Privacy Policy

Privacy Policy

Last Updated: June 31, 2023

At Primis, we believe that you have a right to know about the information we collect from you. This Privacy Policy describes the types of information about you that Primis Inc. (“Primis”, “we”, “us”, and “our”) collects, uses, and shares when you visit our websites, applications, or website features you use or access (collectively, the “Sites”), as well as any mobile applications (each, an “Application” and together with the Sites and Applications, our “Services”) that link to or make this Privacy Policy available to you. 

By using our Services, you consent to the practices set forth in this Privacy Policy, which is incorporated into our Terms of Use.

Please note that this Privacy Policy does not govern the information we process on behalf of our Resale-as-a-Service (RAAS) clients.  For details about our processing of information on their behalf, please see the “Information Collected on Behalf of our RaaS Clients” section below.

This Privacy Policy has been designed to be reasonably accessible to people with disabilities.  If you experience any difficulties accessing the information in this Privacy Policy, please email us at privacy@Primismedical.com.

  1. NOTICE AT COLLECTION
  2. CATEGORIES OF INFORMATION WE COLLECT
  3. CATEGORIES OF SOURCES
  4. PURPOSES FOR COLLECTION AND USE
  5. CATEGORIES OF PARTIES TO WHOM WE DISCLOSE INFORMATION
  6. DATA RETENTION
  7. YOUR RIGHTS AND CHOICES
  8. NOTICE TO NON-US RESIDENTS
  9. HOW WE PROTECT INFORMATION AND INFORMATION SECURITY
  10. CHILDREN
  11. UPDATING AND REVISING THE PRIVACY POLICY
  12. QUESTIONS?

1. Notice at Collection

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you (“Personal Information”). 

The categories of Personal Information we collect include Personal Identifiers, Financial Information, Communication Information, Commercial Information, General Location Information, Demographic Information, Online Identifiers, Audio Information, Inferences, and Employment-Related Information. For more information on the categories of Personal Information we collect, review the “Categories of Information We Collect” section below.

The purposes for collecting and using the above categories of Personal Information is described in the “Purposes for Collection and Use” section below.

We sell and share the following categories of Personal Information for targeted advertising: Personal Identifiers, Commercial Information, Online Identifiers, General Location Information, Demographic Information, and Inferences. If you would like to opt-out of the sale or sharing of these categories of personal information, please contact us at info@primismedical.com. 

We retain your information as set out in the “Data Retention” section below.

2. Categories of Information We Collect

The categories of personal information (together “Personal Information”) we have collected over at least the last 12 months includes the following:

  • Personal Identifiers – such as your name, gender, email address, mobile phone number, account credentials, and your shipping and billing address
  • Financial Information – such as your credit card information when completing an order
  • Communication Information – such as when you reach out to us with questions or concerns, or when you voluntarily respond to our requests seeking your opinion and feedback
  • Commercial Information – such as the products or services you have purchased and your purchasing history or tendencies
  • General Location Information – such as location derived from an IP address or data that indicates a city or postal code level
  • Demographic Information – such as your age, age range or birth day
  • Internet or other electronic network activity information (Online Identifiers) – such as your browser information, operating system information, device information, IP address, and the date, time, length of stay and your browsing/search history, including the specific pages accessed during your interactions with the Services
  • Audio Information – such as when we collect voice recordings if you contact us for customer service
  • Inferences – drawn from the categories of Personal Information listed above in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, predispositions, behavior, and attitudes.
  • Employment-Related Information – such as your employment and education history, resume, cover letter, transcript, writing samples, and references as necessary to consider you for job openings
  • Additional Information– In addition to the information described above, we may collect certain information about your use of our online services.  For example, we may capture the IP address of the device you use to connect to the online service, the type of operating system and browser you use, and information about the site you came from, the parts of our online service you access, and the site you visit next. We or our third-party partners may also use cookies, web beacons or other technologies to collect and store other information about your visit to, or use of, our online services.  In addition, we may later associate the usage and other information we collect online with personal information about you.

We also aggregate your Personal Information, including with information collected from other users, to (i) provide you with a better experience, (ii) improve the quality and value of the Services, (iii) analyze and understand how our Services are used, and (iv) as otherwise permitted by law. We may collect, use and share de-identified information except as prohibited by applicable law. Where required by law, we will maintain and use such de-identified information in de-identified form and will not attempt to re-identify the information, except to make sure the information is truly de-identified.

