PRIMIS PRIVACY NOTICE

This Privacy Notice (“Privacy Notice”) sets out how M.D. Primis Technologies Ltd., previously known as McCann Disciplines Ltd., (“Primis”, “we”, “our”) governs the processing and transfer of data collected in connection with our websites, available at: www.primis.tech,  (each a “Website” and together the “Websites”) analytics tools, sites, platforms, as well as data that is otherwise processed by us through other technical applications that we may provide through our customers and third-party websites (collectively, “Services”), to each person accessing or using the Websites and/or the Services, including our Partners and End-Users (the “User” or “you”). 

• This Privacy Notice is an integral part of our Publisher Terms and Conditions and Website Terms and Conditions as applicable, which can be found at: https://www.primis.tech/publishing-agreement-general-tc/ and   https://sellers.guide/terms(together the “Terms”). Please note that if you are an End-User (as defined below) the Terms may not be applicable to you, thus only this Privacy Notice shall apply to you. 
• Primis’s Services, provided by Primis, include (i) an online platform enabling an advertiser (“Advertiser”) to display advertisements and marketing materials by video to End-Users who use or otherwise interact with certain web-pages owned by publishers we engaged with (respectively, “End-Users”, and “Publishers”); (ii) and online search engine which help publishers and buyers gain insight into the authenticity of the parties who mediate between them. 
• We may process data collected through the Websites and/or Services in various ways, depending on whether: (i) you are an Advertiser, Publisher or other content provider with whom Primis has a contractual relationship (“Partner(s)”); (ii) you are a visitor of our Websites; or (iii) you are an End-User using or visiting our Partners websites or platforms. 
• This Privacy Notice explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it and how you may exercise your rights associated with your Personal Data (as defined below), including, where applicable, as required under the EU General Data Protection Regulation (“GDPR”), the Brazilian General Data Protection Law (as amended by Law No. 13,853/2019) (“LGPD“),  the California Consumer Privacy Act (“CCPA”) and additional US data protection laws as detailed below. 
• You may not use the Services or the Websites or submit any data through them if you do not agree to any of the terms hereunder. This Privacy Notice shall not be construed in any manner to derogate from the Terms or any other agreement or understanding between Primis and you.
• Please note, that the Websites and/or Services may contain links to other websites, products or services offered by third parties, which are not governed by this Privacy Notice. This Privacy Notice does not apply to the practices of entities which are not controlled by Primis. 
• If you are a Partner, please note that additional terms may be applicable to you in connection with the processing of Personal Data by you regarding your users and customers, as further specified in the relevant Data Processing Agreement.

Primis is considered as the “Data Controller” of the Personal Data we collect from our Websites visitors and Partners directly, as further detailed below. As with respect to Personal Data we collect regarding our End Users we act as a Data Processor. Even as a Processor, we will assist our Partners, the Data Controllers to comply with applicable laws and respect your rights. 

M.D. Primis Technologies Ltd, at 2 Raoul Wallenberg St., Tel Aviv, 6971902 Israel

You may contact us and our privacy team by email: privacy@primis.tech

M.D. Primis Technologies Ltd participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. operates Consent Management Platform with the identification number 228

“Personal Data” means any information which identifies or can be used to identify a natural person, including, but not limited to, first and last name, phone number, email address, IP address, billing information, etc.

“Non-Personal Data” means non-identifiable information, for example we may collect information regarding Users concerning their use of the Websites and Services, such as the scope, frequency, latency, pages accessed, what and when a User views or interacts with content and materials displayed through our Services, device specifications, and other technical information regarding the device used to access the Services, such as model, operating system, etc.

We collect certain information about you and your use of the Websites and Services, including information we collect from you directly (e.g. when you contact us directly we will collect your contact details) and information we collect about you from others (e.g. certain cookies of third parties (please see below for more information about cookies)). Such information may include Personal Data and Non-Personal Data.

We use the data collected from Users for the specific purposes listed in the table below. Please note that this table explains:

• The types of Personal Data and Non-Personal Data we collect from Users; and

The legal basis for processing your Personal Data, linked to each processing purpose;

We do not knowingly collect or process any Special Categories of Personal Data (as defined in the GDPR) or Sensitive Personal Data (as defined under the LGPD). Please contact us immediately in the event you become aware of the fact that such data has been posted to the Websites or collected or processed by us.

