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PRIMIS PRIVACY NOTICE

Recently Updated: February 3, 2020

1. WHO ARE WE?

This Privacy Notice (“Privacy Notice”) sets out how Primis, part of McCann Israel Group (McCann Disciplines Ltd.) (collectively, “McCann” “Primis”, “we”, “our”) governs the processing and transfer of data collected in connection with our website, available at: www.primis.tech(“Website”) analytics tools, sites, platforms, and as well as otherwise processed by us through other technical applications that we may provide through our customers and third-party websites (collectively, “Services”), to each person accessing or using the Website and/or the Services, including our Partners and End-Users (the “User” or “you”).

 

1.1.  This Privacy Notice is an integral part of our Publisher Terms and Conditions, which can be found at: https://www.primis.tech/publishing-agreement-general-tc/ (the “Terms”).Please note that if you are an End-User (as defined below) or visitor of the Website the Terms may not be applicable to you, thus only this Privacy Notice shall apply to you.

 

1.2. McCann’s Services, provided by Primis, include an online platform enabling an advertiser (“Advertiser”) to display advertisements and marketing materials by video to End-Users who use or otherwise interact with certain web-pages owned by publishers we engaged with (respectively, “End-Users”, and “Publishers”).

 

1.3. We may process data collected through the Website and/or Services in various ways, depending on whether: (i) you are an Advertiser, Publisher or other content provider with whom McCann has a contractual relationship (“Partner(s)”); (ii) you are a visitor of our Website; or (iii) you are an End-User using or visiting our Partners websites or platforms.

 

1.4. This Privacy Notice explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it and how you may exercise your rights associated with your Personal Data (as defined below), including, where applicable, as required under the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

 

1.5. You may not use the Services or the Website or submit any data through them if you do not agree to any of the terms hereunder. This Privacy Notice shall not be construed in any manner to derogate from the Terms or any other agreement or understanding between McCann and you.

 

1.6. Please note, that the Website and/or Services may contain links to other websites, products or services offered by third parties, which are not governed by this Privacy Notice. This Privacy Notice does not apply to the practices of entities which are not controlled by McCann.

 

1.7. If you are a Partner, please note that additional terms may be applicable to you in connection with the processing of Personal Data by you regarding your users and customers, as further specified in the relevant Data Processing Agreement. In the event you are a California resident and the CCPA apply to you (subject to the CCPA provision), please review our CCPA Privacy Notice , for more information regarding your rights and information you are entitled to under the CCPA.

2. THE HIGHLIGHTS:

• You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary. 

 

• Our Services are intended for Users over the age of 16 or equivalent minimum age for providing consent to processing of Personal Data in the relevant jurisdiction. Children under such age are not permitted to use the Services. If you are under such age you should cease to use the Services immediately. 

 

• You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data. Please note that in case you request to erase or restrict the processing of your Personal Data, your use of the Services may be restricted or disabled.

 

• We do not sell, trade, or rent Users’ Personal Data to third parties. We only share Personal Data with third parties in connection with the provision of the Services to our Users, or other limited circumstances as specified herein. 

 

• If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Notice, please send us an email to: privacy@primis.tech.

3. AMENDMENTS TO THIS PRIVACY NOTICE

We reserve the right to periodically revise or update this Privacy Notice. Any modifications to this Privacy Notice will go into effect upon the publication of the revised Privacy Notice on our Website. The last revision date will be reflected in the “Recently Updated” heading located at the top of the notice.

 

We will make a reasonable effort to provide notification in the event that we implement any amendments that substantially change our privacy practices. We recommend that you review this page periodically to ensure that you understand our privacy practices and to check for any amendments.

4. WHAT IS PERSONAL DATA, AND WHAT KINDS OF PERSONAL DATA DOES MCCANN COLLECT?

Personal Data” means any information which identifies or can be used to identify a natural person, including, but not limited to, first and last name, phone number, email address, IP address, billing information, etc.