3. Categories of Sources 

We may collect your information in the following ways:

WHEN YOU PROVIDE US WITH INFORMATION TO MAKE A PURCHASE, SUBMIT A CLEAN OUT BAG, OR SIGN UP FOR PRIMIS SALES

If you use our Services to make a purchase or sign up for Primis Auctions we collect Personal Identifiers, Financial Information, Communication Information, Commercial Information, General Location Information, Demographic Information, and Online Identifiers, for the purpose of facilitating current and future transactions. In an effort to facilitate your payments, we collect certain financial information from you, such as your payment card number and authentication details. We use a payment processor so that we do not need to maintain your credit card information other than in a tokenized form.  By making a purchase through the Services or signing up for Primis Auctions, you give us consent to use and provide your financial information as we consider necessary to process the transaction.

FROM COMMUNICATIONS YOU INITIATE WITH US

If you contact us in person, by phone, email, instant message, live chat, social media, or by some other means (either through our Services or through another entity), we may collect and keep a record of your Personal Identifier, Communication Information, Commercial Information, Demographic Information, Online Identifiers, and Audio  Information. 

FROM SOCIAL MEDIA AND OTHER PLATFORMS

If you create your Primis account by connecting through another entity, such as Amazon or Facebook, you are authorizing us to use Personal Identifiers, Demographic Information, and Online Identifiers from that connected account to help complete your Primis profile. We collect and store this information and use it to help you connect to our Services. Connecting your Primis account to one of these entities is completely optional, and you will have the opportunity to grant permission when you attempt to connect. Please remember that the manner in which these entities  use, store, and disclose your information is governed by the policies of such entities. We recommend that you review the terms and policies of that entity, including its privacy and data practices. Primis has no liability or responsibility for the privacy practices or other actions of any of these entities or other  sites or services not owned and operated by Primis that may be enabled within the Services.

We also collect information from websites that include the Primis widgets on their sites. When you load a site that includes our widgets, we receive analytics information through a cookie and that information is used in accordance with this Privacy Policy, including to enhance our data and to improve our Services. 

INFORMATION WE AUTOMATICALLY COLLECT

Like most websites, and as mentioned above, our Services incorporate tracking technologies such as “pixel tags”, “web beacons” and “cookies” which allow us to track Personal Identifiers, Commercial Information, Communication Information, Online Identifiers, Inferences, and General Location Information about our users across time and services. Pixel tags or web beacons are tracking technologies on websites, ads, and in emails that can monitor the behavior of the user visiting the website, viewing the ad, or receiving the email. Cookies are small files placed on your computer that recognize you when you return to Primis and that allow us to customize your user experience, deliver relevant ads, and improve the Services. You may modify the cookies that are accepted by your computer by changing your browser settings, or by clicking ‘Manage Preferences’ in the cookie banner popup that appears on your screen, although this may change how the Primis website is presented to you. In some instances, other companies’ use of their cookies is subject to their own privacy policies, and we encourage you to review their policies to better understand their data practices

As an example, Primis uses cookies to keep track of your shopping cart and for other personalized experiences. We also use tracking technology to create remarketed user audiences based on visitor behavior on our Services. Primis may also deliver custom ads based on your Inferences, General Location Information, and Demographic Information. In particular, Primis may use other companies or services such as Google Analytics to monitor activity on the Services and to assist with advertising. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at https://www.google.com/policies/privacy/partners/.

Interest-Based Advertising 

Primis uses the information you make available to us when you interact with our Services to provide you with advertising and offers that are more relevant to you. We also partner with third-party advertising companies to provide advertisements on our Services and other sites about goods and services that may be of interest to you, including advertisements for unaffiliated products and services on our Services. The advertisements may be based on information collected through cookies, web beacons, and other tracking technologies from our Services.  These third parties may use persistent identifiers to track your Internet usage across other websites and mobile applications in their networks beyond these Services. 

To learn more about third-party advertising companies and the options available to limit their collection and use here:

Learn about your options to opt out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device. For more information about how to change these settings go to:

Please note that opting-out of advertising networks services does not mean that you will not receive advertising, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms.

BLOGS, REVIEWS AND TESTIMONIALS

The Services may from time to time offer publicly-accessible blogs, customer reviews or testimonials. Any information you provide in these areas may be read, collected and used by us and others who access them. To request removal of your Personal Information from our blogs, customer reviews or testimonials, please contact us at privacy@Primismedical.com. Please note that in some cases we may be unable to remove your Personal Information.