With to the GDPR, we act as a Processor of certain Personal Data, such as End-Users’ IP address and other online identifiers, on behalf of our Partners. We are also a Controller of certain Personal Data, such as our Partner’s data, or if individuals contact us or use our Websites.

Please note that, the actual processing operation per each purpose of use and lawful basis detailed in the table above, may differ. Such processing operation usually includes set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. Transfer of personal data to third party countries as further detailed in the Data Transfer section is based on the same lawful basis as stipulated in the table above. 

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on out legitimate interests.

We would like to provide clarity on our involvement in the processing of End User Data, as this plays a crucial role in the services that we offer to our Partners. The usual practice involves us, or our partners, serving advertisements tailored to your preferences and interests. This approach employs cross-contextual, interest-based methods and is rooted in the consent for processing Personal Data, as outlined in the table above. This consent is also communicated to our partners to guide their actions. However, in certain situations, we use data – including Personal Data like Online Identifiers – to refine our services or to technically facilitate the delivery of advertisements. During these instances, the processing is based on our legitimate interest, a key factor in ensuring our platform and services remain operational and effective. End Users should anticipate this kind of processing. We are committed to respecting and protecting your privacy rights, a factor we deem to be of paramount importance. We consistently adhere to rigorous privacy standards and regulations. Moreover, we maintain an open dialogue about our data processing activities and equip you with the necessary tools to manage your preferences and opt-out if desired. We would also like to emphasize that we conduct an in-depth balancing test. This is to ensure our legitimate interest doesn’t infringe excessively on your rights and freedoms, maintaining an equilibrium that respects all parties involved.

Depending on the nature of your interaction with the Website and Services, we may collect information either automatically or voluntarily provided by you or the Partners. 

• Automatically – we may use cookies (as elaborated in the section below) or similar tracking technologies in connection with our Site.  The way in which we, and third parties placing cookies in connection with the Services, use cookies and collect data, is explained in our Cookie Policy. We further automatically process and collect the End-User on behalf of the Partner. 
• Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through a physical agreement, contact us communications, etc. all as detailed in this Privacy Policy.
• Provided by our Partners and Cookie Management Platforms implemented in our Partner’s assets.

We use data files such as cookies, pixel tags, “Flash cookies,” or other local storage files provided by your browser or associated applications (“Cookies”). We use these technologies in order to recognize you as an End-User; customize our Services, content, and advertising; measure promotional effectiveness; help ensure that your account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety across our Websites and Services. For more information please refer to our Cookie Policy.

In addition, every user that interacts with our Services will be assigned with a unique ID. We use the unique ID similar to how we use cookies, for marketing purposes and in order to customize the Service and content as well as enhance your experience.

Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion. This information does not contain Personal Data and is used to develop content and services for our Users and clients. We use third-party advertising companies to serve ads when you visit our Websites and/or Services. These companies may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please press here and here in order to opt-out.

We share Personal Data only under the following limited circumstances:

• For personalizing your experience in the Services, including by way of targeted advertising on the Websites we may share the Data Regarding End-Users with our Partners which use our Services and implemented on their websites and platforms our solution. In addition, we may provide our Partners with insights and reports that include information on the ad campaigns and how effective such campaign was.  
• We may disclose all of the data we collect with trusted partners and third parties who assist us in operating the Services and conducting our business, such as fraud prevention, bill collection, account maintenance, marketing and technology services.
• We may share your Personal Data with a parent company, subsidiaries, joint ventures, or other companies under common control with us (“Affiliated Companies”) solely if and when applicable or necessary. In addition, we may share information, in the event of a corporate transaction (e.g. sale, merger, consolidation, etc.), provided however, that our Affiliated Companies or acquiring company will be subject to the obligations detailed herein with respect to your Personal Data.
• To comply with a legal requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.
• Other third parties with your consent or direction to do so.

You may have certain rights regarding the Personal Data that Primis has collected about you, note, we provide all individuals, regardless of where you are based, the same opportunity to exercise your rights.