 

Non-Personal Data” means non-identifiable information, for example we may collect information regarding Users concerning their use of the Website and Services, such as the scope, frequency, latency, pages accessed, what and when a User views or interacts with content and materials displayed through our Services, device specifications, and other technical information regarding the device used to access the Services, such as model, operating system, etc.

 

We collect certain information about you and your use of the Website and Services, including information we collect from you directly (e.g. when you contact us directly we will collect your contact details) and information we collect about you from others (e.g. certain cookies of third parties. See below more information about cookies). Such information may include Personal Data and Non-Personal Data.

 

We also use third-party advertising companies to serve ads when you visit our Website and/or Services. These companies may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please press here and here in order to opt-out.

 

 

5. PERSONAL DATA PROCESSED BY MCCANN

5.1. We use the data collected from Users’ for the specific purposes listed in the table below. Please

note that this table explains:

5.1.1. The types of Personal Data and Non-Personal Data we collect about User.

5.1.2. The legal basis for processing your Personal Data.

TYPE OF DATA
PURPOSE OF PROCESSING
FOR EU PERSONS -LEGAL
Partners’ Registration
When you register to one of our Services or request a demo, you will be requested to provide certain Personal Data, such as full name, e-mail address, your company’s name, phone number, country of residence, your industry role (publisher, advertiser or other), and your website’s URL.
To administer our relationship with you, provide services and ensure the billing of any procured Services by you and obtain payment.
Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Necessity of processing for the purposes of our legitimate interests.
Contact Details
If you voluntarily contact us in any manner, or for any requests or to notify us about something, you may be required to provide us with certain information such as your name and email address which we will then process.
We will use your contact details only in order to respond to you, provide you with support and assist you or provide you with any other service that you may request
Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Necessity of processing for the purposes of our legitimate interests.
Technical Data
We may collect “technical data” from you. This information includes the type of device, operating system and browsers you use, the time and date you accessed the website, User’s actions (i.e. regarding the User’s viewing of and interaction with the Website, including the web pages the user visited and clickstream), your approximate geographical location, and any redirecting URLs.
We collect this data solely in order to operate, provide, maintain, protect, manage, customize and improve our Website.
Necessity of processing for the purposes of the legitimate interests of McCann.
Career
In the event you are interested in joining our team, and wish to submit your CV, you will be required to provide us with your full name, phone number, email address and submit your CV
We collect this data in order to process your job application, including assessing suitability, eligibility and/or fitness to work
Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
Commercial materials and newsletters
In the event a you sign up to receive our newsletter or other marketing materials, you will be requested to provide your email address.
We will use this data solely to send the newsletter and other requested marketing materials.
User’s active consent, as demonstrated by User’s voluntary registration to receive commercial materials and newsletters.
Data Regarding End-Users
When you use the Services as an End-Users of our Partners (e.g. when you visit certain websites that we have placed our Services) we may use cookies or other similar technologies as detailed in our Cookies Policy, and we use certain online identifiers to collect certain information, such as session duration, page impressions, Internet protocol (IP) address, the domain name that served you to access the Service, the geographic location of the computer system that you are using to log-in to, or access the Services, your advertising ID. With respect to the domain name, our system will only use it on real time to make a decision about the type of content to display to you. Such information may be attributed to a general user ID that we generate for each User on the system and is a completely random identifier.We also collect data about End-users’ access and use of advertisements that our Partners embed on their websites through the use of the Services, and the redirection of end-users from such advertisements to the Advertisers’ websites and web pages.

– To provide our Services to our Partners.

– To tailor the content and information that we may send or display to Users.

– To retarget content to end-users through our Services and elsewhere.

– To personalize end-users’ experience while interacting with our Services.

– To operate, provide, maintain, protect, manage, and improve the Website and Services.

– Performing research, as well as for analytical and statistical purposes.

– To audit and track usage statistics and traffic flow, audit our affiliates, calculate payments, detect fraud, for security or technical reasons in connection with the Website and the Services.

