recognized security standards. Access to personal data is restricted to authorized personnel, and security controls are periodically reviewed to ensure ongoing protection
Security Measures: We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit and at rest, access controls, regular security assessments, and employee training on data protection principles.
Security Incidents: The Company maintains procedures for identifying, managing, and responding to information security incidents involving personal data, including notification to relevant authorities and affected individuals where required by applicable law
Additional Information for Individuals in the EU or UK
Controller and GDPR Representative
| Name | Address |
| M.D. Primis Technologies Ltd. (previously known as McCann Disciplines Ltd.) | 2 Raoul Wallenberg St., Tel Aviv, 6971902 Israel |
International Data Transfers
Our processing of your personal data occurs in Israel, a country recognized with an adequacy decision under the EU GDPR and UK GDPR.
To facilitate sharing your information with others, we will transfer your information to countries such as the United States. We do so under the terms of a data transfer agreement that contains standard data protection contract clauses with adequate safeguards determined by the EU Commission.
Legal Basis for Processing Your Personal Data
| Purpose or Scenario | Legal Basis |
| Store and access information on your device to allow us to recognize you each time you interact or connect with Online Properties. | Consent |
| Select advertising that we aim to tailor to your interests, according to your information. | Consent |
| Create and improve user profiles to present more relevant advertising based on your assumed interests. This includes combining the data we collect with other information about the user or similar users. | Consent |
| To measure the performance and effectiveness of ads and other content that you see or interact with, to inform our business development, and to allow our advertising partners to understand the relevance of advertising campaigns. | Consent |
| To monitor for and prevent fraudulent activity, and to ensure systems and processes work properly and securely. | Legitimate interests in preventing fraudulent activity |
| To receive and send technical information that enables your device to present and interact with ads and content. | Legitimate interests in providing the content or ad requested |
Data Subject Rights
If you are in the EU or the UK, you have the following rights under the GDPR:
Right to Access and receive a copy of your personal information that we process.
Right to Rectify inaccurate personal information we have concerning you and to have incomplete personal information completed.
Right to Withdraw Consent that you have previously given to our processing of your personal data, at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Right to Data Portability, that is, to receive the personal information that you provided to us, in a structured, commonly used, and machine-readable format. You have the right to transmit this data to another person or entity. Where technically feasible, you have the right to have your personal information transmitted directly from us to the person or entity you designate.
Right to Object to our processing of your personal information based on our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or if we need to process such personal information for the establishment, exercise, or defense of legal claims.
Right to Restrict us from processing your personal information (except for storing it): (a) if you contest the accuracy of the personal information (in which case the restriction applies only for a period enabling us to determine the accuracy of the personal information); (b) if the processing is unlawful and you prefer to restrict the processing of the personal information rather than requiring its deletion by us; (c) if we no longer need the personal information for the purposes outlined in this Notice, but you require the personal information to establish, exercise, or defend legal claims; or (d) if you object to our processing based on our legitimate interest (in which case the restriction applies only for the period enabling us to determine whether our legitimate grounds for processing override yours).
Right to be Forgotten. Under certain circumstances, such as when you object to our processing of your personal information based on our legitimate interest and there are no overriding legitimate grounds for the processing, you have the right to ask us to erase your personal information. However, notwithstanding such a request, we may still process your personal information if it is necessary to comply with our legal obligations, or for the establishment, exercise, or defense of legal claims. If you wish to exercise any of these rights, please contact us through the channels listed in this Notice.
When you contact us, we reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. If we are unable to provide you with the information you have requested, we will explain the reason.
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint with the supervisory authority in the Member State of your residence, place of work, or place of alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.
If you are in the UK, you can lodge a complaint with the Information Commissioner’s Office (ICO) pursuant to the instructions provided here.
Additional Information for Individuals in the United States |
|||||||||||
| If you are an individual residing in the United States, we provide you with the following information pursuant to the California Privacy Rights Act (CPRA) and other state privacy laws in the U.S. This is also the information we have collected in the past 12 months.
We share all the categories of personal information detailed below for online behaviorally targeted ads, but we do not sell your personal information and have not done so in the past 12 months. We do not use or disclose sensitive personal information.
|
Sharing and Disclosing Your Information to Third Parties
The chart below explains the personal information we share for online behaviorally targeted ads in the preceding 12 months. Other than this sharing, we have not disclosed your personal information for a business purpose in the preceding 12 months.