PUBLICLY AVAILABLE SOURCES

For example, we collect information in the public domain, data available in open government databases, and as otherwise permitted by law.

VENDORS

We receive information from our vendors. For instance, we may engage with vendors and service providers to collect or provide us with information about you, such as access to location services via wireless networks or cell towers near your mobile device, or your IP address. Our employment and recruiting vendors also give us information. Our marketing agencies, advertising technology vendors, and analytics providers may also provide us with information. 

COMBINING INFORMATION

We may combine information we have collected offline with information we collect online. We may combine information we get from another party with information we already have. We may also aggregate your information with other consumers’ information to understand preferences and trends over time.

INFORMATION COLLECTED ON BEHALF OF OUR RETAIL AS A SERVICE CLIENTS

We provide products and services to our RaaS clients, and collect and process information about individuals (including through tracking technologies) at the direction of our clients (“RaaS Client Data”). When we operate on behalf of our RaaS clients, we are acting at their direction as a service provider.  We are not responsible for the privacy practices of our RaaS clients, and we recommend you review their own privacy policies for information on their data processing activities. 

4. Purposes for Collection and Use

In the past twelve months we have used the categories of information described above in the following ways:

We use Personal Identifiers, Communication Information, Commercial Information Online Identifiers, and General Location Information to: (i) provide or enhance our Services and evaluate the effectiveness of our partnerships; (ii) provide you with additional services related to our Services and the Primis Sale program; (iii) conduct quality assurance testing; (iv) facilitate creation of accounts; (v) provide technical support and/or monitor the security of our Services; (vi) advertise and market the Services; (vii) facilitate business partnerships with trusted partners; (viii) to provide other services requested by you; (ix) respond to comments, requests, or questions from you; (x) manage your purchases, Clean Out Bag requests and submissions, and refunds; (xi) personalize your experience with us, including promotional communications sent through email and text messages; and (xii) inform you about new products, features, updates, and special promotions, including third-party offers or products we think you might find interesting. 

We use Financial Information to (i) manage your purchases, Clean Out Bag requests and submissions, and refunds; and (ii) provide you with customer service.

We use Demographic Information to (i) provide and enhance you our Services, additional services related to our Services, and the Primis Sales program; (ii) facilitate creation of accounts; (iii) advertise and market the Services; and (iv) personalize your experience with us, including promotional communications sent through email and text messages.

We use Inferences to (i) provide and enhance our Services, (ii) provide you with additional services related to our Services; (iii) advertise and market the Services; (iv) facilitate business partnerships with trusted partners, (v) personalize your experience with us, including promotional communications sent through email and text messages; and (vi) inform you about new products, features, updates, and special promotions, including third-party offers or products we think you might find interesting.

We use Audio Information to provide you with customer support and for internal research and analytics.

We use Employment-related Information to (i) process your application for a job with Primis; (ii) conduct a background check (prior to onboarding you as an employee with Primis); and (iii) conduct internal research and analytics.

We may also use all of the categories of Personal Information noted above as we believe necessary:

  • to verify your identity or determine your eligibility for some of our products, services, and promotions. For example, this may include verifying your age, date of birth, and state of residence;
  • if we determine a policy violation has occurred, to enforce our rights, or to enforce agreements;
  • to protect against unauthorized access to our systems or other inappropriate use of our Services, including protecting the safety of our company, our Services, consumers who use our Services, and others;
  • to comply with laws, regulations, court orders and subpoenas or similar requests for information by authorities;
  • to perform audits;
  • to contact you about Services or policy updates;
  • for research and analytics, including to identify usage trends, and to improve and update our products and services;
  • to assist us in fraud prevention or investigation, all on the basis of our legitimate interest in the continuation of our commercial activities and the protection of our rights; and
  • for purposes otherwise permitted by law or as we may notify you and obtain your consent.

5. Categories of Parties to Whom We Disclose Information

During at least the past 12 months, we have disclosed the information described above with the following categories of entities:

AGENTS

We provide all categories of Personal Information described above to our employees, contractors, commercial partners, agents, service providers and designees (“Agents”) where necessary to enable them to perform certain services for us including without limitation: order fulfillment, payment processing, Clean Out Bag processing, website-related services such as web hosting, database management, improvement of website-related services and features, maintenance services and distribution of offers, business partnerships, partner promotions, advertisements and other marketing materials on our behalf.