Performance of a contract. Necessity of processing for the purposes of the legitimate interests of McCann and its customers.End-Users’ consent, where necessary under applicable laws for the processing of such data.
5.2. We do not knowingly collect or process any Personal Data included in Special Categories of Personal Data (as defined in the GDPR). In the event you become aware that such data has been posted to the Website or collected by us, please inform us immediately.

 

5.3. Please note, that with respect to the GDPR, we act as a Processor of certain Personal Data, such as End-Users’ IP address and other online identifiers, on behalf of our Partners. We are also a Controller of certain Personal Data, such as our Partner’s data, or if individuals contact us or is using our Website.

6. COOKIES

We use data files such as cookies, pixel tags, “Flash cookies,” or other local storage files provided by your browser or associated applications (“Cookies”). We use these technologies in order to recognize you as an End-User, customize our Services, content, and advertising; measure promotional effectiveness; help ensure that your account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety across our Website and Services. For more information please refer to our Cookie Policy.

7. WILL MCCANN SHARE MY PERSONAL DATA WITH OTHERS?

7.1. Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion. This information does not contain Personal Data and is used to develop content and services for our Users and clients.

7.2. We share Personal Data only under the following limited circumstances:
7.2.1. With our Partners when you interact with our Services that are implemented on their websites and platforms.
7.2.2. With trusted partners and third parties who assist us in operating the Services and conducting our business, such as fraud prevention, bill collection, account maintenance, marketing and technology services.
7.2.3. For personalizing your experience of the Services, including by way of targeted advertising on the Website.
7.2.4. As necessary to help detect and prevent potentially illegal acts and fraud, and to guide decisions about products, services and communications.
7.2.5. We may share your Personal Data with a parent company, subsidiaries, joint ventures, or other companies under common control (“Affiliated Companies”) solely if and when applicable or necessary. In addition, we may share information, in the event of a corporate transaction (e.g. sale, merger, consolidation, etc.), provided however, that our Affiliated Companies or acquiring company will be subject to the obligations detailed herein with respect to your Personal Data.
7.2.6. To comply with a legal requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.
7.2.7. Other third parties with your consent or direction to do so.

8. WHAT USER RIGHTS DO I ENTITLED TO?

Since different Users have different privacy rights under applicable laws, we provide you with the ability to exercise certain choices, rights and controls in connection with your data, depending on your relationship with us and the applicable laws. For instance, if you are a visitor of our Website, a Partner or an End-User, you may be entitled to different rights under applicable data protection and privacy laws, including (and depending on your jurisdiction):

• The right to access Personal Data that we process about you;
• The right to ensure your Personal Data is accurate, complete and up to date;
• The right to ask the deletion of your Personal Data (to the extent practical and applicable);
• The right to object to the processing of your Personal Data, to the extent applicable;
• The right to send as for the portability of your Personal Data;
• The right to file a complaint with a supervisory authority;
• The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice;
• The right to not be discriminated against exercising your rights; and
• The right to submit an opt-out (e.g. “do not sell”) request, where applicable.

For more information about these rights and how you can exercise them, including what each right please review our User Rights Policy.

We provide you with the ability to exercise your rights, depending on your relationship with us. If you wish to exercise any or all of the above rights, please contact us at: privacy@primis.tech.

We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.

9. FOR HOW LONG DO WE RETAIN THE DATA WE COLLECT AND PROCESS?

We retain the data we collect solely for as long as required to fulfil the purposes for which it was initially collected, or for longer periods in the event we are required to do so in order to comply with legal, tax and accounting requirements. In addition, we will retain information we believe is needed in order to protect our rights and interests in accordance with applicable laws. For additional information on our data retention policy in connection with different types of Personal Data, see the below table.

TYPE OF PERSONAL DATA
RETENTION PERIOD
“Contact Us” communications
As long as needed to provide you with the Services you have requested and for longer periods in the event, we believe it is required in order to defend our rights and interests, subject to applicable laws.

