Introduction

Primo understands that your privacy is important to you and respects your privacy. We are committed to protecting your personal data and remaining compliant with the UK General Data Protection Regulation (UK GDPR) and the EU GDPR. This privacy policy will inform you as to how we collect or use your personal data when you visit or use our website (regardless of where you visit from) or when you use our telecommunications services provided by us and tell you about your privacy rights.

This policy is effective as of 8 August 2025.

Contact Details

What Does This Policy Cover

This privacy policy only applies to your visit or use of our website and other sites that we own and operate or when you use our telecommunications services provided by us.

This privacy policy supplements other notices and privacy policies and is not intended to override them. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data.

This website is not intended for children, and we do not knowingly collect personal data relating to children. By visiting www.primodialler.com or by using the telecommunications services provided by us, you are accepting and consenting to the practices described in this privacy policy.

Third-Party Links

This website may include links to third party websites, plug ins- and application that are not operated by us. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about you.

We do not control these third-party websites and have no control over the content and practices of these websites as well as how your personal data is collected, stored or used by these websites. We cannot accept responsibility or liability for their respective privacy policies.

When you leave our website, we encourage you to read the privacy policy of every website you visit.

What Personal Data do we Collect or Use

Primo collects or uses the following information any time you use Primo’s websites and/or services as well as any time you contact Primo via direct interactions such as telephone calls or email, our Contact Form, Live Chat on our Site:

• Contact information such as name, address, email, phone numbers.
• Payment details (including card or bank information for transfers and direct debits, payment preference, PayPal address).
• Transaction data (including details about payments to and from you and details of products/services that you have purchased).
• Credit history and credit reference information.
• Service usage data (including pages viewed, links clicked, visit duration, time visited, referring/forwarding website, and how you interact with and use our website/services).
• Device information (including IP address, browser type, operating system and unique ID).
• Call metadata (including numbers dialled, call duration, call recordings and timestamps).
• Website and app user journey information.
• Account information (including access information and registration details).
• Client accounts and records.
• Information relating to compliments and complaints.
• Biometric information and identification documents (where used to identify someone or an entity).
• Purchase or service history.
• Website and app user journey information.
• Information used for security purposes.
• Marketing preferences.
• Technical data (including information about browser and operating systems).
• IP addresses.
• Any other personal data required to comply with legal obligations.
• Criminal offence data.

We may keep details about your visit to our site but not limited traffic data, location data, weblogs and other communication data.

We also retain records of your inquiries and correspondences any time you contact Primo.

What Personal Data do we Collect or Use

Primo collects or uses the following information any time you use Primo’s websites and/or services as well as any time you contact Primo via direct interactions such as telephone calls or email, our Contact Form, Live Chat on our Site:

• Contact information such as name, address, email, phone numbers.
• Payment details (including card or bank information for transfers and direct debits, payment preference, PayPal address).
• Transaction data (including details about payments to and from you and details of products/services that you have purchased).
• Credit history and credit reference information.
• Service usage data (including pages viewed, links clicked, visit duration, time visited, referring/forwarding website, and how you interact with and use our website/services).
• Device information (including IP address, browser type, operating system and unique ID).
• Call metadata (including numbers dialled, call duration, call recordings and timestamps).
• Website and app user journey information.
• Account information (including access information and registration details).
• Client accounts and records.
• Information relating to compliments and complaints.
• Biometric information and identification documents (where used to identify someone or an entity).
• Purchase or service history.
• Website and app user journey information.
• Information used for security purposes.
• Marketing preferences.
• Technical data (including information about browser and operating systems).
• IP addresses.
• Any other personal data required to comply with legal obligations.
• Criminal offence data.

We may keep details about your visit to our site but not limited traffic data, location data, weblogs and other communication data.

We also retain records of your inquiries and correspondences any time you contact Primo.

Why do we need to Collect and Store Personal Data

Primo collects or uses various types of personal data any time you use Primo’s websites and/or services as well as any time you contact Primo via direct interactions such as telephone calls or email, our Contact Form, Live Chat on our Site, for the following purposes:

• To provide and improve products and services for clients.
• For the operation of client or customer accounts.
• For call routing.
• For billing.
• For the prevention, detection, investigation or prosecution of crimes.
• For information updates or marketing purposes.
• For surveys, research or archiving purposes.
• To comply with legal requirements.
• To protect client welfare.
• For dealing with emails, queries, complaints or claims.
• To contact you over telephone or email.
• To register you as a new customer in the event you wish to become one.
• To fulfil your requests for articles, newsletters or other content.

How do we use your Personal Data

Our lawful basis for collecting or using your personal data are:

• Consent – we have permission from you after we gave you all the relevant information. All your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use your information so we can enter into or carry out a contract with you or because you have asked Primo to take specific steps before entering a contract. All your data protection rights may apply except the right to object.
• Legal Obligations – we have to collect or use your information so we can comply with the law. All your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All your data protection rights may apply, except the right to erasure and the right to portability.

What are your Rights

You have the following rights which are in brief set out below. You may find out more about your rights and the exemptions which may apply on the ICO’s website.

• Right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
• Right of rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
• Right to erasure – You have the right to ask us to delete your personal information.
• Right to restriction of processing – You have the right to ask us to limit how we can use your personal information.
• Right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
• Right to be informed – You have the right to be informed about our collection and use of personal information.
• Right to object – You have the right to object to certain types of processing for particular purposes.
• Right to object to automated processing, including profiling – You have the right not to be subject to the legal effects of automated processing or profiling.