Since different Users have different privacy rights under applicable laws, we provide you with the ability to exercise certain choices, rights and controls in connection with your data, depending on your relationship with us and the applicable laws. For instance, if you are a visitor of our Websites, a Partner or an End-User, you may be entitled to different rights under applicable data protection and privacy laws, including (and depending on your jurisdiction):

• The right to access Personal Data that we process about you;
• The right to ensure your Personal Data is accurate, complete and up to date;
• The right to ask that we delete your Personal Data (to the extent practical and applicable);
• The right to object to the processing of your Personal Data, to the extent applicable;
• The right to request the portability of your Personal Data;
• The right to file a complaint with a supervisory authority or national authority; 
• The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice; 
• The right to not be discriminated against when you request to exercise your rights; 
• The right to submit an opt-out (e.g. “do not sell”) request, where applicable; 
• The right to anonymize, block, or delete unnecessary or excessive processing of Personal Data or Personal Data that is not being processed in compliance with the LGPD; 
• The right to receive information regarding the public and private entities with which we have shared your Personal Data with; and
• The right to receive information about the possibility of denying consent and the consequences of such denial. 

We provide you with the ability to exercise your rights, depending on your relationship with us. You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request (“DSR”) form available here and send it to us at: privacy@primis.tech. 

We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.

Interest-Based Advertising (“IBA“): We do not sell your Personal Data. We may “share” your Personal Data with third parties for personalized advertising purposes. If you wish to opt-out from the sharing of your personal data with third parties for the purpose of cross-contextual interest-based advertising there are many way to do so, as further detailed below. Please note that even if you opt-out you may still see personalized ads based on information other companies and ad networks have collected about you, if you have not opted out of sharing with them.

For IBA opt out options on desktop and mobile websites, please visit: 

• Digital Advertising Alliance (US) https://www.aboutads.info/choices/
• Digital Advertising Alliance (Canada) https://youradchoices.ca/en/tools
• Digital Advertising Alliance (EU) https://www.youronlinechoices.com/
• Network Advertising Initiative https://optout.networkadvertising.org/?c=1

Further, on every webpage or app you browse there are “cookie settings” through which you may opt out. Additional information on opt-out rights and means are available through our DSR form.

Basically, we only keep your data as long as required to fulfill the purpose for which the data was collected, or as we are required by law. 

We retain the data we collect solely for as long as required to fulfil the purposes for which it was initially collected, or for longer periods in the event we are required to do so in order to comply with legal, tax and accounting requirements. In addition, we will retain information we believe is needed in order to protect our rights and interests in accordance with applicable laws. See the table below for additional information regarding our data retention policy for different types of Personal Data.

Our databases are currently located in the Netherlands and the U.S. Some of our processing activities are done in Israel. The European Commission has decided that the State of Israel ensures an adequate level of privacy and data protection, therefore, in accordance with the GDPR, the transfer of Personal Data from the EU to Israel is lawful and does not require any specific authorization.

 If you are a resident of the European Economic Area (“EEA“) we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such data transfer.

Please see below the table detailing the transfer of the data outside the EEA:

Primis may send you offers that may be of special interest to you via email or SMS. You may unsubscribe from receiving such communications at any time, by sending us a notification to: privacy@primis.tech, or following the instructions for unsubscribing that are included in such communications.  

We may also engage with third parties to track and report performance of advertising and marketing campaigns to and from Primis and third party web sites. We may combine your information with information we collect from third parties and use it to improve and personalize our Services, content, and advertising.

Our Websites and/or Services are intended for a general audience, which is not directed to persons under 16 years old. If a parent or guardian becomes aware that his/her child has provided us with Personal Data without their consent, he/she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 16 years old. If we become aware that a person under 16 years old has provided us with Personal Data, we will delete such data from our databases.

We reserve the right to periodically revise or update this Privacy Notice. Any modifications to this Privacy Notice will go into effect upon the publication of the revised Privacy Notice on our Websites. The last revision date will be reflected in the “Recently Updated” heading located at the top of the notice. 

We will make a reasonable effort to provide notification in the event that we implement any amendments that substantially change our privacy practices. We recommend that you review this page periodically to ensure that you understand our privacy practices and to check for any amendments.

If you have any questions or concerns regarding privacy issues, please send us a detailed message to privacy@primis.tech, or via regular mail to: M.D. Primis Technologies Ltd, at 2 Raoul Wallenberg St., Tel Aviv, 6971902 Israel and we will make every effort to resolve your concerns without delay.