Data regarding End Users
Where such data constitutes Personal Data, we will retain the data for the duration of the term of provision of our Services to our Partners, and in addition a reasonable terms for the defense and assertion of legal claims. Non-personal data may be retained indefinitely.
Email address for receiving Commercial materials and newsletters
Until the User has opted out of the service.

Career – C.V.
In the event the User has become an employee, for the duration of employment and in addition for as long as necessary to for the defense and assertion of legal claims.
Technical Data
Technical data is retained in a manner which does not enable the identification of any individual, and may be retained indefinitely.

Customers Registration
Where such data constitutes Personal Data, we will retain the data for the duration of the term of provision of our Services to our customers, and in addition a reasonable terms for the defense and assertion of legal claims.

10. WILL MCCANN TRANSFER MY PERSONAL DATA INTERNATIONALLY?

Our databases are currently located in the Netherlands and the U.S. Some of our processing activities are made in Israel. The European Commission has decided that the State of Israel ensures an adequate level of privacy and data protection, therefore, in accordance with the GDPR, the transfer of Personal Data from the EU to Israel is lawful and does not require any specific authorization.

Any other transfer of Personal Data originating from the EU to a third country (other than Israel) shall be made in accordance with applicable law, including by providing adequate protections, or otherwise implementing appropriate safeguards to ensure the protection of our Users’ rights.

11. WILL I RECEIVE PROMOTIONAL MATERIALS FROM MCCANN?

McCann may send you offers that may be of special interest to you via email or SMS. You may unsubscribe from receiving such communications at any time, by sending us a notification to: privacy@primis.tech, or following the instructions for unsubscribing included in such communications.

We may also engage with third parties to track and report performance of advertising and marketing campaigns to and from McCann and third party web sites. We may combine your information with information we collect from third parties and use it to improve and personalize our Services, content, and advertising.

12. PERSONS UNDER 16

Our Website and/or Services are intended for a general audience, which is not directed to persons under 16 years old. If a parent or guardian becomes aware that his/her child has provided us with Personal Data without their consent, he/she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 16 years old. If we become aware that a person under 16 years old has provided us with Personal Data, we will delete such data from our databases.

13. APPLICABLE LAWS

The provisions included in this Notice relating to matters regulated under the GDPR will apply only to the processing of Personal Data which is subject to the GDPR in accordance with the applicability provisions contained therein. If the GDPR does not apply to the processing of your Personal Data, some of the provisions above may not apply to you.

14. QUESTIONS OR CONCERNS REGARDING PRIVACY

If you have any questions or concerns regarding privacy issues, please send us a detailed message to privacy@primis.tech, or via regular mail to: McCann Tel Aviv, at 2 Raoul Wallenberg St., Tel Aviv, 6971902 Israel and we will make every effort to resolve your concerns without delay.

 

You may also be entitled to file a complaint with the appropriate supervisory authority in connection with concerns you may have with regards to your privacy.


PRIVACY NOTICE FOR CALIFORNIA RESIDENTS UNDER THE CCPA
Last Modified: February 3, 2020

This California privacy notice (“California Notice”) for California Residents under the California Consumer Privacy Act of 2018 (“CCPA”) supplements the information contained in Primis Privacy Notice, and applies solely to Users others who reside in the State of California (“Consumers” or “you”), as defined under the CCPA. Any terms defined in the CCPA have the same meaning when used in this California Notice. Further, this Privacy Notice is an integral part of our Privacy Notice, thus, definitions used herein but not defined herein shall have the meaning ascribed to them in our Privacy Notice.

As required under the CCPA, we will update this California Notice every 12 months. The last revision date will be reflected in the “Last Modified” heading

TYPES OF PERSONAL INFORMATION WE COLLECT

Under the CCPA, “Personal Information” is defined as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device. The categories of Personal Information that we collect (and has collected within the last 12 months), are detailed in the table below. Please note that, it includes Personal Information collected from our Website and Services, as applicable.

