Privacy Policy

Acceptance of Privacy Policy

Primero Systems Inc. (“Primero Systems”, “we,” “our,” or, “us”) is committed to protecting the privacy of its users. We provide this Privacy Policy to explain how we collect, use, protect and disclose information and data when you use the website (“Website”). This Privacy Policy also explains your choices for managing information preferences, including opting out of certain uses of your Personal Information (defined below).  This Privacy Policy applies to all users of the Website.

Please review the following statement to understand how the information you provide to Primero Systems through our Website will be treated.


Personal Information

We collect the following categories and types of “Personal Information”:

Contact and Demographic Information: We collect your contact and demographic information only as applicable, potentially including, but not limited to, your name, city and state, e-mail address, company name, and phone number.

Other Identifying Information: We collect other identifying information including IP address and cookies or other persistent online identifiers only as applicable.

Internet or Other Electronic Activity: Your browsing and click history, including information about how you navigate within our Website and which elements of our Website you use the most.

Sources of Personal Information

We collect Personal Information from the following sources:

We collect information directly from you: When you contact us, we collect contact and demographic information directly from you (only if applicable). We also collect content of any correspondence between you and us.

We collect Information about you from third parties: If you are referred to our website via a third party we will determine the referring site (e.g. a search engine, or media piece).

We collect Information about you passively: We collect internet or other electronic activity passively using tools like browser cookies. This activity is further described in the Cookies section below.

What Primero Systems does with the Information it collects

Primero Systems collects information for the following purposes:

Transactional Purposes: We use your contact information, and demographic information to receive, process, confirm and communicate with you.

Analytical Purposes: We use your other identifying information, if provided, such as internet activity and browsing history to analyze preferences, trends, and statistics.

Maintenance and Improvement of the Website: We use your contact information, if provided, as well as internet activity and browsing history on our Website to provide you with the Website. This includes handling your customer service requests and helping us diagnose technical and service problems to administer our Website.

Security and Fraud Prevention: We use your contact information, if provided, as well as other identifying information including internet activity and browsing history on our Website to protect the Website, Primero Systems, and others, and to prevent fraud, theft and misconduct.

Categories of Third Parties to Which We Share Personal Information

Primero Systems provides information as applicable to the following third-party entities:

Our Affiliates: We may share Personal Information with businesses controlling, controlled by, or under common control with Primero Systems.

Corporate Transactions: If Primero Systems is merged, acquired, or sold, or in the event of a transfer of some or all our assets, we may disclose or transfer Information in connection with such transaction.  You will have the ability to opt out of any such transfer if, in our discretion, it will result in the handling of your Information in a way that differs materially from this Privacy Policy.

Compliance with Laws and Law Enforcement We cooperate with government and law enforcement officials and private parties to enforce and comply with the law.  We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of Primero Systems or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.

Cookies: A cookie is a small data file that certain Web sites write to your hard drive when you visit them. A cookie file may contain information such as a user ID that the site uses to track the pages you’ve visited. However, the only personal information a cookie will contain is information you supply yourself. A cookie cannot read data off your hard disk or read cookie files created by other sites. Primero Systems uses cookies to tell when a user is a repeat visitor and to let us know how the user found the site. This helps us better understand and improve areas of the site that our users find valuable.

If you’ve set your browser to warn you before accepting cookies, you will receive the warning message with each cookie. Visitors to the Website always have the option of disabling cookies via their browser preferences. You may refuse cookies by turning them off in your browser.

Google Analytics: We use Google Analytics on the Website to analyze how users use the Website.  For more information about how to opt out of having your information used by Google Analytics, visit

Managing Your Information Preferences

You may review, correct, update, or change your Personal Information or opt out of receiving certain e-mails by e-mailing us at  If you have questions or concerns regarding this Privacy Policy, please e-mail us at that same address.

Be Careful When You Share Information with Others

Please be aware that whenever you share information on any public area of the Website, that information may be accessed by others.  In addition, please remember that when you share information in any other communications with third parties, that information may be passed along or made public by others.  This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.


All your personal information is stored on servers at a location designed specifically to ensure that no unauthorized individuals have access to the server or its data.  We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us.  However, no data transmission over the Internet or other network can be guaranteed to be 100% secure.  As a result, while we strive to protect information transmitted on or through the Website, we cannot and do not guarantee the security of any information you transmit on or through the Website, and you do so at your own risk.