We do not have actual knowledge that we share the personal information of consumers under 16 years of age for online behavioral-targeted ads.
| Categories of personal information | Categories of third parties to whom we share your information for online behavioral-targeted ads | The specific business or commercial purpose for sharing your information for online behavioral-targeted ads |
| Identifiers |
|
|
| Internet or other electronic network activity information | ||
| Inferences | To show you personalized ads and other content based on a profile about your visits to Online Properties and your approximate location. |
Your rights under state privacy laws in the United States
Notice of the Right to Opt-Out Using the Opt-Out Preference Signal
You have a right to opt out of sharing your personal information for behavioral-targeted ads. You can exercise this right by using the opt-out preference signal as explained here.
We process the opt-out preference signal if it is sent by your browser in accordance with the “Global Privacy Control.” For more information on how to install and implement the Global Privacy Control, please visit globalprivacycontrol.org/#download.
If you turn on this Global Privacy Control in your browser, we will receive the signal, process it in a frictionless manner, and treat it as a request to opt out of the use of your personal information for behavioral-targeted ads. The opt-out request is specific to the browser in which you have it turned on. It is effective as an opt-out request only while you use that browser to surf the web.
Knowing the personal information we collect about you
You have the right to know:
- Whether we process your personal information.
- The categories of personal information we have collected about you.
- The categories of sources from which the personal information is collected.
- Our business or commercial purpose for collecting your personal information.
- The categories of third parties with whom we share your personal information, if any.
- The specific pieces of personal information we have collected about you.
Your right to know is subject to exceptions provided by law.
Right to Deletion
Subject to certain exceptions set forth below, upon receipt of a verifiable request from you, we will:
- Delete your personal information from our records; and
- Direct any service providers to delete your personal information from their records.
Please note that we may not delete your personal information if it is necessary to:
- Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided by law.
- Comply with applicable Electronic Communications Privacy law.
- Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete such research, provided we have obtained your informed consent.
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information.
Or
- Comply with an existing legal obligation.
We will also deny your request to delete if it proves impossible or involves disproportionate effort, or if another exception applies. We will provide you with a detailed explanation that includes sufficient facts to give you a meaningful understanding as to why we cannot comply with the request to delete your information.
Right to Correct Inaccurate Personal Information
If we receive a verifiable request from you to correct your information and we determine the accuracy of the corrected information you provide, we will correct inaccurate personal information that we maintain about you.
In determining the accuracy of the personal information that is the subject of your request to correct, we will consider the totality of the circumstances relating to the contested personal information.
We may also require that you provide documentation if we believe it is necessary to rebut our own documentation that the personal information is accurate.
We may deny your request to correct in the following cases:
- We have a good-faith, reasonable, and documented belief that your request to correct is fraudulent or abusive.
- We determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.
- Conflict with federal or state law.
- Other exception under law.
- Inadequacy in the required documentation.
- Compliance proves impossible or involves disproportionate effort.
We will provide you with a detailed explanation that includes sufficient facts to give you a meaningful understanding as to why we cannot comply with the request to correct your information.
Protection against discrimination
You have the right not to be discriminated against by us because you exercised any of your rights under state privacy laws.
Exercising your rights under state privacy laws, methods for submitting requests and appeals
If you would like to exercise any of your rights as described in this Notice (other than the right to opt-out), please contact us by email at privacy@primis.tech.
We will ask you for additional information to confirm your identity and for security purposes before disclosing the personal data requested to you, by using two- or three-points of data verification process, depending on the type of information you require and the nature of your request.
You may also designate an authorized agent to make a request on your behalf. To do so, you need to provide the authorized agent written permission, and the agent will need to submit to us proof that they have been authorized by you. We will also require that you verify your own identity, as explained below.
Our response to your requests
We will respond to your requests within 45 days (or within 90 days, where the law permits and we determine it necessary considering the complexity and number of the requests you have filed). If we take longer than 45 days, we will inform you of the extension within the initial forty-five-day response period, together with the reason for the extension.
We may deny your request in the following cases:
- ● If we believe in good faith, based on reasons that are documented in writing, that your request is fraudulent or is an abuse of your rights under applicable law.
- If we conclude that the request is irrelevant, based on all the circumstances at issue (e.g., if you requested to correct your personal information, and we find that it is likely to be accurate).
- If it is contrary to federal or state law.
- ● Due to a discrepancy in the required documentation.
- ● If the fulfillment of your request turns out to be impossible or involves disproportionate effort.
We will provide you with a detailed explanation, including sufficient facts, to enable you to meaningfully understand why we cannot fulfill your request.
You may appeal our decision to deny your request by sending us an email to privacy@primis.tech.