Please note that, under the CCPA Personal Information does not include: publicly available information from government records and de-identified or aggregated consumer information, information excluded from the CCPA scope and information covered by certain sector-specific privacy laws.

Category
Examples
Collected
A. Identifiers.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
Yes
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
No
D. Commercial
Records of personal property, products or services
No
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
No
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Yes
G. Geolocation data.
Physical location or movements.
No
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
No
I. Professional or employment-related information.
Current or past job history or performance evaluations.
No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
No
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
No

HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:
i. directly from you, for example, if you contact us or send us your CV;
ii. indirectly from you, for example, from observing your interaction with our Services through our Partners’ websites and platforms;
iii. from third-party business partners such as ad networks and analytics providers.

USE OF PERSONAL INFORMATION

We may use, or disclose the Personal Information we collect for one or more of the following business purposes:
• To fulfill or meet the purposes for which you provided the information (e.g. if you contact us with an inquiry and share your name and contact information, we will use that Personal Information to respond to your inquiry.
• To provide, support, improve, and develop our Website and Services.
• For security and fraud detection purposes, and to maintain the safety, security, and integrity of our Website and Services.
• For testing, research, analysis, and product development.
• To calculate payments related to the Services we provide our Partners.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you a notice.

SHARING DATA

We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

We share your Personal Information with the following categories of third parties:
(i) Service providers – Such as cloud service providers and marketing service.
(ii) Data aggregators – for analytic purposes.
(iii) Partners – Publishers and Advertisers using our Services.

DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:

Category A: Identifiers.

SALES OF PERSONAL INFORMATION

In the preceding twelve (12) months, we did not sell Personal Information.
Please note that as we are an ad network we are considered as the Service Provider of our Partners. Therefore, in the event you are an End-User interacting with our Services (i.e., our media player implemented in our Partner’s digital assets), the Partner may provide you with a “Do Not Sell” link.

 

Additionally, you may also use industry opt-out mechanisms, for example:

 

Digital Advertising Alliance (“DAA”) Opt-Out
The DAA offers tools to provide consumers with choices as to whether participating third parties can use your information to provide targeted advertising. To learn more about interest-based advertising, please visit the DAA http://optout.aboutads.info/?c=2&lang=en. To opt out of sharing your information with such participating third parties for targeted advertising, please use the following tools:

For websites: the DAA WebChoices Tool, available at http://optout.aboutads.info/?c=2&lang=EN.
For mobile applications: the DAA AppChoices Tool, available at http://www.aboutads.info/appchoices.

 

Network Advertising Initiative’s (“NAI”) Opt-Out
http://optout.networkadvertising.org/?c=1.

 

Google Opt-Out
You may opt out of Google Analytics by installing opt-out browser add-on, and opt out of interest-based Google ads using Google’s Ads Settings. Google may also participate in the DAA WebChoices Tool (above).

 

More Information about opting out
• The opt-outs described above are device and browser based, thus you must opt out on each device and each browser where you want your choice to apply.
• Opt-outs may be implemented via cookies. If you clear cookies, your opt-out will no longer be valid and you must opt out again where you want your choices to apply.
• McCann does not maintain or control the opt-out mechanisms and settings above and is not responsible for their operation.
• Exercising these choices will not prevent us from delivering contextual advertising or using information for non-targeted advertising purposes. Furthermore, we may still share some Personal Information for a business purpose such as fraud prevention or if required under applicable laws.
• Our Partners may provide ways for you to opt out from or limit their collection of information from and about you. Please refer to the Partner’s privacy policies. Please note, however, that we are not responsible for the privacy practices of our Partners, and other third parties.
• For end user interacting with the Services – we require our Partners, such as websites and applications that implement our Services, and Advertisers or content providers that serve and display content on Publishers’ websites, to provide Users with an easy to access opt out option. You can also opt out from having content displayed to you based on your data (however it can still be based on a web-page data in which the Services are implemented).