You may also be entitled to file a complaint with the appropriate supervisory authority or national authority (depending on your jurisdiction) in connection with any concerns you may have with regards to your privacy.

APPLICABILITY: The California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2020effective January 1, 2023 (“CPRA”), any other California privacy laws, and this CCPA Notice apply to visitors, employees, users, applicants for employment, and independent contractors, and others who are California residents (“consumers” or “you”). Any terms defined in the CCPA and CPRA have the same meaning when used in this CCPA Notice. This CCPA Notice applies to California residents’ Personal Information, which we collect directly or indirectly while using our Service or in order to provide our Services, or employee and business-to-business Personal Information. 

This CCPA Notice is an integral part of our Privacy Policy, and thus, definitions used herein shall have the same meaning as defined in the Privacy Notice.

(A) CATEGORIES OF PERSONAL INFORMATION WE COLLECT

We collect Personal Information which is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device, all as detailed in the table below. 

Personal Information further includes Sensitive Personal Information (“SPI”) as detailed in the table below. 

Personal Information does not include: Publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; De-identified or aggregated consumer information; Information excluded from the CCPA’s or CPRA’s scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

We have collected the following categories of personal information within the last twelve (12) months:

• Directly and indirectly from activity on our website: For example, directly from you when you inquire about our Services via our website, or indirectly, we collect your usage data automatically from measurement tools. 
• Directly from you: For example, from forms you complete, contact us, etc. 
• Indirectly from you: we track your activities across the internet, for example, when you view or interact with certain content, web page or ad. 
• From third-parties: For example, from vendors who assist us in performing services for consumers, advertising networks, internet service providers, data analytics providers, social networks, and data brokers.

We may use the Personal Information collected as identified above, for the following purposes: To fulfill or meet the reason you provided the Personal Information (support, respond to a query, review the CV considered for a job posting, evaluating your qualifications for that position, etc.); monitor and improve our Services; provide the Services; marketing our Services; analyzing our Services and your use of the Services and website; respond to law enforcement; or otherwise as detailed in our Privacy Notice. 

We will not collect additional categories of personal information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice. 

We may disclose your Personal Information to a contractor or service provider for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract, we further restrict the contractor and service provider from selling or sharing your Personal Information. In the preceding twelve (12) months, we disclosed the following categories of Personal Information for a business purpose: 

In the preceding twelve (12) months, we do not “sell” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Information in direct exchange for money or some other form of payment.  We may “share” Personal Information for “interest-based advertising” or “cross-context behavioral advertising”. The CCPA defines “sharing” as “communicating orally, in writing, or by electronic or other means, a consumer’s personal information” to “a third party for cross-context behavioral advertising, whether or not for money or other valuable consideration”. In other words, we may share your Personal Information with a third party to help serve personalized content or ads that may be more relevant to your interests, and to perform other advertising-related services such as enabling our partners to serve such personalized content.  

Further, as we promote our Service through online campaigns, we place third-party marketing and analytic cookies on our website, sharing the unique identifier with such partners for analytic and marketing purposes may also fall under the definition or “share and sell” therefore, we offer the opportunity to opt-out as detailed below

In the preceding twelve (12) months, we “sell” or “share” the following categories of Personal Information for a business purpose: 

We do not knowingly collect information from children under the age of 16.

The retention periods are determined according to the following criteria:

1. For as long as it remains necessary in order to achieve the purpose for which the Personal Information was initially processed. For example: if you contacted us, we will retain your contact information at least until we will address your inquiry.
2. To comply with our regulatory obligations. For example: transactional data will be retained for up to seven years (or even more under certain circumstances) for compliance with our bookkeeping obligations purposes.
3. To resolve a claim we might have or a dispute with you, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.

Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.

Online identifiers are usually kept for a few days. Other information usually will not be retained for more than 24-months. 

When we destroy your Personal Information, we do so in a way that prevents that information from being restored or reconstructed.

If you are a California resident, you may exercise certain privacy rights related to your Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. We may limit our response to your exercise of these privacy rights as permitted under applicable law, all as detailed herein and the in the Data Subject Request Form 

As a third-party business, we do not have a direct interaction with the end-user, however we provide option to opt out of Sharing for Cross-Contextual Behavioral Advertising or Selling Personal Information by using the following opt-out options: 

• Use the “Do Not Sell or Share My Information” through the first-party business, i.e., through the cookie consent manager presented on the browser or app you are using.

