Last Updated: Dec 20, 2020
WHO ARE WE?
We are Prima Systems, LLC. Our contact and other details are set out at the end of this policy. We are the controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise).
WHOSE PERSONAL DATA DO WE PROCESS?
We may process personal data relating to you if:
- You are a customer or a supplier of ours (or are interested in becoming so).
- You use our services or products developed by us.
- You work for a customer or a supplier of ours, or for someone who uses our services or products developed by us.
- You are someone (or you work for someone) to whom we want to advertise or market our services.
- You are our employee, contractor or have expressed an interest in working for us.
INFORMATION WE DO NOT COLLECT – CHILDREN
We do not knowingly solicit data online from or market to children under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information without parental consent, we take steps to delete such information.
WHAT SORT OF PERSONAL DATA ABOUT YOU DO WE PROCESS?
We may process personal data relating to you that we have either obtained from you, or obtained from somewhere else. Personal data relating to you that we process may include:
- Your name.
- Who you work for, and your job function or department.
- Your address, phone number, email address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the person that you work for).
- Information about you that you give us by communicating with us by phone, by e-mail, via our website, via social media or otherwise. It includes information you give us or that we obtain when you use our website, obtain or subscribe to our events, supply us with goods or services, enquire about our services, place an order, enter a competition, promotion or survey, or contact us to report a problem, or do any of these things on behalf of the person that you work for.
- Information relating to transactions with us involving you or the person that you work for (for example, details of products developed by us or services that we have supplied to, or obtained from, you or the person you work for).
- Other information relating to you which it is necessary for us to process in order to enter into or perform a contract with you or the person that you work for (for example, right to work information and information obtained from credit references agencies where this is necessary to enable us to carry out appropriate checks in relation to contracts with you or someone else that you work for or are otherwise related to).
- Information that we obtain from you when you use our website, including:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us or social media handle used to connect with us.
WHAT DO WE DO WITH YOUR PERSONAL DATA?
We process your personal data for the following purposes:
- To enter into, and to perform, contracts with you or the person that you work for.
- provide services to customers or other users of those services;
- obtain goods and services from suppliers;
- manage and administer our relationships with customers, suppliers or other users of our services;
- Where you or the person that you work for may be the relevant customer, user or supplier of goods or services for these purposes.
- To advertise and market, and provide information about, our services.
- To administer our website under our terms and for internal operations, including troubleshooting, and data analysis, testing, research, statistical and survey purposes.
- To improve our site to ensure that content is presented in the most effective manner for you and for your computer.
- To keep our website and other systems safe and secure.
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising.
- To make suggestions and recommendations about services that may interest you or the person that you work for and subject to your stated preferences, where relevant.
- Prima Systems does not sell your personal information.
Prima Systems may share your data with our affiliated research and development center (the “Center”) to improve and analyze our website and marketing strategies. Prima Systems enters into comprehensive confidentiality agreements with the center to ensure that Your Personal Data remains secure at all times. Prima Systems may provide anonymized information about you which does not allow you to be identified or contacted (‘Aggregate Information’) to third parties. For example, we might inform third parties regarding the number of users of our website and the activities they conduct while on our website.
WHAT ARE THE LEGAL GROUNDS FOR OUR PROCESSING OF YOUR PERSONAL DATA?
The basis on which we process your personal data is as follows:
- Where it is necessary to obtain your prior consent to the processing concerned in order for us to be allowed to do it (for example, direct marketing activities), we will obtain and rely on your consent in relation to the processing concerned (see below for how to withdraw your consent to processing).
- Otherwise, we will process your personal data only where the processing is necessary:
- for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract;
- for compliance with a legal obligation to which we are a subject; or
- for the purposes of the legitimate interests pursued by us or another person, provided that this will only be in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data (most circumstances in which we process your personal data in relation to a relationship that we have with the person that you work for will fall into this category).
HOW LONG DO WE PROCESS PERSONAL DATA FOR?
We process personal data only for so long as is necessary for the purpose(s) for which it was originally collected, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject or for another legitimate and lawful purpose. If you are a customer or prospect, we will maintain personal data for up to 3 years after collection unless another term applies according to such purposes.
Prima Systems may disclose Your Personal Data when we believe in good faith that disclosure is required by law or legal process, or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate and prevent measures against suspected or actual illegal activities or to cooperate with public and government authorities; (2) enforce our contractual requirements; (3) protect and defend ourselves against any third-party claims or allegations; (4) maintain the security or integrity of the Prima Systems Services; or (5) safeguard the rights and safety of Prima Systems, its workforce and others.
Prima Systems will undertake good faith efforts to notify You about any legal demands for Your Personal Data when appropriate in our judgment, unless restricted by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
WHAT ARE YOUR RIGHTS?
You have the following rights in relation to personal data relating to you that we process:
- You may request access to the personal data concerned (please see the section on obtaining access to your personal data, below).
- You may request that any incorrect personal data about you that we are processing be rectified.
- In certain circumstances (normally where the personal data has been provided by you and it is no longer necessary for us to continue to process it), you may be entitled to request that we erase the personal data concerned.
- Where we are processing personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent to processing, after which we shall stop the processing concerned.
HOW TO WITHDRAW YOUR CONSENT TO PROCESSING
You can withdraw your consent to any relevant processing of personal data:
- By emailing us at firstname.lastname@example.org
- By writing to us at the address below
HOW TO EXERCISE YOUR RIGHT OF ACCESS TO YOUR PERSONAL DATA
You can exercise your right of access to your personal data:
- By emailing us at email@example.com
- By writing to us at the address below
Please note that we may be required to ask you for further information in order to confirm your identity before we provide the information requested.
OUR DETAILS – CONTACTING US
Our full details are:
100 Enterprise Drive, Suite 301,
Rockaway, NJ 07866
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