BUSINESS TRANSACTIONS AND TRANSFERS

If we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Primis customer information (including all categories of Personal Information described above) will likely be shared for evaluation purposes and included among the transferred business assets. If an acquirer that has assumed all or part of our business materially alters how it uses or shares your Personal Information than at the time of initial collection, the acquirer will provide prior notice of the new or changed practice as required by law.

COMPLIANCE WITH LAWS AND LAW ENFORCEMENT

Primis cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose all categories of personal information described above to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process, to protect our rights or the rights of our users or others, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be illegal, unethical or legally actionable activity, including but not limited to third party intellectual property infringement. We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to accomplish the foregoing.

THIRD PARTIES

We sell and share Personal Identifiers, Commercial Information, General Location Information, Online Identifiers, and Inferences with third parties, such as our advertising and marketing partners, for targeted advertising. To opt-out of the selling and sharing of these categories of Personal Information with third parties for targeted advertising purposes, click here. 

We may also provide all categories of entities noted above with de-identified or aggregate information for any purpose not prohibited by law, including the creation of aggregate reports indicating the demographic information of users on our Services, buying behavior, and opportunities to market to select segments of our users indirectly. When we share de-identified or aggregate information, it is done in a way that cannot identify you.

6. Data Retention

We keep Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting, or other purposes), whichever is longer. Where we have no continuing purpose to process the Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because the Personal Information has been stored in backup archives), then we will securely store the Personal Information and isolate it from any further processing until deletion is possible.

7. Your Rights and Choices

Where provided for by law and subject to any applicable exceptions, you have the right:

  • To know the categories of Personal Information that we have collected about you, the business or commercial purpose for collecting or selling your Personal Information, and the categories of sources from which the Personal Information was collected;
  • To access the specific pieces of Personal Information that we have collected about you;
  • To know whether we have disclosed your Personal Information for business purposes or have sold your Personal Information, the categories of Personal Information so disclosed or sold, and the categories of third parties to whom we have disclosed or sold your Personal Information;
  • To have us, under certain circumstances, delete your Personal Information;
  • To  have us, under certain circumstances, correct your Personal Information;
  • To opt out of the sale and sharing of Personal Information for targeted advertising. We may sell or share the following categories of Personal Information to companies that provide marketing and advertising services to us: Personal Identifiers, Commercial Information, Online Identifiers, General Location Information, Demographic Information, and Inferences; and
  • To be free from discrimination related to the exercise of these rights.

EXERCISING YOUR RIGHTS

The listed privacy rights are available to all of our customers, regardless of where they live. If you would like to exercise any or all of these rights, you may do so by accessing our tools at primismedical.com/privacy , emailing us at privacy@Primis.com, or by completing the “Do Not Sell or Share My Personal Information” form. We honor opt-out signals sent via the Global Privacy Control, as well as any other recognized browser-based opt-out signal. If you use an opt-out preference signal, we will apply the opt-out to the device or browser which sends the opt-out preference signal and to any consumer profile associated with that browser or device, including pseudonymous profiles. You can use an opt-out preference signal by downloading a supported browser or extension.  If known, we will also treat the opt-out preference signal as a valid request to opt-out of sale/sharing for the user. Some browsers allow you to send a Do Not Track signal, an older request to block tracking of users by third parties. We may not honor these older signals. We acknowledge that you may also have rights in connection with the Personal Information we process on behalf of our RaaS clients. If Personal Information about you has been processed by us as a service provider on behalf of a RaaS client and you wish to exercise any rights you have with such Personal Information, please inquire with our RaaS client directly. We will support them to the extent required by applicable law in responding to your request.

VERIFICATION

After we receive your request to know, delete, or correct, we may request additional information from you to verify your identity. If we cannot verify your identity, we will not honor your request.

AUTHORIZED AGENTS

Your authorized agent may submit requests in the manner described above, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request. 

Please contact us with questions or to request access to an alternative format of this Privacy Policy.

NOTICE OF FINANCIAL INCENTIVES

Financial incentives, as defined under the U.S. state privacy laws, include “programs, benefits, or other offerings, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information about them.”  Although we do not consider our discounts and offerings to be “financial incentives,” each may be interpreted to be one under California law.

