Privacy Policy

Last Updated: March 04, 2024

PE Primer, LLC (“PE Primer” "we," or "us") recognizes the importance of data privacy, and this Privacy Policy sets forth the terms and conditions with respect to how we process personal information. This Privacy Policy describes, among other issues, the types of personal information that we collect, the purposes for which we use it, the types of third parties with whom we share it, and any rights and responsibilities you may have with respect to such personal information.

This Privacy Policy applies to the personal information you provide us when you (i) access and use our website: https://pe-primer.com or https://learn.pe-primer.com (together, the “Website”), (ii) purchase or receive products or services through the Website, or (iii) otherwise contact or engage with us. For purposes of this Privacy Policy, the Website and all information and features provided for thereon shall be referred to collectively as the “Services.”

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING THE SERVICES OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY POLICY AND OUR TERMS & CONDITIONS AND APPLICABLE COOKIE POLICY AVAILABLE ON THE SITE.

PE Primer is headquartered in the United States, and the personal information you provide to PE Primer may be processed and stored in the United States. For more information on our data transfer practices, please see Section 8 (Data Retention and Localization).

1.   Scope 

For purposes of this Privacy Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual or household and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual or household and that is not otherwise subject to a data protection law, statute, or regulation. PE Primer may anonymize or de-identify personal information, and such data is not subject to this Privacy Policy, and PE Primer may use such data for any purpose.

To the extent that PE Primer is providing learning management services as part of its contract with an organization, PE Primer will serve as a data “processor” and the organization will serve as the data “controller” and in such circumstances, PE Primer will collect and process any personal information derived from the organization’s employees in accordance with our Data Processing Addendum (and not this Privacy Policy). To the extent you are using our learning management services in an individual, personal capacity (i.e., you are not an employee, contractor, or agent of an organization to whom we have a contract to furnish services), then any and all of your personal information is collected and processed in accordance with this Privacy Policy (and not the Data Processing Addendum) and the term “Services” includes the learning management services we are furnishing to you.

2.   The Types and Categories of Personal Information We Collect 

PE Primer collects personal information in order to provide our Services, comply with our legal obligations, promote our business interests, and for the other reasons set forth in this Privacy Policy. When you do not provide personal information to PE Primer, we may not be able to provide you the Services or to complete a transaction you requested. Generally, we collect the following types and categories of personal information during our business operations:

Usage and Device Data. When you access and use the Website, we automatically collect details of your access to and use of the Website, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Website (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Website may collect “diagnostic” data related to your use of the Website, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.

Cookies and Tracking Data. We use “cookies” and other tracking technologies within the Website. A cookie is a small file placed on your device. It may be possible to refuse to accept cookies by activating the appropriate setting on your device. However, if you select this setting, some parts of the Website may become inaccessible or not function properly. In addition, the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of the Website (e.g., recording the popularity of certain content and verifying system and server integrity). The Website may collect data about the advertisements you have seen or engaged.

Website Monitoring. Please be aware that we, and our service providers and partners, use cookies and other tracking technologies within the Website to monitor and record any and all activities and communications to, from, and on, the Website in order to safeguard, improve, and analyze usage of, the Website, for marketing, and for the other purposes listed in this Privacy Policy. For the avoidance of doubt, you hereby acknowledge, agree, and consent to, such monitoring and recording by us and our service providers and partners. 

Audio and Visual Materials. Our Website may, from time to time, display live or prerecorded videos or similar audio visual materials (“Videos”). We may collect personal information with respect to you requesting access to, and/or accessing, such Videos, and we may disclose such personal information to third parties, including to our third-party service providers through the use of cookies. By requesting access to, or accessing, such Videos, you hereby agree to our Video Information Disclosure Consent Form. The provision of Videos on our Website is not an admission by PE Primer and shall not otherwise be interpreted, in any form or manner, to mean that PE Primer is a “video tape service provider” for purposes of the Video Privacy Protection Act (codified as amended at 18 U.S. Code § 2710) (the “VPPA”) or PE Primer is otherwise subject to the VPPA.

Non-Cookie Technologies. Our Website may deploy “Non-Cookie Technologies” to support our digital advertising programs. These technologies often include browser cache, locally stored objects, or the creation of a statistical identifier wherein an identifier, much like a cookie identifier, is calculated based on the characteristics of a browser or device that distinguishes it from other browsers or devices. These identifiers are calculated either from the data your browser or device shares automatically with the Website or with additional data specifically requested from your browser or device. For more information, see here.

3.   Sources of Information

We collect the personal information identified herein directly from you when you use our Services, through automated means when you are using the Website, and from third parties, as follows:

First Party / Direct Collection. We collect personal information directly from you when you use our Services (e.g., registering accounts, completing purchases, signing up for subscriptions), when you provide a Product Review (as defined below), or whenever you directly engage with us, such as when you visit our offices or premises or otherwise contact us or we visit your office or premises (e.g., in-person training).

Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use the Website (see “Technical Data” above).

Third-Party Sources. We collect personal information from third parties, such as publicly available databases, social networking providers, advertising companies, our service providers, and third-party references.

4.   How We Use your Information / Purpose of Collection

We may use the personal information we collect about you in order to perform our Services, comply with our legal obligations, and promote our business interests.

                                                                                                 How Your Personal Information Is Used

5.   Sharing Information / Third-Party Disclosures

We share your personal information as described below and in this Privacy Policy, and as permitted by applicable law.

6.   Social Media/ Platform Data Rights

We may engage with you on various social media platforms (e.g., LinkedIn, Facebook, Twitter, Pinterest, Instagram). If you contact us on a social media platform for customer support or for other reasons, we may contact you via the social media’s direct message tools. Those communications to and from us are governed by this Privacy Policy. However, your use of a social media platform is also subject to the policies and terms of the relevant social media platform. Certain social media platforms may also automatically provide us with your personal information, the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Website includes social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on the Website. These features may collect your IP address and which Website page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Website. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.

According to the terms and conditions governing certain social media platforms, you may request that the information, data, or other content we obtain from or through the social media platform (“Platform Data”) be deleted or modified. If you would like Platform Data related to you deleted or modified, please contact us in accordance with the “Contact Us” section below and (i) identify the social media platform at issue and (ii) the Platform Data that you would like deleted and/or modified, and if modified, the modification to said Platform Data. We may also delete Platform Data if requested by the social media platform.

 7.   Links to Other Websites; Your Direct Third-Party Disclosures

As a resource to you, the Website may include links to third-party websites or provide you the opportunity to disclose information directly to third parties (e.g., credit card processors). Our Privacy Policy does not apply to such third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the Services. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.

 8.   Data Retention and Localization

The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information for as long as needed to provide you with our Services, to facilitate transactions you have requested, to comply with our legal obligations (e.g., tax filings), to engage in marketing activities, and for as long as is necessary to defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy.

PE Primer is based in the United States, and the personal information that we collect and process is retained and stored in the United States. PE Primer uses service providers that store personal information on our behalf in the United States and in other countries where you may not reside (each a “third country”). Please be aware that the United States, and these other third countries, may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. By continuing to provide us such information, you hereby acknowledge and agree that your personal information will be transferred to, and stored in, the United States and in such other third countries.

 9. Security 

We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE, AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE SITE AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION CAUSED BY A THIRD PARTY. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately (and in any event within twenty-four (24) hours) if you have reason to believe that your username or password to our Services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.

10.   No Data Collected from Children

The Website is not directed at, nor intended for use by, children. As a result, if you are under the age of eighteen (18), you are prohibited from accessing or using the Services (including the Website) or with providing us with your personal information.

11.   Publicly Posted Information; Product Reviews

You may, from time to time, have the ability to submit via the Website a comment on, provide an opinion about, rate, or otherwise discuss our Services (a “Product Review”). In other circumstances, you may directly provide us feedback on our business, our business sector, or the Services (“Feedback”). Any information or content you post in a Product Review or in your Feedback may be available to other users of the Website (and our social media platforms) and may be retrievable by third-party search engines, and third parties may also be able to download or share your Product Review and Feedback to social media websites or elsewhere. We recommend that you guard your privacy and anonymity and not upload any information in your Product Review and Feedback that you wish to remain confidential. Any third party with access to your information via the Website will be permitted to use the information in the same manner as if you submitted the information directly to that third party. Publicly posting any information on the Website is entirely voluntary on your part, and we recommend you carefully consider the information you choose to make publicly available. As between you and PE Primer, any and all Product Reviews and Feedback shall be considered our confidential and proprietary information. In order for PE Primer to utilize such Product Reviews and Feedback, you grant to PE Primer a non-exclusive, perpetual, irrevocable, worldwide, royalty-free license, with the right to sublicense, under all relevant intellectual property rights, to use, publish, and disclose such Product Reviews and Feedback in any manner we choose and to display, perform, copy, make, have made, use, sell, and otherwise dispose of PE Primer’s and our sub-licensees’ products or services embodying such Product Reviews and Feedback in any manner and via any media we choose, without reference to the source. PE Primer shall be entitled to use Product Reviews and Feedback for any purpose without restriction or remuneration of any kind with respect to you and/or your representatives.

12.   Your Responsibilities

You are permitted, and hereby agree, to only provide personal information to PE Primer if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO PE PRIMER, YOU EXPRESSLY REPRESENT AND WARRANT TO PE PRIMER THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE PE PRIMER WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT PE PRIMER’S USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY PE PRIMER FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO PE PRIMER.

13.   Updating Your Information

It is important that the personal information that you provide to us is accurate and reliable. In certain circumstances, you may have the ability to directly edit your account to update and change your personal information (e.g., name, telephone number, email, shipping address), and you must do so when such changes are warranted. You may review, update, or modify your personal information, including profile and contact information, at any time by logging into your account. You may request deletion of your personal information or Company account by emailing privacy@pe-primer.com.

14. European Data Protection Rights

If you are located in the EU, Switzerland, or the UK, you have the following data protection rights and privileges:

We would, however, appreciate the opportunity to address your concerns, so please feel free to contact us regarding any complaint you may have. We will not discriminate against individuals for exercising their data privacy rights or filing a privacy complaint.

We will facilitate your exercise of the rights that apply to you in accordance with applicable law. If you have questions about your rights or wish to exercise your rights, you can contact us at privacy@pe-primer.com, or otherwise in accordance with the “Contact Us” section listed below.

15. Legal Basis for Processing (EEA/UK/Switzerland Only)

For purposes of the EU/UK GDPR, we can collect and process your data under one of the following legal bases:

16. California Privacy Rights

Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of personal information, as defined under Shine the Light, such as name, email address, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. However, PE Primer does not disclose personal data to third parties for their direct marketing purposes. Separately, PE Primer is not a “business” within the meaning of the California Consumer Privacy Act of 2018, as amended.

17. Marketing Opt-Out

You have the right to opt out of receiving email marketing communications from us. You can object to further marketing at any time by selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you. If you are paying for one of our services, please note that clicking the “unsubscribe” link will not cancel your paid subscriptions, but it is likely to affect deliverability of your newsletter messages, announcements, or other product related communications. If you purchase products or services from us, or if you register for an account with us, we may contact you to confirm your purchase, subscription, or registration, or to provide you with information about its terms or features. You may wish to keep these transactional or relationship emails, to help you use our products and services.

18.  Do-Not-Track Signals 

Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.

19.   Persons with Disabilities

PE Primer strives to ensure that every person has access to information related to our Services, including this Privacy Policy. Please contact us if you would like this Privacy Policy provided in an alternative format, and we will seek to meet your needs.

20.   Changes to the Policy

We reserve the right to amend this Privacy Policy at any time. We will notify you if this Privacy Policy is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto. Your use of the Services, and continued use of the Services after any amendments are made to this Privacy Policy, signifies your consent to this Privacy Policy and any amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Privacy Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto.

21.   Contact Us

If you have questions regarding this Privacy Policy, or would like to request more information from us, please contact us by mail at: PE Primer, LLC, Attn: Legal Department, 1317 Edgewater Dr, #2407, Orlando, FL 32804; or, use our interactive webform at: https://pe-primer.com/contact/, or email us at privacy@pe-primer.com.