Primer CCPA Policy

Welcome to the Primer CCPA Policy. This CCPA Policy is incorporated by reference into the Primer Privacy Policy, found here, and applies only to California consumers and the Personal Information of California consumers. If you have any questions about whether this CCPA Policy applies to you, please contact us using the methods described in the Privacy Policy. Any capitalized terms not defined in this CCPA Policy have the same meaning given to them in our Privacy Policy and/or the CCPA.

Information We Collect

We have collected the following categories of Personal Information within the last 12 months:


name, business address, email address, telephone number, IP address, publicly visible social media identifiers (handles, user names/IDs, avatars, follower/following counts, publicly visible statuses or biographies)

Customer Record Information

financial information, bank account number, credit card number, debit card number

Commercial Information

Primer products and services you’ve purchased or considered purchasing

Internet or Electronic Network Activity

IP address, date and time of visits, pages viewed, links to/from any page, time spent at a site, hashed identifiers derived from email addresses for the purposes of cross-device tracking for targeted advertising, device identifiers and indicators

Geolocation Data

city, state, country, time zone,latitude and longitude data of the city center of the city in which a company is located

Professional or Employment-related Information

employer, industry, title, role, sub-role, seniority

Primer Labs Inc.

3895 Clay St.

San Francisco, CA, 94118


Use of Personal Information

Primer used or disclosed the Personal Information we collected for one or more of the following business purposes and objectives within the last 12 months:

• To directly respond to your requests or inquiries or to otherwise meet the reason for which you provided the information.

• For our internal operational and administrative purposes, maintaining and servicing your account with us, providing customer service, processing or fulfilling your orders and transactions with us, verifying your information, processing payments, and internal business functions such as accounting and forecasting.

• For auditing, security, debugging, maintaining the quality and safety of our services, and service performance purposes.

• To measure traffic and usage activity on our Site for purposes of improving and enhancing the functionality of our Site, to look for possible fraudulent activity, and to better understand the sources of traffic and transactions on our Site.

• To provide personalized and streamlined information across related pages on our Site by identifying whether you have visited specific pages on our Site or seen one of our advertisements.

• To undertake internal research and development of our Services.

• To comply with law, legal process, and internal policies and to exercise and defend legal claims.

• As described to you before or at the time of collection of your Personal Information, or as otherwise permissible under the CCPA.

Sharing and Selling

Disclosures for a Business Purpose

• Service providers who provide us with critical services such as web hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure (such as cloud computing), customer service, email delivery, security and other auditing, advertising or marketing, and similar services.

• Affiliates and contractors, and similar affiliated entities or individuals.

Categories of Personal Information that we have disclosed for a business purposes within the last 12 months include: identifiers; customer record information; commercial information; internet or electronic network activity; geolocation data (only at the city, state, and country level, and only for Companies, not Professionals or individuals); and professional or employment-related information.

Disclosures or "Sales" for a Commercial Purpose

Primer does not sell or rent to any third party any of the personal information or data of our users.

However, in order to provide business-to-business marketing data as part of the Services, we make available to our customers and partners third-party data. We also participate in some digital advertising networks ("Ad Networks") with which we share certain information collected through cookies and other tracking technologies and receive back similar information from other participants in the Ad Networks, as well as analytics about the information we share with the Ad Networks. Within the last 12 months, we have disclosed the following categories of Personal Information in a manner that may be considered a "sale" as defined in the CCPA: identifiers, commercial information, internet and other electronic network activity, geolocation data (only at the city, state, and country level, and only for Companies, not Professionals or individuals), and professional and employment-related information.

You may opt-out of the "sale" of your Personal Information on a going-forward basis by contacting us at:

Primer Labs Inc.

3895 Clay St.

San Francisco, CA, 94118


Individual Rights

The CCPA provides California consumers with several individual rights with respect to Personal Information. Note that these rights apply to individual consumers, not to Companies. This section describes those rights in detail and provides information on how to exercise those rights

Exercising Your Rights

To exercise any of the rights described in this section, please contact us at with (i) a complete description of your request, including the specific right(s) you wish to exercise and (ii) sufficient information about you so we can confirm that your request is a verifiable customer request, including at a minimum your name and email address. Once we have received your verifiable consumer request, we will respond consistent with applicable law. Please note that you may also designate an authorized agent to make a request on your behalf. In order for us to process a request from your authorized agent, we must (i) confirm that the agent is a natural person or business entity registered with the Secretary of State that you have authorized to act on your behalf, (ii) receive from you a copy of the written authorization that provides the authorized agent to act on your behalf, and (iii) verify your identity by asking you to provide us sufficient information in order to do so.

Access and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of Personal Information within the last 12 months: (1) categories of Personal Information we collected about you; categories of sources of Personal Information we have collected about you; our business or commercial purpose for collecting that Personal Information (if applicable); categories of Personal Information we have made available to our customers or partners, if any; and categories of Personal Information we disclosed to service providers or third parties, and the categories of those parties, for a business purpose, if any; and (2) the specific pieces of Personal Information we have collected about you in a readily useable format that allows you to transmit it to another entity. Please note that, with respect to the information described in (1), it will be the same information as can be found in our Privacy Policy (including this CCPA Policy).

Deletion Rights

You have the right to request that we delete Personal Information about you that we have collected, subject to certain exceptions.

Right to Opt-Out of Sales of Personal Information

You have the right to direct us not to sell your Personal Information on a going-forward basis. Please contact us with the information provided above to manage your opt-out preferences with respect to this right.


You have the right not to receive discriminatory treatment for the exercise of your rights under the CCPA, subject to certain limitations. Please note that we reserve the right to offer you certain financial incentives as permitted by the CCPA that may result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time by contacting us.

Changes to this CCPA Policy

We reserve the right to amend this CCPA Policy at our discretion and at any time. When we make changes to this CCPA Policy, we will post the updated notice on the Site and update the CCPA Policy effective date at the top of the page. By accessing or using the Site and/or the Services, you acknowledge that you have read this CCPA Policy and, to the extent it applies to you, that you agree to the practices described in this CCPA Policy.

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