Our Website may contain links to other websites.  A link to a third party’s website does not mean that we endorse it or that we are affiliated with it.  We do not exercise control over third-party websites.  You access such third-party websites or content at your own risk.  You should always read the privacy policy of a third-party website before providing any information to the website.

Privacy of Children

We do not knowingly collect any personal information from children under the age of 18. If a parent or guardian believes that their child has provided us with personal information without consent, please contact us by using the information below, and we will use our best efforts to delete such information from our systems.

Processing in the United States

Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country.  If you are located outside of the United States, please be advised that we process and store all information in the United States.  The laws in the United States may not be as protective of your privacy as those in your location.  By using the Website, you are agreeing to the collection, use, transfer, and disclosure of your Personal Information and communications will be governed by the applicable laws in the United States.

Special Notice to California Residents/Your California Privacy Rights

If you are a California resident, you have certain privacy rights under the California Consumer Privacy Act (“CCPA Rights”). This Section describes those rights and how you can exercise them with Primero Systems.

CCPA Rights Requests

Right to Know

You can request what Personal Information we have collected about you in the preceding 12 months. You can request the specific pieces of Personal Information we have collected about you. You can also request the following categories of information:

  • The categories of Personal Information we have collected about you.
  • The categories of sources from which the Personal Information was collected.
  • The business or commercial purpose for collecting or selling the Personal Information.
  • The categories of third parties with whom we shared Personal Information.

Right to Deletion

You can also request that we delete your Personal Information. We may not delete all your Personal Information if one of the following exceptions applies:

  • Transactional: to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or perform a contract we have with you.
  • Security: to detect and prevent data security incidents.
  • Error Correction: to debug or repair any errors.
  • Legal: to protect against fraud or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech.
  • Internal Use: to use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e., to improve our services).

We will also maintain a record of your CCPA Rights requests.

Exercising your Rights

To exercise your right to know or delete your Personal Information, submit a verifiable consumer request to us by emailing us at or sending your request to:

Primero Systems Inc.
11440 West Bernardo Court, Suite 300
San Diego, CA 92127

Your verifiable consumer request must provide sufficient identifying information (including full name, postal address, and email address) to allow us to reasonably verify you are the person about whom we collected and retained Personal Information, and/or your authority to make such request on behalf of the data subject. Additionally, you or your authority must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Note that we will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request or to review and comply with the request.

You may authorize someone to act as your agent and submit a request on your behalf. Due to the sensitivity of such requests, you must verify the agent’s authorization before we will act. Accordingly, you or your agent must supply written permission for a specific agent to act on your behalf and we will use your email address to connect directly with you to verify agent identity and authority.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm with a level of confidence appropriate to the sensitivity of the information that the Personal Information we have collected and retained in our systems and databases relates to you.

Do Not Sell My Personal Information

We do not currently “sell” your Personal Information, as that term is defined under the CCPA.

Right to Opt Out of Sale

California residents have the right to opt out of the sale of your Personal Information to third parties, as “sale” is defined under CCPA.

Please note that Primero Systems does not presently share personal information within the meaning of “sale.” However, if you would like to opt out of the “sale” of your personal information as permitted under CCPA in the event we do “sell” personal information in the future, you can do so, and we will keep a record of this request.

To submit a request to opt out of the sale of your Personal Information, please email us at You must use “California Opt Out from Sale” in the subject line of your email and provide us with your full name and email address. To designate an authorized agent to act on your behalf, you must send a signed, written authorization containing your first name, last name, email address, and phone number to:

Primero Systems Inc.
11440 West Bernardo Court, Suite 300
San Diego, CA 92127


We will not discriminate against you for exercising any of your CCPA Rights and we will not deny you goods or services, charge you a different price, or provide you with a lesser quality of goods or services if you exercise any of your CCPA Rights.

Privacy Policy Changes

We may change this Privacy Policy from time to time.  If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Website.  Those changes will go into effect on the “Revised” date shown in the revised Privacy Policy.  By continuing to use the Website, you are consenting to the revised Privacy Policy.

Contact Primero Systems

If you have any questions about this privacy statement or our Website, please contact us electronically through or write to:

Primero Systems Inc.
11440 West Bernardo Court, Suite 300
San Diego, CA 92127

In the event that you are concerned about how data you have provided Primero Systems through the Website or the Services has been used, please contact us electronically or write to the postal address listed above. Primero Systems takes all concerns about privacy and use of data very seriously and shall endeavor to reply to you within two business days to commence its investigation of your concerns.

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