Last Updated: November 26, 2024

Note for California Residents: This Privacy Policy describes how Primate Technologies LLC processes your Personal Information and your choices regarding our processing. The Notice for California and Other US State Residents section below contains specific details about your rights under California law, including your right to opt out of Personal Information "sales."

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This Privacy Policy applies to Primate Technologies LLC ("we," "us") websites (the "Websites"). This policy does not apply to Personal Information collected on any of our product platforms and solutions, which are governed by the privacy policy available at privacy@primate-tech.com.

This Privacy Policy describes the collection, use, and disclosure of Personal Information gathered through our Websites. Personal Information includes any information that identifies, describes, or relates to an identified or identifiable individual, or information reasonably capable of being associated with a particular consumer or household ("Personal Information") from visitors to our Websites ("you," "your"). It also outlines your choices regarding use, access, and modification of your Personal Information.

By using the Primate Technologies LLC Websites, you acknowledge reading and understanding this Privacy Policy. If you disagree with this Privacy Policy, please do not use the Websites.

Please also review our Website Terms of Use, as all terms and conditions form an agreement between you and us.

Table of Contents

• Collection of Personal Information
• Privacy of Minors
• Website Usage Data and Tracking
• Information Usage and Sharing
• Personal Information Management
• Third-Party Services
• External Links
• Data Protection
• Information Retention
• Opt-Out Options
• California Residents' Rights
• European Privacy Rights
• Data Privacy Framework Details
• Additional Rights
• Policy Updates
• Contact Information

We collect Personal Information when you provide information directly to us to access certain services and resources. Examples include:

Newsletter Subscription:

• First and last name
• Email address

Product Demonstration or Support Requests:

• First and last name
• Work email address
• Organization type
• Country location

Optional Information We May Request:

• Job title
• Organization name
• State/region of operation

Our Websites target a general audience and are not intended for individuals under age 13 or below the age of consent in each operating region ("children," "child"). Primate Technologies LLC does not knowingly gather Personal Information from children. Upon discovering any inadvertently collected child's Personal Information, we will promptly delete it.



When you visit our Websites, our servers automatically collect:

• Internet Protocol ("IP") address of your device
• Browser type and version
• Operating system and language
• Country location
• Referral URL
• Time spent on Websites
• Frequently visited pages and timing

We utilize this information for:

• Website administration
• Preference management
• Technical issue diagnosis
• Analytics for user behavior patterns
• Website improvement

We collect this data through web servers and the following digital tracking technologies:

Tracking Technology Details:

• Browser Cookies: Small data files stored on your device that help recognize your browser and remember preferences
• Web Pixels: (also called "clear gifs" or "beacons") Track usage patterns and monitor email engagement
• Local Storage: HTML5 storage retains device information and preferences
• Session Storage: Temporary data storage during browser session

We partner with service providers to analyze usage data and support marketing activities.

Website Advertising Notice: Our Websites do not serve targeted advertising. However, when you browse the internet, we and our partners may use tracking technologies to collect information about your online activities across websites. This data helps:

• Measure marketing effectiveness
• Analyze user engagement
• Improve service delivery

Currently, our Websites do not respond to "Do Not Track" browser signals.



We use and share your Personal Information for purposes noted at collection and as described below:

Website Operations:

• Maintain and administer Websites
• Ensure platform security
• Provide technical support
• Enable service delivery

Communications:

• Respond to inquiries
• Address support issues
• Share Website updates
• Request feedback
• Send service notifications

Business Operations:

• Support company reorganization
• Enable merger activities
• Facilitate business transfers
• Share with Primate Technologies LLC affiliated entities
• Engage professional advisors

Our legal basis for these practices, where required by law, includes:

• Fulfilling legitimate business interests
• Meeting contractual obligations
• Providing requested services
• Maintaining legal compliance

To review, correct, update, or request deletion of your Personal Information, contact privacy@primate-tech.com with your specific request.



To deliver our Websites and features, we engage third-party providers for:

• Cloud hosting services
• Analytics platforms
• Content delivery networks
• Infrastructure maintenance
• Email management
• Marketing operations
• Security monitoring

These providers may require limited Personal Information access to deliver their services.



