PRIMOARTISTS.COM
Primo Artists LLC Privacy Policy
Welcome to the privacy policy (the “Privacy Policy”) of Primo Artists LLC (“Primo Artists”, “we”, “us”, or “our”) located at www.primoartists.com (the “Website”).
In using the Website, you accept this Privacy Policy and the collection and processing of your personal data (“Personal Data”). Primo Artists respects your privacy and is committed to protecting your Personal Data. Primo Artists processes the Personal Data transmitted to it in accordance with the legislation in force, and, in particular, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (the “GDPR”).
This Privacy Policy will inform you as to how we collect and process your Personal Data when you visit our Website, and tell you about your privacy rights and how the law protects you.
If you have any comments on this Privacy Policy, please email them to charlotte@primoartists.com.
1. IMPORTANT INFORMATION AND WHO WE ARE
A. PURPOSE OF THIS PRIVACY POLICY
This Privacy Policy aims to give you information on how Primo Artists collects and processes your Personal Data through your use of this Website, including any data you may provide through this Website when you sign up to receive our newsletter, or contact us.
The Website is not directed at or intended for anyone under 18 years of age. Additionally, in accordance with the Children’s Online Privacy Protection Act (“COPPA”), we do not knowingly collect or solicit Personal Data from individuals under 13 years of age. If we later obtain actual knowledge that we have obtained Personal Data from an individual under 13 years of age, we will take steps to remove that individual’s information from our systems. If you are the parent or guardian of a minor whom you believe has disclosed Personal Data to us, please contact us so that we may delete and remove such information from our systems.
B. CONTROLLER
Primo Artists is the controller and responsible for your Personal Data. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact Primo Artists LLC, charlotte@primoartists.com, 244 Fifth Avenue, Suite B222, New York, NY 10001, 212-804-8301.
C. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our Privacy Policy under regular review. If we amend or update the Privacy Policy, we will upload the updated Privacy Policy to the Website, indicating the date of the latest update. You must therefore regularly check the Website to remain informed of any change or update made to the Privacy Policy. This version was last updated on January 20, 2020. Historic versions can be obtained by contacting us.
D. THIRD-PARTY LINKS
This Website may include links to third-party Websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party Websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the Privacy Policy of every Website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal Data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
Identity Data includes first name and last name.
Contact Data includes email address.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
Usage Data includes information about how you use our Website.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.
We collect information that you provide to us during your use of the Website such as Identity Data and Contact Data that you submit to us when contacting us through the “Contact” section of the Website, including your first and last name, and email address. We also collect your communications with us, including your messages in the “Contact” section of the website and your emails to us. We also use third party tracking services, such as Google Analytics, to track and analyze data from users of the Website.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may provide us with your Identity and Contact by signing up for email updates or registering for our newsletter, or by corresponding with us by mail, phone, email or otherwise.
Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, and other similar technologies. Please see our cookie policy below in Section 4(F) for further details.
Third parties or publicly available sources. We will receive Technical Data about you from analytics providers such as Google.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your Personal Data as the law allows. Most commonly, we will use your Personal Data in the following circumstances:
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will get your consent before sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
A. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We will only use your Personal Data as necessary to serve the legitimate interests of Primo Artists.
Primo Artists may use your Personal Data for communication purposes to send out newsletters and information. Such processing serves the legitimate interests of Primo Artists, for the development of its relationships with clients and prospective clients.
Your Personal Data may be processed to:
Ensure the proper functioning and security of the Website – to improve its functioning and adapt it to your requests; and
Carry out anonymous statistical analyses.
Such processing serves the legitimate interests of Primo Artists regarding the proper functioning and security of the Website, and to assess its audience.
B. MARKETING COMMUNICATIONS
You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.
C. THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.
D. OPTING OUT
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by contacting us at any time.
E. COOKIES
When you visit and browse the Website, you accept that the Website uses cookies to improve its functionalities and performance. Cookies are small text files that a website sends to your web browser and that are stored on your computer. Cookies enable a website to collect information about you, such as your browsing behavior on the website, in order to improve your browsing experience and the functionalities of the website.
There are different types of cookies:
Session cookies, which disappear as soon as you leave the website; and
Permanent cookies, which remain on your computer until they expire or until you delete the cookies using the browser settings.