USER RIGHTS

The CCPA provides consumers with specific rights regarding their Personal Information. Please review our The right to erasure is not absolute. to learn your rights as well as the way you may exercise them, the process and the applicable time frame.

CONTACT US

If you have any questions or comments about this Policy, or any concerns with respect to how your privacy any information are handled, please contact us at:
privacy@primis.tech.

McCann Tel Aviv, at 2 Raoul Wallenberg St., Tel Aviv, 6971902 Israel


USER PRIVACY RIGHTS POLICY
Last Modified: February 3, 2020

Primis – Video Discovery, part of McCann Israel Group (McCann Disciplines Ltd.) (Collectively, “McCann” “Primis”, “we”, “our”) values the privacy rights of our Users. Thus, we have designed this User Privacy Rights Policy (“User Rights Policy” or “Policy”) as an overview of your rights regarding your personal data, under the following legislation:

 

(i) The EU General Data Protection Regulation (“GDPR”), which shall apply to you in the event you are a resident of the European Economic Area (“EEA”); and

 

(ii) The California Consumer Privacy Act of 2018 (“CCPA” or “Act”) which shall apply to you in the event you are a “California Resident”, as defined under the CCPA. This Policy applies solely to your rights concerning Personal Data or Personal Information (as defined under the applicable law) processed by us. If you wish to submit a request to exercise any of your rights, please contact us at: privacy@primis.tech.

Your Right to be Informed

You have the right to be informed with our details (e.g. name, address, etc.), as well as why and how we process Personal Data. This right includes, among others, the right to be informed with the identity of the business, the reasons and lawful basis for processing Personal Data, and additional information necessary to ensure the fair and transparent processing of Personal Data. Further, you have the right to be informed on the categories of Personal Information collected, sold, disclosed by us in the previous 12 months, therefore we ensure our Privacy Notice discloses all of the above and is updated every 12 months.

Right to Access

You have a right to request us to confirm whether we process certain Personal Data related you, as well as a right to obtain a copy of such Personal Data, with additional information regarding how and why we use this Personal Data. After we receive such request, we will analyze and determine the veracity and appropriateness of the access request and provide you with the applicable confirmation of processing, the copy of the Personal Data or a description of the Personal Data and categories of data processed, the purpose for which such data is being held and processed, and details about the source of the Personal Data if not provided by you. Our response detailed above will be provided within the period required by law (please see additional information under “Response Timing and Format” below). Notwithstanding the above, the GDPR and CCPA provide different protections, the GDPR enables access to all Personal Data processed by a controller, however the CCPA access right applies only to Personal Information collected in the 12 months prior to the request.

The Right of Rectification

If Personal Data held by us is not accurate, you may require us to update such data so it is accurate. Further, in the event we have passed on incorrect information about you to a third party, you also have a right to oblige us to inform those third parties that the applicable information should be updated.

Erasure Rights (“right to be forgotten” or “right of deletion”, as applicable)

We are legally obligated to comply with a request to delete Personal Data if: the data is no longer needed for the original purpose and no new lawful purpose exists for continued processing; the lawful basis for processing is consent of the data subject and such consent is withdrawn; the data subject exercises his or her right to object to the our processing of his or her personal data, and we have no overriding grounds for processing the data; the personal data is processed unlawfully; or erasure of the data is necessary to comply with applicable laws.

In addition, if we passed on Personal Data to a third party, a data subject also has a right to oblige us to tell those third parties that the information should be erased. The right to erasure is not absolute. Even if a data subject falls into one of the categories described above, we are entitled to reject the data subject’s request and continue processing data if such processing is: necessary to comply with legal obligations; necessary to establish, exercise or defend legal claims. or is necessary for scientific research, etc. necessary to perform a contract between you and us. necessary to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity. necessary to debug to identify and repair errors that impair existing intended functionality. and to enable solely internal uses that are reasonably aligned with your expectations based on the our relationship with you – all subject to applicable laws.

