Privacy Notice

Definitions and interpretation

In this privacy policy, the following definitions are used:

• Data: collectively all information that you submit to Primary Technologies Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws.
• Cookies: a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the section below headed "Cookies".
• Data Protection Laws: the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, together with the Privacy and Electronic Communications Regulations 2003 (as amended), and any other applicable law relating to the processing of personal data.
• UK GDPR: the retained EU law version of the General Data Protection Regulation (EU) 2016/679 as it forms part of the law of England and Wales.
• Primary Technologies Ltd, we or us: Primary Technologies Ltd, a company incorporated in England and Wales with registered number 04760864 whose registered office is at Studio 210, Monocle, 184 Ferensway, Hull, HU1 3UT.
• PECR: the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended.
• User or you: any third party that accesses the Website and is not either (i) employed by Primary Technologies Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Primary Technologies Ltd and accessing the Website in connection with the provision of such services.
• Website: the website that you are currently using, https://www.primarytech.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

In this privacy policy, unless the context requires a different interpretation: the singular includes the plural and vice versa; a reference to a person includes firms, companies, government entities, trusts and partnerships; "including" is understood to mean "including without limitation"; and the headings do not form part of this privacy policy.

Scope of this privacy policy

This privacy policy applies only to the actions of Primary Technologies Ltd and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website, including any links we may provide to social media websites.

For the purposes of the applicable Data Protection Laws, Primary Technologies Ltd is the data controller. This means that Primary Technologies Ltd determines the purposes for which, and the manner in which, your Data is processed.

Data we collect

We collect the following Data, which includes personal Data, from you:

Information you give us when you complete an enquiry or contact form on the Website, or otherwise contact us:

• your name;
• your organisation (if provided);
• contact information such as your email address and telephone number;
• any other information you choose to include in your message.

Information collected automatically when you visit the Website:

• your IP address;
• your web browser type and version, and your operating system;
• information about your visit, including the pages you view, the links you follow, and the date, time and frequency of your visits.

Automatically collected information is gathered through our analytics provider and only where you have given consent (see "Cookies" below). We do not collect payment details through this Website, and the Website does not have user accounts or login areas.

How we collect Data

We collect Data in the following ways:

• Data given to us by you: for example, when you submit an enquiry form, or contact us by telephone, post or email.
• Data collected automatically: for example, through cookies and analytics, in line with the consent you give via the cookie banner.

How we use your Data

We use your Data for the following purposes:

• To respond to your enquiry. Where you submit a form or contact us, we use your details to reply and to provide the information or services you have asked about. The lawful basis is our legitimate interests (responding to enquiries about our services) and/or taking steps at your request to enter into a contract.
• To improve the Website. We use analytics data, where you have consented, to understand how visitors use the Website so we can improve its content and navigation. The lawful basis is your consent.
• For our internal record keeping and the proper administration of our business. The lawful basis is our legitimate interests.

We will only send you marketing communications by email where you have given us consent, or where you have previously enquired about similar products or services and have not opted out (a "soft opt-in"). You can withdraw your consent or opt out of marketing at any time (see "Your rights" below). We send marketing emails through a third-party email marketing platform (see "Who we share your Data with" below).

Who we share your Data with

We do not sell your Data. We share it only with the following parties, and only as necessary:

• Hosting and forms (Netlify). This Website is hosted by Netlify, and enquiry form submissions are processed through Netlify's forms service. Netlify is operated by Netlify, Inc. in the United States; where your Data is transferred outside the UK, it is protected as required by the Data Protection Laws, relying on an officially recognised adequacy framework (such as the UK Extension to the EU-U.S. Data Privacy Framework) or other appropriate safeguards.
• Our own systems (Microsoft Azure). A copy of enquiry submissions is stored in our own content management system, which we host on Microsoft Azure in the UK (UK South region).
• Analytics (Google). Where you consent, we use Google Analytics to collect website usage statistics. This is provided by Google LLC in the United States; where your Data is transferred outside the UK, it is protected as required by the Data Protection Laws, relying on an officially recognised adequacy framework (such as the UK Extension to the EU-U.S. Data Privacy Framework) or other appropriate safeguards. Analytics cookies are not set unless you accept them via our cookie banner.
• Email marketing (Mailchimp). Where you have given consent to marketing, we share your name and email address with Mailchimp so we can send you updates and offers. Mailchimp is operated by Intuit Inc. in the United States; where your Data is transferred outside the UK, it is protected as required by the Data Protection Laws, relying on an officially recognised adequacy framework (such as the UK Extension to the EU-U.S. Data Privacy Framework) or other appropriate safeguards. You can unsubscribe at any time via the link in any marketing email.
• Our group companies, professional advisers, or a prospective purchaser of our business, where relevant and in accordance with this privacy policy.

Keeping Data secure

We use technical and organisational measures to safeguard your Data, including storing it on secure servers and restricting access to authorised personnel. We are certified to Cyber Essentials, which helps us manage and protect your Data.

Our measures include steps to deal with any suspected data breach. If you suspect any misuse, loss, or unauthorised access to your Data, please let us know immediately by emailing privacy@primarytech.co.uk.

Data retention

Unless a longer retention period is required or permitted by law, we will hold your Data only for as long as is necessary to fulfil the purposes set out in this privacy policy, for example, to respond to and follow up on your enquiry and for our legitimate business purposes, or until you ask us to delete it. When your Data is no longer needed, we securely delete it. Even after deletion, Data may persist on backup or archival media for a limited period for legal, tax or regulatory purposes.

Your rights

You have the following rights in relation to your Data:

• Right to access: to request copies of the information we hold about you.
• Right to rectification: to have inaccurate or incomplete Data corrected.
• Right to erasure: to request that we delete your Data from our systems.
• Right to restrict processing: to limit the way we use your Data.
• Right to data portability: to request that we move, copy or transfer your Data.
• Right to object: to object to our use of your Data, including where we rely on legitimate interests.
• Right to withdraw consent: where we rely on your consent, you may withdraw it at any time.

To exercise any of these rights, or to withdraw consent, please contact us at privacy@primarytech.co.uk. We will not charge you for this unless your request is manifestly unfounded or excessive.

If you are not satisfied with how we handle a complaint about your Data, you may refer it to the Information Commissioner's Office (ICO), the UK supervisory authority, at https://ico.org.uk/.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes.

Cookies

This Website may place and access certain Cookies on your computer. We use Cookies to understand how the Website is used so we can improve it.

Before any non-essential Cookies are placed, you are shown a cookie banner asking for your consent. Analytics cookies are not set until you accept them. You can decline, and you can change your choice at any time. Declining does not affect your ability to use the Website.

This Website uses the following types of Cookie:

We do not use advertising or targeting cookies, and we do not use cookies to show you adverts on other websites.

You can enable or disable cookies in your internet browser. Most browsers accept cookies by default, but this can be changed. For more information about cookies generally, including how to manage them, please refer to your browser's help menu.

General

You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this privacy policy is invalid, illegal or unenforceable, that provision will, to the extent required, be deemed deleted, and the validity of the remaining provisions will not be affected.

This privacy policy is governed by and interpreted according to the law of England and Wales. All disputes arising under it are subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

Primary Technologies Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as required by law. Any changes will be posted on the Website, and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the changes.

You may contact Primary Technologies Ltd about this privacy policy by email at privacy@primarytech.co.uk.