Privacy Policy

Last update: July 25th 2024

CLUTCH, a French société par actions simplifiée with a share capital of €14,081 whose registered office is located at 14 rue Beffroy 92200 Neuilly-sur-Seine, registered with Trade and Companies Registry of Nanterre under number 919 404 301(“CLUTCH” or “we”), may collect and process your personal data when you are using the website https://www.getprimo.com/ (the “Website”).

We value your privacy and are committed to comply with applicable data privacy laws, such as the French data privacy act No.78-17 as amended and the General Data Protection Regulation from EU Regulation 2016/679 (the “GDPR”).

This Privacy Policy aims to inform you about how we use your personal data and how you may keep control over it.

For any question about our privacy policy, please contact us by email at: dpo@getprimo.com

1. Who collects and processes your personal data?

We act as the data controller of your personal data (as an individual or a professional representing alegal entity) that we collect and process during your use of the Website.

2. For what purposes is your personal data processed?

In connection with your use of the Website, we use your personal data:

for commercial prospection purposes, to send you our offers, promotions and newsletters,
to fulfill any request you submit to us, notably through the Website’s live chat or form,
to enable you to exercise your rights relating to your personal data,
to draw statistics on use of our Website and the services provided,
to provide and enhance the Website (e.g. for monitoring the performance of the Website; enhancing your browsing experience; understanding user behavior for providing you with a more relevant browsing experience or personalizing the content on the Website);
Primo use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Primo use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

We only collect data that is adequate, relevant, and limited to what is necessary for the purposes for which it is processed.

Those purposes are specific and legitimate, and, under no circumstances, will your personal data be further processed in a way that is incompatible with these purposes, except with your prior consent.

3. What are the legal bases for processing your personal data?

We process your personal data on the basis of (a) your consent, (b) our legitimate interest, (c) for taking steps at your request before entering into a contract with you, or (d) for the performance of legal obligations.

Consent
We will send you offers, promotions, newsletters, whether targeted or not, if you consent to it when required.
We will also process your personal data to personalize and measure the effectiveness of advertising on the Website or other pages you visit through the Website provided that you consent to advertising cookies.
Legitimate interest
Providing and enhancing the Website may require processing your personal data. In this case, the basis of processing will be our legitimate interest.
We can send newsletters to your professional e-mail address to update you on our activities and services based on our legitimate interest and provided that you did not object
For taking steps at your request before entering into a contract
If you contact us, we believe that we may eventually and in the near future enter into a contract with you or your company. The basis of the processing of your personal data is to take steps at your request before executing a contract with you.
Legal obligations
We may be required to process your personal data to comply with our legal obligations in the context of the management of your rights relating to your personal data.

4. What categories of personal data are processed?

We only process your personal data that is strictly necessary to pursue the purposes described above, which includes the following categories of data:

personal identification data (such as your name, surname, email address, IP address),
professional identification data (the name of your company, your professional email address, your title/position in the company),
connection data on browsing activities (such as page view, duration of visit, clicks on pages),
technical data (such as an incident report while browsing the Website) and device data,
any data you want to share about the subject matter of your request when you contact us,
records of our discussions, including the date of your request, the internal number attributed to your request and our answer to the said request,
any data that you may provide us with in relation to the exercise of your rights relation to your personal data,

5. Who are the recipients if the personal data processed?

Your personal data is carefully stored and only made available under strict conditions to the following people:

members of our staff who need to access it,
our service providers(such as hosting service provider, software and other online tool provider).

6. Is personal data transferred outside the European Economic Area?

We may transfer some of your personal data outside the European Economic Area. Such transfers are carried out:

by signing Standard Contractual Clauses which have been approved by the European Commission as providing an adequate level of protection of your personal data, or
by using any other appropriate safeguards.

You can contact us for more information on how we handle transfers.

7. What are the retention periods for your personal data?

Your personal data is kept only for as long as is necessary for the purpose for which it was collected. The retention periods applied to data are proportionate to the purposes for which they were collected.