• To opt out of the sale or share of Personal Information, you may also directly opt out from third party retargeting cookies or other ad-technology trackers through self-regulatory services. For more information, please visit:

Digital Advertising Alliance (US) HERE

Digital Advertising Alliance (Canada) HERE

Digital Advertising Alliance (EU)HERE 

Network Advertising Initiative HERE

You can also opt out of interest-based advertising with some of the service providers we use, such as Google HERE, Google Analytic HERE. 

In addition, you may opt out from our Search Partners at the following links: 

Microsoft (Bing): Microsoft’s opt out information which will enable you to limit data collection by Microsoft is available HERE. 

Oath (Yahoo): Oath’s opt out information which will enable you to limit data collection by Oath is available HERE. 

For further information about the opt out options, please visit our Privacy Policy.

• California resident and wish to opt-out from having your data used for the Apps, you may exercise your right here: https://optout.privacyrights.info/. 

Other rights may be exercised by using the Data Subject Request Form, the Instructions for submitting, the general description of the process, verification requirements, when applicable, including any information the consumer or employee must provide are all detailed in the Data Subject Request Form.

“Authorized agents” may submit opt out requests on a consumer’s behalf. If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer. Usually, we will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that the third party successfully completes the following qualification procedures:

a.When a consumer uses an authorized agent to submit a request to know or a request to delete, a business may require that the consumer do the following:

1. 1. Provide the authorized agent signed permission to do so or power of attorney. 
   2. Verify their own identity directly with the business.
   3. Directly confirm with the business that they provided the authorized agent permission to submit the request.

b. business may deny a request from an authorized agent that does not sub

We do not offer financial incentives to consumers for providing Personal Information.

M.D. Primis Technologies Ltd. (Previously known as McCann Disciplines Ltd.)  

M.D. Primis Technologies Tel Aviv, at 2 Raoul Wallenberg St., Tel Aviv, 6971902 Israel

privacy@primis.tech.

UPDATES:

This notice was last updated on December 14th, 2022. As required under the CCPA, we will update our Privacy Policy every 12 months. The last revision date will be reflected in the “Last Modified” heading at the top of this Privacy Policy.

Direct Marketing Requests: California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please use Data Subject Request Form.

Do Not Track Settings: Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we so not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us. 

California’s “Shine the Light” law (Civil Code Section § 1798.83): permits employees that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us the Data Subject Request Form.

Under the Colorado Privacy Act (“CPA”) if you are a resident of Colorado, acting only as an individual or household context (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context), your rights with respect to your personal data are described below.

“Personal Data” as defined in the CPA means: “information that is linked or reasonably linkable to an identified or identifiable individual” and does not include any of the following: publicly available information, de-identified or aggregated consumer, and information excluded from the CPA scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) or 42 CFR Part 2- “Confidentiality Of Substance Use Disorder Patient Records”, Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or and the Driver’s Privacy Protection Act of 1994, Children’s Online Policy Protection Act of 1998 (COPPA), Family Educational Rights and Privacy Act of 1974, national Security Exchange Act of 1934, higher education data and employment data.

Sensitive Data includes (i) racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life or sexual orientation; (ii) Genetic or biometric data that can be processed to uniquely identify an individual; or (iii) child data. We do not process or collect any sensitive data. 

Section “What kinds of Personal Data does Primis collect and process” of the Privacy Policy, we describe our collection and processing of personal data, the categories of personal data that are collected or processed, and the purposes. Additionally, in Section “Will Primis Share My Personal Data with Others” details the categories of third-parties the controller shares for business purposes. 

YOUR RIGHTS UNDER CPA:

Herein below, we will detail how consumers can exercise their rights, and appeal such decision, or if Primis sells the personal data, or sells the personal data for advertising and how to opt-out.

HOW TO SUBMIT A REQUEST UNDER CPA? 

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Data. If the DSR is submitted by someone other than the consumer about whom information is being requested, proof of authorization (such as power of attorney or probate documents) will be required. 

We will respond to your request within 45 days after receipt of a verifiable Consumer Request and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@primis.tech and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Colorado AG at https://coag.gov/file-complaint/ 

If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request. 