We offer discounted prices to consumers who sign up for our offerings and voluntarily provide us with certain requested personal information to be used in accordance with this Privacy Policy.  For example, as part of Primis Sales you may choose to voluntarily provide us with your birthday so that we may send you a special reward on your birthday.  You can opt-in by submitting the requested personal information. You can withdraw your consent at any time by emailing us at privacy@Primis.com with “Opt-out of Financial Incentives” in the subject line.

We generally do not treat consumers differently if they exercise a privacy right under U.S. privacy laws. However, you will need to provide some personal information in order to receive certain discounts or benefits. In such circumstances, we offer a price difference that is reasonably related to the value of your data to us in connection with the discount or benefit.

APPEALS

You may have a right to appeal decisions concerning your ability to exercise your consumer rights. To submit an appeal, please email us at info@primismedical.com

“SHINE THE LIGHT” LAW

If you are a California resident, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please email us at info@primismedical.com and indicate in your email that you are a California resident making a “Shine the Light” inquiry.

ACCOUNT INFORMATION

You can visit the account section of the Services to access, remove, or update certain account information we have on file about you and that you have submitted through the Services. Please note that if you ask us to remove information, we will remove it from consumer-facing parts of the Services but may continue to store and use the information for internal analytics purposes or as otherwise permitted under applicable law. We will retain and use your information as necessary to comply with our legal obligations or data retention policies, resolve disputes, and enforce our agreements.

PROMOTIONAL COMMUNICATIONS

  • Emails. You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at privacy@Primis.com. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations. Your opt-out is limited to the email address used and will not affect subsequent subscriptions.
  • Text messages. For text message communications and calls to your phone number, you may opt-out at any time by texting STOP, QUIT, UNSUB, or UNSUBSCRIBE to the appropriate shortcode available from our confirmation text message. If you unsubscribe from one of our text message programs, you may continue to receive text messages from Primis through any other programs you have joined until you separately unsubscribe from those programs. For more information about our text messaging activities, please review our SMS Policy.
  • Push notifications. For push notifications or in-app messages, you may adjust the permissions in your mobile device or uninstall our app.

8. Notice to Non-US Residents

INTERNATIONAL USERS CONSENT TO TRANSFER

The Services are hosted in the United States. If you are visiting the Services from outside the United States, your information may be transferred to, stored and processed in the United States in accordance with this Privacy Policy and applicable United States laws. Please note that data protection and other applicable laws of the United States may not be as comprehensive as those laws or regulations in your country or may otherwise differ from the data protection or consumer protection laws in your country. By using the Service, you consent to the transfer of your information to our facilities as described in this Privacy Policy.

9. How We Protect Information and Information Security

We use administrative, technical, and physical safeguards to protect Personal Information, taking into account the nature of the Personal Information processing, and the threats posed.

Without limiting the terms of our Terms of Use and this Privacy Policy, you understand that we do not guarantee that your use of the Services and/or information provided by you will be private or secure and we are not responsible or liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the Services. You also understand that any information provided by you or collected by us or our Agents in connection with your use of the Services will be used in the manner described in our Terms of Use. Any information that you provide to us is done so entirely at your own risk. Please do not use the Services if you do not agree to the terms and conditions described in this Information Security section. 

10. Children

The Services are intended for a general audience and not directed at children. Specifically, Primis does not sell products for purchase by children. We sell children’s products for purchase by adults. We do not knowingly collect information from children under the age of 13, in accordance with the Children’s Online Privacy Protection Act. We do not knowingly “sell” or “share” or process for targeted advertising (as those terms are defined under U.S. state privacy laws), the personal information of minors under 16 years old.

If you have questions concerning our practices, please email us at info@Primis.com.

11. Updating and Revising Privacy Policy

We review this Privacy Policy at least once every 12 months to make sure it complies with applicable law and conforms to changes in our business. We may need to update this Privacy Policy, and we reserve the right to do so at any time. If we do revise this Privacy Policy, we will update the “Last Updated” at the top of this page so that you can tell if it has changed since your last visit. Please review this Privacy Policy regularly to ensure that you are aware of its terms. Your use of Services constitutes your acceptance of the terms of the Privacy Policy as amended or revised by us from time to time.

12. Questions?

If you have any questions, please contact using the following information:

Primis Inc.

Attention: Privacy Policy

854 West 450 North Suite 9

Kaysville, UT 84037

By email: info@Primismedical.com