Privacy Policy

Last updated March 31, 2024 This privacy notice for Prime Digital Solutions, Inc. describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

• Visit our website at https://www.primelicense.com/en-gb/, or any website of ours that links to this privacy notice
• Download and use our mobile application (PrimeLicense), or any other application of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at contact@primelicense.com.

Summary of key points

This summary provides key points from our privacy notice, but you can find out more details about any of these topics in the full notice below.

• What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Prime Digital Solutions, Inc. and the Services, the choices you make, and the products and features you use.
• Do we process any sensitive personal information? We do not process sensitive personal information.
• Do we receive any information from third parties? We do not receive any information from third parties.
• How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent, and only when we have a valid legal reason to do so.
• In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties, described below.
• How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.
• What are your rights? Depending on where you are located geographically, applicable privacy law may give you certain rights regarding your personal information.
• How do you exercise your rights? The easiest way is by contacting us. We will consider and act on any request in accordance with applicable data protection laws.

Table of contents

1. Data controller
2. What information do we collect?
3. How do we process your information?
4. What legal bases do we rely on to process your personal information?
5. Data transfer to other countries
6. When and with whom do we share your personal information?
7. Do we use cookies and other tracking technologies?
8. How long do we keep your information?
9. How do we keep your information safe?
10. Do we collect information from minors?
11. What are your privacy rights?
12. Controls for Do-Not-Track features
13. Do California residents have specific privacy rights?
14. Do we make updates to this notice?
15. How can you contact us about this notice?
16. How can you review, update, or delete the data we collect from you?

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1. Data controller

In short: Prime Digital Solutions, Inc. is the Data Controller. The Data Controller is Prime Digital Solutions, Inc. (EIN: 38-4304710), with registered office in the state of Delaware (United States of America), City of Wilmington, No. 3422 Old Capitol Trail, Suite 404, Zip Code 19808. Please note that the data provided may be processed by other subjects involved in the organization of the Data Controller, all acting as data processors, or by external subjects (such as third-party technical service providers, hosting providers, or platforms for the provision of training courses), appointed as data processors or, if necessary, external data processors by the Data Controller.

2. What information do we collect?

Personal information you disclose to us In short: We collect personal information that you provide to us. We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, participate in activities on the Services, or otherwise contact us. The personal information we collect may include the following:

• Names
• Phone numbers
• Email addresses
• Mailing addresses
• Usernames
• Billing addresses

Sensitive information. We do not process sensitive information. Payment data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is stored by Stripe, PayPal, Amazon Pay, Google Pay, and Apple Pay — you can find their respective privacy notices on their websites. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such information. Information automatically collected In short: Some information — such as your IP address, browser, and device characteristics — is collected automatically when you visit our Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and information about how and when you use our Services. This is primarily needed to maintain the security and operation of our Services, and for internal analytics and reporting. Like many businesses, we also collect information through cookies and similar technologies — see our Cookie Notice for details. The information we collect includes:

• Log and usage data: service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, including IP address, device information, browser type, and activity such as pages viewed, searches, and features used.
• Device data: information about the computer, phone, tablet, or other device you use to access the Services, such as device and application identification numbers, browser type, hardware model, internet service provider, operating system, and system configuration.
• Location data: information about your device’s location, either precise or imprecise, based on IP address or other technologies. You can opt out by disabling your device’s Location setting, though some features may not work without it.

3. How do we process your information?

In short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts (name, surname, email, IP address, geolocation data — mandatory).
• To enable you to use our Services and purchase our products (name, surname, email, IP address, geolocation data — mandatory).
• To request feedback and contact you about your use of our Services (name, surname, email, IP address, geolocation data — optional).
• To send you marketing and promotional communications — by email, SMS, or instant messaging apps such as WhatsApp — in accordance with your marketing preferences (name, surname, email, IP address, geolocation data, phone number — optional). We collect and use your phone number for SMS/messaging marketing only with your express consent given via pop-ups or forms. You can opt out at any time using the unsubscribe link in our messages or by contacting us. See “What are your privacy rights?” below.
• To deliver targeted advertising tailored to your interests, location, and more — see our Cookie Notice (name, surname, email, IP address, geolocation data — optional).
• To identify usage trends so we can better understand and improve how our Services are used (name, surname, email, IP address, geolocation data — optional).
• To determine the effectiveness of our marketing and promotional campaigns (name, surname, email, IP address, geolocation data — optional).
• To protect an individual’s vital interest, such as to prevent harm, using the data provided when creating your account (mandatory).

4. What legal bases do we rely on to process your information?

In short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law — such as your consent, to comply with laws, to fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests. The GDPR and UK GDPR require us to explain the legal bases we rely on to process your personal information. We may rely on the following:

• Consent. We may process your information if you have given us permission for a specific purpose. You can withdraw your consent at any time. Processing related to marketing, profiling, and sending commercial offers is based exclusively on your consent; once revoked, such processing stops immediately.
• Legitimate interests. We may process your information when reasonably necessary to achieve our legitimate business interests — for example, to provide you with the requested service, or to send you the products you’ve purchased — provided those interests do not outweigh your rights and freedoms.
• Legal obligations. We may process your information where necessary to comply with legal obligations, such as cooperating with a law enforcement body or regulatory agency, or exercising or defending our legal rights.
• Vital interests. We may process your information where necessary to protect your vital interests or those of a third party, such as situations involving potential threats to safety.