Right to Object

With regards to Personal Data processed by us under the lawful basis of our legitimate interests (such as direct marketing), you may object to our processing on such grounds. However, even if we receive your objection, we will be permitted to continue processing the Personal Data in the event that (subject to applicable laws and regulations):

(i) our legitimate interests for processing override your rights, interests and freedoms.

(ii) the processing of such Personal Data is necessary to establish, exercise or defend a legal claim or right, etc.

The Right of Restriction

A data subject may limit the purposes for which we may process his/her personal data. Our processing activities may be restricted if: the accuracy of the data is contested; processing is unlawful and data subject requests restriction instead of erasure; we no longer need the data for its original purpose, but the data is still required to establish, exercise or defend legal rights; or consideration of overriding grounds in the context of an erasure request.

Data Portability

You may request us to send or “port” your Personal Data held by us to a third-party entity, however note, the GDPR and CCPA apply differently to this right, thus, we will handle this according to the jurisdiction you are subject to.

Do Not Sell

You have the right to know which data is sold, to whom and for what purpose. You also have the right to request the data not to be sold. Note, “selling” data under the CCPA includes any transfer of data for the purpose of receiving valuable goods.

Nondiscrimination

Under the CCPA, you must not be discriminated for exercising any of your rights, including by denied goods or services, charging you with different fees for goods or services, including through the use of discounts or other benefits or imposing penalties; suggested you will receive a different price or rate for goods or services. Notwithstanding the above it is allowed to set up schemes for providing financial incentives and you can opt-in to become part of them.

Response Timing and Format

1. Time. We endeavor to respond to a verifiable consumer request with undue delay and in any event within 30 days from the receipt of the request subject to GDPR, and between 10-45 days from receipt of a request subject to CCPA.

2. Extension. If we require more time, we will inform you of the reason and extension period in writing. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

3. Fees. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.Further, note, under the CCPA you are not entitled to submit more than 2 requests in a 12 months period.

Further, note, under the CCPA you are not entitled to submit more than 2 requests in a 12 months period.

Please submit a request by:
* Emailing us at privacy@primis.tech.

About this Cookie Policy

This Cookie Policy explains what cookies are and how we and third parties use them. For further information on how we use, store and process Personal Data, see our Privacy Notice.

This Cookie Policy includes the following information:
1. Cookies and similar technologies
2. Types of cookies
3. What Information Do We Collect?
4. How To Manage Cookies
5. Changes and Updates6. Cookies used on our Site
7. Cookies used through our Services

1. COOKIES AND SIMILAR TECHNOLOGIES

1.1. A cookie is a small text file that is placed on the browser of your computer or mobile device (or other end device), by websites you visit and applications you use. Other automated means often used on websites and applications are Pixel tags (also known as web beacons or clear GIFs). Pixel tags are typically transparent graphic images placed on a website. These pixels are used in combination with cookies to measure the actions of visitors on the website.

Most websites and applications use cookies and other automated means to collect certain data and facilitate services. Cookies are typically used in order to make websites function, or function more efficiently, make your experience when browsing the website or application more enjoyable and smooth, to remember your preferences, to autocomplete details so you don’t have to insert your full details every time you log in (such as user name and password), to tailor content and information that is displayed to you and otherwise work to personalize your experience of the website or application. Cookies are also commonly used a tools enabling websites and applications owners to better understand the use of their products and services, to conduct business analytics and to engage in advertising activities for their business purposes or on behalf of third parties.

1.2. There are different types of cookies. Some cookies come directly from the website or application you are browsing and others come from third parties which place cookies on such site. Such types of cookies are commonly categorized as “First Party Cookies” and “Third Party Cookies”, respectively.

 

1.3. Cookies can be stored for varying lengths of time on your browser or device. “Session Cookies” are limited to the duration of you visit to the relevant website or application, and are terminated when you exit the website or application. “Persistent Cookies” will remain stored on your computer or device until deleted or until they reach their expiry date.

