Privacy Policy

Last Updated: 19 December 2025

PRIMO ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and share your personal information when you visit our website at joinprimo.co.uk (the "Website").

1. Information We Collect

1.1 Information You Provide

When you sign up for early access or subscribe to our mailing list, we collect:

• Email address
• Any other information you choose to provide

1.2 Information Collected Automatically

When you visit our Website, we automatically collect certain information about your device and browsing behaviour through cookies and similar technologies:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Information: Pages visited, time spent on pages, scroll depth, click interactions, referring website
• Location Information: Approximate geographic location based on IP address

2. How We Use Your Information

We use the information we collect for the following purposes:

• To communicate with you about PRIMO products and updates
• To provide early access notifications and launch information
• To analyse and improve our Website performance and user experience
• To measure the effectiveness of our marketing campaigns
• To comply with legal obligations

3. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect information about your browsing activities. You can control cookie settings through our cookie consent banner and your browser settings.

3.1 Essential Cookies

These cookies are necessary for the Website to function properly and cannot be disabled.

3.2 Analytics Cookies

Google Analytics 4 (GA4): We use GA4 to understand how visitors interact with our Website. GA4 collects information such as pages viewed, time spent on site, and user interactions. This data is anonymised and aggregated. Google may also use this data in accordance with their own privacy policy.

• Provider: Google LLC
• Purpose: Website analytics and performance measurement
• Data retention: 14 months (configurable)
• Learn more: Google Privacy Policy

3.3 Marketing Cookies

Meta Pixel: We use the Meta Pixel (Facebook Pixel) to measure the effectiveness of our advertising campaigns on Meta platforms (Facebook and Instagram). The Pixel collects information about your visit and interactions with our Website, which helps us:

• Measure and optimise the performance of our advertisements
• Build audiences for future advertising campaigns
• Understand user behaviour across Meta platforms and our Website

Information collected by Meta Pixel may include:

• Button clicks and page views
• Device information and browser data
• IP address and user agent
• Meta user ID (if you're logged into Facebook or Instagram)

Meta may use this data in accordance with their own privacy policies and terms.

• Provider: Meta Platforms Ireland Limited
• Purpose: Advertising measurement and targeting
• Learn more: Meta Privacy Policy
• Opt-out: Facebook Ad Preferences

4. Legal Basis for Processing (GDPR)

Under the UK General Data Protection Regulation (UK GDPR), we process your personal information based on the following legal grounds:

• Consent: When you provide your email address or accept cookies, you give us explicit consent to process your data
• Legitimate Interests: We have a legitimate interest in analysing Website performance and improving user experience, provided this does not override your privacy rights
• Legal Obligation: We may process data to comply with legal requirements

5. Data Sharing and Third Parties

We share your information with the following third-party service providers who process data on our behalf:

• Google (GA4): Website analytics
• Meta: Advertising measurement and targeting
• Webflow: Website hosting and form management
• Email service provider: [To be confirmed - e.g., Mailchimp, ConvertKit]

These service providers are contractually obligated to protect your data and use it only for the purposes we specify. We do not sell your personal information to third parties.

5.1 International Data Transfers

Some of our service providers are based outside the UK and European Economic Area (EEA). When we transfer your data internationally, we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by the UK Information Commissioner's Office
• Adequacy decisions recognising equivalent data protection standards
• Privacy Shield frameworks (where applicable)

6. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes outlined in this Privacy Policy:

• Email addresses: Until you unsubscribe or request deletion
• Analytics data: 14 months (GA4 default)
• Cookie data: As specified in individual cookie settings (typically 6-24 months)

7. Your Rights Under UK GDPR

You have the following rights regarding your personal information:

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data ("right to be forgotten")
• Right to Restrict Processing: Request limitation on how we use your data
• Right to Data Portability: Request transfer of your data to another service provider
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Withdraw consent at any time (without affecting prior processing)

To exercise any of these rights, please contact us using the details below.

8. Cookie Management

You can manage your cookie preferences through:

• Our cookie consent banner (displayed on your first visit)
• Your browser settings (to block or delete cookies)
• Third-party opt-out tools:
  • Google Analytics: GA Opt-out Browser Add-on
  • Meta Advertising: Facebook Ad Preferences

Please note that disabling cookies may affect Website functionality and your user experience.

9. Data Security

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Secure SSL/TLS encryption for data transmission
• Access controls and authentication
• Regular security assessments
• Secure data storage with trusted providers

However, no method of transmission over the Internet is 100% secure, and we cannot guarantee absolute security.

10. Children's Privacy

Our Website is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The "Last Updated" date at the top of this page indicates when the policy was last revised. We encourage you to review this policy periodically.

12. Contact Us

13. Complaints

If you are unhappy with how we have handled your personal information, you have the right to lodge a complaint with the supervisory authority: