Owner and Data Controller
Michael Sloan Managing Director
MAE Ltd t/a Primo IT
Church Court
Belton Street
Shepshed
Leicestershire
LE12 9AB
Owner contact email: sales@primoit.co.uk
Types of Data collected
Among the types of Personal Data that MAE Ltd t/a Primo IT collects, by itself or through third parties, there are:
Cookies; Usage Data; phone number; email address; first name; last name; address; company name; password; billing address; device information; browser information; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using MAE Ltd t/a Primo IT.
Unless specified otherwise, all Data requested by MAE Ltd t/a Primo IT is mandatory and failure to provide this Data may make it impossible for MAE Ltd t/a Primo IT to provide its services. In cases where MAE Ltd t/a Primo IT specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by MAE Ltd t/a Primo IT or by the owners of third-party services used by MAE Ltd t/a Primo IT serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through MAE Ltd t/a Primo IT.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of MAE Ltd t/a Primo IT (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Handling payments, Interaction with live chat platforms, Contacting the User, Analytics, Registration and authentication, Tag Management and SPAM protection.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Analytics collected directly (MAE Ltd t/a Primo IT)
MAE Ltd t/a Primo IT uses an internal analytics system that does not involve third parties.
Personal Data processed: Cookies; Usage Data.
Google Analytics 4 (Google Ireland Limited)
Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of MAE Ltd t/a Primo IT, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: browser information; device information; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
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Contacting the User
Phone contact (MAE Ltd t/a Primo IT)
Users that provided their phone number might be contacted for commercial or promotional purposes related to MAE Ltd t/a Primo IT, as well as for fulfilling support requests.
Personal Data processed: phone number.
Mailing list or newsletter (MAE Ltd t/a Primo IT)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning MAE Ltd t/a Primo IT. Your email address might also be added to this list as a result of signing up to MAE Ltd t/a Primo IT or after making a purchase.
Personal Data processed: address; company name; email address; first name; last name.
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Handling payments
Payment processing services enable MAE Ltd t/a Primo IT to process payments by credit card, bank transfer or other means. To ensure greater security, MAE Ltd t/a Primo IT shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
Sage Pay (Sage Pay Europe Limited)
Sage Pay is a payment service provided by Sage Pay Europe Limited.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: UK – Privacy Policy.
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Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of MAE Ltd t/a Primo IT, for contacting and being contacted by MAE Ltd t/a Primo IT support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
Tawk.to Widget (tawk.to ltd.)
The Tawk.to Widget is a service for interacting with the Tawk.to live chat platform provided by tawk.to ltd.
Personal Data processed: Cookies; Usage Data.
Place of processing: United Kingdom – Privacy Policy.
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Registration and authentication
By registering or authenticating, Users allow MAE Ltd t/a Primo IT to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, MAE Ltd t/a Primo IT will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Direct registration (MAE Ltd t/a Primo IT)
The User registers by filling out the registration form and providing the Personal Data directly to MAE Ltd t/a Primo IT.
Personal Data processed: billing address; company name; email address; first name; last name; password.
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SPAM protection
This type of service analyzes the traffic of MAE Ltd t/a Primo IT, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Google reCAPTCHA (Google Ireland Limited)
Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on MAE Ltd t/a Primo IT in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
Further information about the processing of Personal Data
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GatorLeads
GatorLeads is a tool that identifies the business or organisation that website visitors belong to, based on a reverse IP Lookup. GatorLeads also use cookies to process this identification, and personal information about individual users is stored. Cookies used by GatorLeads store information about your current web browsing session (pages viewed, time on site etc) and the dates and times of previous website visits.
This information is used by Primo IT to profile website visitors, in order to better understand the way in which our website content is viewed by different segments. It is also used to identify the types of organisations that might be interested in our products or services.
We use a combination of both session and persistent cookies. Session cookies keep track of your current visit and how you navigate the site, persistent cookies enable our website to recognise you as a repeat visitor when you return. The session cookies will be deleted from your computer when you close your browser. Persistent cookies will be removed on a pre-determined expiry date, or when deleted by you.
The cookies used are;
wow.anonymousId
wow.data
wow.schedule
wow.session
wow.trackingData
wow.utmvalues
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ProspectSoft CRM
Prospect is our on premise CRM solution
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Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by MAE Ltd t/a Primo IT depends on the payment system used.
Cookie Policy
MAE Ltd t/a Primo IT uses Trackers. To learn more, Users may consult the Cookie Policy.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of MAE Ltd t/a Primo IT or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, MAE Ltd t/a Primo IT may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, MAE Ltd t/a Primo IT and any third-party services may collect files that record interaction with MAE Ltd t/a Primo IT (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within MAE Ltd t/a Primo IT and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through MAE Ltd t/a Primo IT (or third-party services employed in MAE Ltd t/a Primo IT), which can include: the IP addresses or domain names of the computers utilized by the Users who use MAE Ltd t/a Primo IT, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using MAE Ltd t/a Primo IT who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of MAE Ltd t/a Primo IT. The Data Controller, unless otherwise specified, is the Owner of MAE Ltd t/a Primo IT.
MAE Ltd t/a Primo IT (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by MAE Ltd t/a Primo IT as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to MAE Ltd t/a Primo IT, if not stated otherwise within this document.