Our Websites contain links to third-party sites, including social media platforms. We:

• Do not endorse linked websites
• Have no control over third-party privacy practices
• Recommend reviewing each site's privacy policy
• Are not responsible for external site content

We implement industry-standard safeguards:

• Physical security controls
• Administrative protocols
• Technical security measures

While we maintain reasonable security measures, no Internet transmission is completely secure. We cannot guarantee protection against unauthorized access beyond our reasonable control.



We retain Personal Information for:

• Website service delivery duration
• Legal compliance periods
• Industry standard timeframes
• Dispute resolution requirements
• Agreement enforcement needs

Retention period factors include:

• Data category and sensitivity
• Processing purpose
• Legal obligations
• Industry requirements
• Security compliance standards

Email Communications:

• Opt out via "unsubscribe" link in emails
• Reply "unsubscribe" to messages
• Contact privacy@primate-tech.com

Digital Marketing Preferences:

• Adjust privacy controls
• Select communication preferences

We do not send third-party marketing emails.



Certain US state laws, including California, provide their residents with certain rights related to their Personal Information, as described below. We provide these rights to all US residents. Before we may fulfill certain requests, we are required by law to verify your identity in order to prevent unauthorized access to your data, as described below.

Right to Know and Access: You have the right to request access to the Personal Information we maintain about you in the ordinary course of business. This may include Personal Information we collect, use, or disclose about you.

Right of Correction: You have the right to correct inaccuracies in the Personal Information we maintain about you. Right to Delete: You have the right to request that we delete your Personal Information.

Right to Opt Out of “Sale” or “Sharing” of Personal Information: You have the right to opt out of “sales” of Personal Information or “sharing” of Personal Information for cross-contextual behavioral advertising purposes (as these terms are defined under applicable law), which for our Websites essentially means transfer of your Personal Information to certain third parties for their or for others ‘ commercial purposes, including advertising and marketing purposes. You may opt out of this practice by clicking on the “Do Not Sell My Personal Information” link available here or on the footer of our Websites and follow the instructions.

In the case of all such requests, we may not fulfill all or part of the request as permitted or required by applicable law. For example, if you request that we delete your Personal Information, there may be certain records we are legally required to retain.

Verification

In the case of requests to know, correct, and delete in relation to our Websites, we must take reasonable steps to verify your identity before fulfilling your requests. For example, we may seek to establish your identity to a reasonable or a reasonably high degree of certainty by matching information that you submit alongside your request with information that we have in our records. We may ask you or your authorized agent for supplemental information as needed to establish your identity. Authorized agents may also be required to provide a copy of the consumer ‘s signed permission authorizing the agent to submit requests on the consumer ‘s behalf under applicable local law.

To Exercise Your Rights

To exercise the rights described above, please contact us at privacy@primate-tech.com. Should you have any questions or concerns regarding your privacy rights or this Privacy Policy, you may contact us at privacy@primate-tech.com.

Please note that your ability to exercise the above rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, we will notify you if we reject your request and notify you of any reasons we are unable to honor your request.

Non-discrimination

We do not discriminate or otherwise penalize anyone for exercising their rights under this Privacy Policy.

The chart below explains our Personal Information collection and sharing practices over the past 12 months.

Categories of Personal Information we may collect

• Identifiers such as your first and last name, work email address, organization type, and country, which is considered Personal Information under subdivision (e) of California Business and Professions Code Section 1798.80.
• Internet or other electronic network activity information related to your use of our Websites including your Internet Protocol address.
• Professional or employment-related information, including your job title, organization name, and state.
• If you choose to sign up to receive resource or newsletter updates, we will collect your email address.

We do not collect Sensitive Personal Information as it is defined under applicable law.

Categories of sources from which the Personal Information is collected
We collect the Personal Information directly from you including during the time you spend on the Websites.

Business or commercial purpose for collecting, “selling,” or sharing Personal Information
We collect your Personal Information to operate the Websites, respond to your requests and for the following business purposes:

• Maintaining or servicing the Websites and providing customer service.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• Sending you marketing communications.
• Inferences drawn from your use of our Websites are used by us and our third parties to support our marketing and remarketing efforts, and by third parties for their or others commercial interests, including to enable interest-based advertising.