In order to adapt the Website to your demands, Primo Artists measures the number of visits, the number of pages visited, your activity on the Website, and how frequently you return. For this purpose, Primo Artists uses Google Analytics, a statistical tool developed by Google. It generates a cookie with a unique identifier. For more information, you may consult the Google “Data privacy & Security” page here.
How can you accept, refuse or delete cookies with your browser?
As explained above, during your visits to the Website, cookies may be installed on your computer. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly.
At any time, you may disable the cookies installed through the Website. In order to disable the aforementioned cookies, the process is as follows:
In Google Chrome:
To set your browser to block cookies:
Click the “Chrome” menu on the browser toolbar.
Select “Settings”.
Click “Show advanced settings”.
In the "Privacy" section, click the “Content settings” button.
In the "Cookies" section, you can change the following cookies settings:
Block cookies by default.
Keep cookies and site data by default until you close your browser.
Make exceptions for cookies from specific websites or domains.
To delete cookies:
Click on the Chrome menu on the browser toolbar.
Select Settings.
Click Show advanced settings.
In the "Privacy" section, click the Content settings button.
In the "Cookies" section, you can click “All cookies and site data” to open the ”Cookies and site data” dialogue box.
To delete all cookies, click “Remove all” at the bottom of the dialogue box.
To delete a specific cookie, hover over the website that issued the cookie, then click the X that appears on the right-hand side.
For more information, please go to: https://support.google.com/chrome/answer/95647?hl=en
In Safari:
To set your browser to block cookies:
Open Safari, go to “Safari” and then “Preferences”.
In the Preferences tab, click “Privacy”.
In the “Block cookies” section, specify if and when Safari should accept cookies from websites.
To delete cookies:
Open Safari. Click “Safari” and choose “Reset Safari”.
In the new window, select “Remove all cookies”. Click “Reset” to confirm.
In Firefox:
To set your browser to block cookies:
Open Firefox, click “Tools”, and then choose “Options”.
Click on the “Privacy” tab, and set “Firefox will” to “Use custom settings for history”.
Tick “Accept cookies” from sites to enable Cookies, and untick it to disable them.
Tick for how long cookies may be stored:
Keep until they expire: Each cookie will be removed when it reaches its expiration date, which is set by the site that sent the cookie.
Keep until I close Firefox: The cookies that are stored on your computer will be removed when Firefox is closed.
For further information, please go to: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
To delete cookies:
Open Firefox, click “Tools”, and then on “Options”.
In the Privacy panel, click “Clear recent history”, select “Cookies” and click “Clear now”.
In Internet Explorer:
To set your browser to block cookies:
Open Internet Explorer, click “Tools”, and then choose “Internet Options”.
Click on the “Privacy” tab, then move the slider on the option of your choice and click on OK.
Internet Explorer gives a description of the types of cookies that are blocked at each confidentiality level.
If you decide to block cookies, some website pages may not function properly.
For further information, please visit: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
To delete cookies:
Open Internet Explorer, click “Tools”, and then choose “Internet Options”.
On the General tab, click “Delete” under Browsing History in the Internet Options dialogue box.
In the “Delete Browsing History” dialogue box, tick the "Cookies and website data" check box, and click “Delete”.
F. CHANGE OF PURPOSE
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your Personal Data with the parties set out below for the purposes which we will use your Personal Data.
External Third Parties as set out in the Glossary below.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Policy.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
6. DATA SECURITY
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA?
We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, or other requirements.
8. YOUR LEGAL RIGHTS
In line with applicable law, you have the right to request access to and modification of your Personal Data, meaning you may ask for modification or erasure of your Personal Data that is inaccurate, incomplete or obsolete. You also have the right to request restriction or to object to processing of your Personal Data for legitimate reasons.
You may also, at any time and without giving reason, oppose the processing of your Personal Data for communication purposes. Such rights may be exercised upon request, by emailing charlotte@primoartists.com or writing to Primo Artists LLC, 244 Fifth Avenue, Suite B222, New York, NY 10001.
A. NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
B. WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
C. TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9. GLOSSARY
A. LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.
B. EXTERNAL THIRD PARTIES
External third parties include service providers who provide IT and system administration services, and professional advisers who provide consultancy, legal, insurance and accounting services.
C. YOUR LEGAL RIGHTS
You have the right to:
1. Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
2. Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use.
7. Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
Last Update: January 20, 2020