The retention periods for your personal data are as follows:

Purposes

Data retention periods

Sending newsletters, promotions and offers, whether or not targeted.

Until you object or withdraw your consent, as applicable, or no later than 3 years from the last contact we had with you.

Fulfilling any request you submit to us

For the time necessary to manage and process your request.

Enabling you to exercise your rights relating to your personal data

Drawing statistics on the use of the Website and our services

Statistical data are available in an aggregated and anonymized form.

At the end of the data retention periods set above, we may archive your personal data for documentary and evidentiary purposes during the statutory limitation periods.

8. Your rights regarding your personal data

You may exercise your rights by writing to us at the following email address: dpo@getprimo.com by providing proof of your identity by any means. If we have reasonable doubts about your identity, we may ask you for a copy of your identity document.

8.1. Access to your personal data

You have the right to know whether we hold any of your personal data and if so, to request access to it.

8.2. Rectify your personal data

You have the right to rectify or request rectification of any personal data which is inaccurate or incomplete.

8.3. Erase your personal data

Where relevant, you have the right to have your personal data be erased. This right can only be exercised in certain cases; for example, it may be personal data which is no longer necessary for the purposes for which it was collected or which has been processed unlawfully.
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If you rightfully exercise your right, we will proceed with the erasure of your personal data as soon as possible.

The deletion is final, except in cases where processing of your personal data is necessary to comply with a legal obligation or to establish, exercise or defend legal claims.

8.4. Restriction of processing of your personal data

You have the right to have the processing of your personal data be restricted. This right may be exercised where you contest the accuracy of your personal data.

This right does not result in erasure and we are obliged to inform you before the relevant processing restriction is lifted.

8.5. Objecting to the processing of your personal data

When we process personal data for commercial prospection purposes, in order to send you our newsletters, promotions and offers, you may object to the processing at any time by clicking on the unsubscribe link provided at the bottom of each prospection message we send you.

8.6. Portability of your personal data

You may request to receive your personal data in a commonly used and machine-readable structured format for portability purposes.

The right to portability of processed personal data is not a general and absolute right. Thus, this right only applies when the processing is based on your consent or on a contract and the processing is carried out by automated means.

8.7. Withdrawing your consent

You may withdraw your consent at any time where processing is based on your consent. We will then stop processing your personal data for the future, without affecting any previous processing of your personal data for which you have consented.

8.8. Defining directives concerning the fate of your personal data after your death

You can give us instructions on what to do with your personal data after your death and how to use it.

8.9. Making a complaint

If, despite all the care we take to protect your personal data, you believe that your rights have not been respected, you may lodge a complaint with the competent authority (in France, the CNIL is the competent authority and its contact details are as follows: 3 Place de Fontenoy- TSA 80715- 75334 PARIS CEDEX 07, telephone number: 01 53 73 22 22).

9. Cookies

Cookies or similar tracking technology (each a “Cookie”) allow to collect a sequence of technical information associated with an identifier that is transmitted by the Website to your web browser, which stores it for a certain period of time and sends it back to a web server each time you use the Website.

We and our partners use the following Cookies:

From Intercom to provide a live chat functionality. These Cookies are functional and not subject to your consent;
From Google Analytics (https://policies.google.com/privacy) to get analytics insights and allow Google to collect data for advertising purposes to enhance our Website. These Cookies are subject to your consent.

We also use Cookies of technical nature to save your Cookies preference or language preference. Those Cookies are not subject to your consent. You can nevertheless disable such Cookies via your internet browser but the Website may cease to properly function.

10. Modification of our Privacy Policy

In order to satisfy you as much as possible, our Website is continuously improved and evolving.

We may have to modify our privacy policy from time to time, in particular to comply with any regulatory, legal, editorial or technical developments. In such a case, we will inform you by any means of this modification and the date appearing at the top of the document will be modified. We invite you to regularly refer to this page.