Categories of third parties with whom we share or “sell” your Personal Information

• We may share your Personal Information - specifically your IP address, device ID, or similar online identifier, with certain third parties, such as social networks and advertising networks. This information may be used to inform the advertising you see after you've visited our Websites, which may constitute the "sale" of your Personal Information (as defined under applicable law).
• We may also share your Personal Information with our parent, subsidiaries, affiliates, and other related entities, such as those listed at https://www.solensoftwaregroup.com, and our advisors, including lawyers, consultants, accountants, and others for our lawful business purposes.

Specific pieces of Personal Information we have collected in the past 12 months.

• Internet Protocol address, device ID.
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with our Websites.
• First and last name, work email address, organization name, country, state, organization type, job role/title, phone.
• Any other information you choose to provide.

If you are located outside of the United States, please be aware that your information will be transferred to, processed, and stored in the United States.

When you access our Websites, we function as a “data controller” under the General Data Protection Regulation (“GDPR”). In some cases, we will ask for your consent so that we may process your Personal Information. In other circumstances, we may rely on a different lawful basis, as explained in the section, “How we Use and Disclose Your Personal Information.”

By submitting your Personal Information, you acknowledge that we may transfer, process and store your information in this way. Wherever the information is, it will be treated securely and in accordance with this Privacy Policy and applicable privacy laws of the United States. These laws may be different from the privacy laws in your country. However, this does not change our commitments to safeguard your privacy and we will comply with all applicable laws relating to the cross-border data disclosure of your Personal Information. Where required, we will implement Standard Contractual Clauses with our third parties or rely on such other transfer mechanisms to ensure that the transfer of your Personal Information outside of the EEA, UK, and Switzerland is lawful.


Primate Technologies LLC complies with the EU-US Data Privacy Framework (“EU-US DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-US DPF) (collectively, the “Frameworks”) as set forth by the U.S. Department of Commerce. Primate Technologies LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-US DPF Principles”) with regard to the processing of Personal Information received from the European Union in reliance on the EU-US DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-US DPF. Primate Technologies LLC has certified to the U.S. Department of Commerce that it adheres to the Swiss-US Data Privacy Framework Principles (“Swiss-US DPF Principles”) with regard to the processing of Personal Information received from Switzerland in reliance on the Swiss-US DPF. If there is any conflict between the terms in this Privacy Policy and the EU-US DPF Principles and/or the Swiss-US DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, please visit https://www.dataprivacyframework.gov.

In compliance with the EU-US DPF and the UK Extension to the EU-US DPF and the Swiss-US DPF, Primate Technologies LLC commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (“DPAs”) and the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (“GRA”) and the Swiss Federal Data Protection and Information Commissioner (“FDPIC”) with regard to unresolved complaints concerning our handling of Personal Information received in reliance on the respective Frameworks.

The Federal Trade Commission has jurisdiction over Primate Technologies LLC’s compliance with the Frameworks. Primate Technologies LLC will submit to binding arbitration in the event that a dispute can not be resolved by the aforementioned mechanisms. Primate Technologies LLC shall assume liability for any onward transfers of Personal Information made to third parties.


Please note that the rules in your country may provide you with additional rights or may limit these rights. In all cases, our provision of the rights will comply with the applicable laws.

If you are based in the EEA, UK, or Switzerland, for example, you may have the right to access, update or correct your Personal Information, to request deletion of such Personal Information, and to object to certain processing, including that related to marketing, to receive a machine-readable copy of the Personal Information concerning you that you provided to us or request us to transfer such data to an applicable third party in certain circumstances.

In addition, where you provided your consent for our processing of your Personal Information, you may withdraw your consent by contacting us using the details provided in the “Contact” section. You may also restrict how we use your Personal Information while a complaint is being investigated.

Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege).



As our Websites evolve, we may update this Privacy Policy. Changes will be communicated through Website notifications or as required by law. The "last updated" date at the top indicates the most recent revision. Updates become effective upon posting.



Questions about this Privacy Policy or concerns about Personal Information handling should be directed to:

Attn: General Counsel
Primate Technologies LLC
478 North Babcock Street, Suite 116
Melbourne, FL  32935