5. Data transfer to other countries

In short: We transfer data to a third country. Under the GDPR, a “third country” is one where privacy law does not guarantee the same rights as EU Regulation 679/2016. Our registered office is in the U.S.A., which is considered a third country, so Prime Digital Solutions, Inc. inevitably transfers data there. We meticulously comply with everything enshrined in EU Regulation 679/2016, so our data processing and security standards match European standards. By providing us your personal data, you consent to the transfer of that data to the U.S.

6. When and with whom do we share your personal information?

In short: We may share information in specific situations and with specific third parties described in this section.

• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or part of our business by another company.
• External suppliers. To carry out our business activities, we rely on qualified outside professionals who, in the course of their work, may come into contact with your personal data. All such individuals are appointed as external data controllers and adhere to European standards.

7. Do we use cookies and other tracking technologies?

In short: We may use cookies and other tracking technologies to collect and store your information. We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific details about how we use these technologies and how you can refuse certain cookies are set out in our Cookie Notice.

8. How long do we keep your information?

In short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice, unless otherwise required by law. We will only keep your personal information for as long as necessary for the purposes set out in this notice, unless a longer retention period is required by law (such as tax or accounting requirements). No purpose in this notice requires us to keep your personal information longer than the period in which you have an account with us. When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it — or, if that isn’t possible (for example, because it’s stored in backup archives), we will securely store it and isolate it from further processing until deletion is possible. If you provide us with information simply to request product-related information, without purchasing anything, we retain it for 90 days before deleting it. If you purchase one of our products, we retain your data for ten years to comply with accounting and tax obligations. If you consent to marketing and promotional offers, we retain your data until you revoke that consent via the unsubscribe link in our promotional messages.

9. How do we keep your information safe?

In short: We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards, no electronic transmission over the internet or information storage technology can be guaranteed 100% secure, so we cannot promise that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security. Transmission of personal information to and from our Services is at your own risk; you should only access the Services within a secure environment.

10. Do we collect information from minors?

In short: We do not knowingly collect data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18, or that you are the parent or guardian of a minor and consent to that minor’s use of the Services. If we learn that personal information from users under 18 has been collected, we will deactivate the account and take reasonable measures to promptly delete that data. If you become aware of any data we may have collected from children under 18, please contact us at contact@primelicense.com.

11. What are your privacy rights?

In short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time. In some regions, you may have the right to: request access to and a copy of your personal information; request rectification or erasure; restrict the processing of your personal information; and, where applicable, request data portability. You may also have the right to object to processing in certain circumstances. Contact us using the details in “How can you contact us about this notice?” below to make such a request — we will consider and act on it in accordance with applicable data protection laws. If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you have the right to complain to your Member State’s data protection authority or the UK’s data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner. Withdrawing your consent. Where we rely on your consent to process your personal information, you may withdraw it at any time by contacting us. This will not affect the lawfulness of processing before withdrawal, nor processing conducted on other lawful grounds. Opting out of marketing communications. You can unsubscribe at any time via the link in our emails or by contacting us. You’ll be removed from marketing lists, though we may still send service-related messages necessary for your account or in response to service requests. Account information. You can review or change your account information by logging in to your account settings. Upon request to terminate your account, we will deactivate or delete it from our active databases, though we may retain some information to prevent fraud, troubleshoot issues, assist investigations, or comply with legal requirements. Cookies and similar technologies. Most web browsers accept cookies by default; you can usually set your browser to remove or reject them, though this may affect certain features. See our Cookie Notice for details, including opting out of interest-based advertising. If you have questions about your privacy rights, email us at contact@primelicense.com.

12. Controls for Do-Not-Track features

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature you can activate to signal that you don’t want your online browsing activity monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized, so we do not currently respond to DNT signals. If a standard is adopted that we must follow, we will inform you in a revised version of this notice.

13. Do California residents have specific privacy rights?

In short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information. California Civil Code Section 1798.83, the “Shine the Light” law, permits California resident users to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes, and the names and addresses of those third parties, for the preceding calendar year. Submit such requests in writing using the contact information below. If you are under 18, reside in California, and have a registered account with the Services, you have the right to request removal of data you’ve publicly posted. Contact us with the email address associated with your account and a statement that you reside in California. We’ll ensure the data is not publicly displayed, though it may not be fully removed from all our systems (e.g., backups).

14. Do we make updates to this notice?

In short: Yes, we will update this notice as necessary to stay compliant with relevant laws. We may update this privacy notice from time to time. The updated version will show a revised “Last updated” date and take effect as soon as it’s accessible. If we make material changes, we will notify you by prominently posting a notice or sending a direct notification. We encourage you to review this notice periodically.

15. How can you contact us about this notice?

If you have questions or comments about this notice, email us at contact@primelicense.com or write to: Prime Digital Solutions, Inc. 3422 Old Capitol Trail, Suite 404 Wilmington, Delaware 19808, United States

16. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change it, or delete it. To make such a request, contact us at contact@primelicense.com.