You are free to refuse our request for your personal data, with the understanding that we may be unable to provide you with some of your desired services.

To make a request, please contact us at hello@primodialler.com and insert “access request” as the subject heading, or write to us at the address provided at the top of this privacy policy under contact details, stating your name and email address for identification purposes. Upon request, we may provide you with a copy of the personal data which we hold about you free of charge. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Please address your requests to change or delete your personal data to hello@primodialler.com and insert “change details” or “unsubscribe” as appropriate as the subject heading. Alternatively, you may write to us at the address provided at the top of this privacy policy under contact details, stating your name and email address for identification purposes. However, take note that it may be impossible to delete your personal data without some residual data because of backups and records of deletions.

Upon request, we may provide you with a copy of the personal data which we hold about you free of charge. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

If you have previously agreed to us collecting or using your personal data to contact you, you may change your mind at any time by writing to us at the address provided at the top of this privacy policy under contact details, or emailing us at hello@primodialler.com. In some cases, withdrawing that consent may prevent us from providing our services to you. We will let you know if that will be the case when you withdraw your consent.

If you have given us consent to contact you by subscribing to us, you will receive occasional Primo news and marketing material. If you would like Primo not to contact you for marketing purposes, you can opt-out at any time by clicking the unsubscribe link in an email or emailing hello@primodialler.com.

We will only perform the activities outlined above to the extent that such activities will not compromise privacy or security interests.

If you do not receive a response to your enquiry – or if you feel your enquiry has not been addressed satisfactorily, you may contact the UK’s Supervising Authority:

Information Commissioner’s Office

Where do we get your Personal Data From

You have the following rights which are in brief set out below. You may find out more about your rights and the exemptions which may apply on the ICO’s website.

• Directly from you.
• Suppliers and service providers.
• Publicly available sources.
• Credit reference agencies.

How Long do we Keep Your Personal Data for

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for and/or for as long as we have your permission to keep it and/or in accordance with the Terms and Conditions. In some cases, your personal data may need to be retained as required by law. 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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. If you wish for your personal data to be deleted before, you can do so by emailing us at hello@primodialler.com.

Your personal data will only be stored within the UK and the European Economic Area (“the EEA”). Data security is important to us, and to protect your personal data, we have taken commercially acceptable measures to safeguard and secure any personal data we hold about you to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification.

Steps we take to secure and protect your personal data include:

Your Acknowledgement of Risk

You acknowledge that Primo cannot guarantee the secure transmission of your personal data through the internet and protection of your personal data due to the nature of the Internet; the website is theoretically accessible by any user of the World Wide Web and any transmission is done so at your own risk. You should be aware that when you disclose personal data on the website, it may be collected by another user and may result in unsolicited messages from other Internet users.

User Responsibility

You must keep your account password secret and notify us immediately using the contact details listed at the top of this privacy policy if you s uspect it has been compromised.

You are responsible for any activity under your account using your password or other credentials.

In case of any breach, you are responsible to notify us immediately using the contact details listed at the top of this privacy policy alongside with what steps you deem necessary to be taken.

Who Do we Share Your Personal Data with and Why

Your personal data may be processed both by us and our affiliates in accordance with this privacy policy. We may pass your personal data on to the following third-party service providers contracted to Primo in the course of dealing with you and they are obliged to keep your details securely, and to use them only to fulfil the service they provide to Primo:

• DCP – this data processor does the following activities for us: Provide server and process stored data on server.
• Hetzner – this data processor does the following activities for us: Provide server and process stored data on server.
• Helpdesk Software – to allow us to manage customer contact.
• Debt Collection Agencies – to allow us to collect outstanding debts.
• Financial Or Fraud Investigation Authorities – to allow us to comply with requests from authorities.
• Professional Or Legal Advisors – to allow us to obtain professional advice.
• Regulatory Authorities – to allow us to comply with requests from authorities.
• Suppliers And Service Providers – to allow us to provide services.

If we wish to pass your personal data onto any other third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

We do not share any personally identifying information publicly.

Sharing Personal Data Outside the UK

Where necessary, we may transfer personal data outside of the UK. When doing so, we comply with the UK GDPR and EU GDPR, making sure appropriate safeguards are in place.

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.

Should your personal data changes during your relationship with us, it is important you inform us using the contact details provided at the top of this privacy policy.

If you have any questions about how Primo uses your personal data that are not answered here, please contact us using the contact details provided at the top of this privacy policy.

How to Complain

If you have any concerns about our use of your personal data, please contact us using the contact details provided at the top of this privacy policy and we will do our best to solve the issue for you.

If we are unable to resolve the problem for you or you remain unhappy with how we have used your information after raising a complaint with us, you can also lodge a complaint with the Information Commissioner's Office.

Information Commissioner’s Office

Changes to this Privacy Policy

We recognise that transparency is an ongoing commitment, so we will keep this Privacy Policy under regular review for operational, legal, or regulatory reasons. Primo may update this policy at different intervals, by updating this page.

It is your responsibility to revisit our website to view this privacy policy from time to time to be aware of any such change.

Any updates will be immediately posted on our website and your continued use of our website will be regarded as your acceptance to any such change of the privacy policy.