2. CATEGORIES OF COOKIES

2.1. Strictly Necessary Cookies – These cookies are necessary to enable the communication between the user’s device and the website or application, or to provide the user with services requested by him/her, such cookies are used for the sole purpose of carrying out a transmission of a communication over an electronic communications network, or to allow the provider of an online service to provide its services as explicitly requested by users.

 

2.2. Functionality Cookies – These cookies allow the website or application to remember choices the user made (such as username, password, language preferences, or region) and provide enhanced, more personal features, to improve the user’s experience on the website or application.

 

2.3. Performance (Analytic) Cookies – These cookies collect information about how visitors use the website or application, such as which pages visitors go to most often and if they are likely to get error messages from certain pages. These cookies collect aggregate information that does not identify a specific user personally. These cookies are used to improve how a website or application works, analyze use patterns of the website or application, and assist the provider to maintain and improve its services.

 

2.4. Advertising (Targeting) Cookies – These cookies are used to deliver personalized advertisements to the user. Such cookies may be used to analyze a user’s preferences in accordance with the contextual information about the user’s activities on the website or application (for example, if a user is surfing a webpage displaying an article about a sporting event, cookies may be used to display to the user an advertisement associated with sports fans), or to correlate between a user and information about such user collected from other websites or applications (for example, to display to the user an advertisement associated with sports fans based on the user’s profile in other websites or applications). These cookies are used to promote advertising campaigns of website and application owners or those of third parties, as well as help measure the effectiveness of an advertising campaign.

 

Advertising cookies are usually placed by advertising networks, which connect between the relevant advertiser and the location of publication of the advertisement.

3. WHAT COOKIES DO WE USE AND WHAT INFORMATION IS COLLECTED USING COOKIES?

3.1. Cookies used on our Website – our Website contains both First Party Cookies and Third Party Cookies, Strictly Necessary Cookies, Functionality Cookies, Performance (Analytic) Cookies, and Advertising (Targeting) Cookies.

 

3.2. information collected through on our Website through the use of cookies includes:

• Information about your operating system and device;

• Webpages accessed within our Website, the link that led you to our Website, dates and times you accessed our Website, event information (e.g. system crashes) and general location information (i.e. city or region).

• Information provided on the Website by users in order to streamline the user’s experience and prevent user from having to re-enter information during the next visit to our Website;

• Number of visitors on our Website and which webpages have been viewed;

• Advertising user ID and information associated with targeted advertising.

 

3.3. Cookies used through our Services – In connection with digital advertising services provided to our Partners by us or other entities within the McCann group, we may use the information collected via cookies on the websites of our customers to make your use of their services and products more enjoyable, to promote their advertising campaigns, to improve the functionality of their services, and tailor the content and information that it displayed to you. We may also use pixel tags on the websites of our customers to track conversions or to create a custom audience for our advertiser customers to target on our network (i.e. retargeting).

 

See below links to common browsers enabling the control of cookies:

BROWSER TYPE

 

Please note however, that if you choose to disable certain cookies, some features of our Website may not operate properly and your online experience may be limited

 

5. CHANGES AND UPDATES

5.1. We may update this Cookie Policy from time to time. We encourage you to periodically review this Cookie Policy to stay informed about our use of cookies, the information we collect via cookies, and any updates in relation thereto.

 

5.2. We will post any changes to this Cookie Policy on our Website.

6. COOKIES USED ON OUR WEBSITE:

The following cookies are used on our Website:

FIRST PARTY COOKIES
COOKIE CATEGORY
COOKIE NAME
PURPOSE
Strictly Necessary cookies
1. csuuidts
Creating anonymous digital ID for Primis users.

You may also encounter McCann Cookies on websites that we do not control. Likewise, certain third parties may place their own Cookies in the Website and Services. Such third party Cookies are not subject to our control and this Notice does not cover them. If you are located in the EEA when accessing our Website, the use of persistent and third party cookies will comply with the laws applicable to you.