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

Under the Virginia Consumer Data Protection Act, as amended (“VCDPA”) if you are a resident of Virginia acting in an individual or household context (and not in an employment or commercial context), you have the following rights with respect to your Personal Data.

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information. Personal Data does not include de-identified data or publicly available data, and information excluded from the scope such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver’s Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act. 

The VCDPA requires Primis discloses the Categories of data processing and the purpose of each category, as detailed 

in Section “What kinds of Personal Data does Primis collect and process” of the Privacy Policy, the categories of data shared and the third parties with whom it is shared, as detailed in Section ‎“Will Primis Share My Personal Data with Others”. Disclosure of sale of data or targeted advertising are detailed in Section OPT OUT OPTIONS above, and in the DSR Form. Further, the table above under Section  “ADDITIONAL NOTICE TO COLORADO RESIDENTS” details the rights you have under VCDPA and how you may exercise your rights. 

HOW TO SUBMIT A REQUEST UNDER VCDPA? 

We shall respond to your request within 45 days of receipt. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@primis.tech and specifying you wish to appeal.  Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request we will not be able to grant your request.

Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (the “CDPA”) if you are a resident of Connecticut, acting in an individual or household context (and not in a commercial or employment context or as a representative of business, non-profit or governmental entity), your rights with respect to your personal data are described below.

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable individual. It does not include de-identified data or publicly available information. If further does not include information excluded from the scope such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver’s Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act. 

The categories of personal data processed, purpose of processing, are detailed in Section “What kinds of Personal Data does Primis collect and process”, categories of personal data shared with third parties, categories of third parties with whom data is shared, are detailed in Section “Will Primis Share My Personal Data with Others”. Disclosure of sale of data or targeted advertising are detailed in Section OPT OUT OPTIONS above, and in the DSR Form. 

Instructions on how to exercise your rights are detailed in the table above under Section ‎“ADDITIONAL NOTICE TO COLORADO RESIDENTS” details the rights you have under CDPA and how you may exercise your rights. 

HOW TO SUBMIT A REQUEST UNDER CDPA? 

We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests and we inform you of such extension within the initial 45 day response period, together with the reason for the extension.

If we decline to take action on your request, we shall so inform you without undue delay, within 45 days of receipt of your request. The notification will include a justification for declining to take action and instructions on how you may appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Connecticut Attorney General at link: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

Under the Utah Consumer Privacy Act (the “UCPA”) if you are a resident of Utah, acting in an individual or household context (and not in a commercial or employment context) your rights with respect to your personal data are described below. “Personal Data” refers that is linked or reasonably linkable to an identifiable individual, and does not include de-identified data and publicly available data.  

The categories of personal data processed, purpose of processing, are detailed in Section “What kinds of Personal Data does Primis collect and process”, categories of personal data shared with third parties, categories of third parties with whom data is shared, are detailed in Section “Will Primis Share My Personal Data with Others”. Disclosure of sale of data or targeted advertising are detailed in Section ‎1.8 OPT OUT OPTIONS above, and in the DSR Form. 

Further, the table above under Section ‎ “ADDITIONAL NOTICE TO COLORADO RESIDENTS” details the rights you have under CDPA and how you may exercise your rights.

Nevada law allows Nevada residents to opt out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We currently do not sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and will record your instructions and incorporate them in the future if our policy changes. You may send opt-out requests to privacy@primis.tech.

Primis – Video Discovery, part of McCann Israel Group (McCann Disciplines Ltd.) (Collectively, “McCann” “Primis”, “we”, “our”) values the privacy rights of our Users. Thus, we have designed this User Privacy Rights Policy (“User Rights Policy” or “Policy”) as an overview of your rights regarding your personal data, under the following legislation:

(i) The EU General Data Protection Regulation (“GDPR”), which shall apply to you in the event you are a resident of the European Economic Area (“EEA”); and

(ii) The California Consumer Privacy Act of 2018 (“CCPA” or “Act”) which shall apply to you in the event you are a “California Resident”, as defined under the CCPA; and

(iii) The Brazilian General Data Protection Law (as amended by Law No. 13,853/2019) (“LGPD”), which shall apply to you in the event that you are located in the national territory of the Federative Republic of Brazil (“Brazil”) at the time of the collection of your Personal Data (as such term is defined under the LGPD).

This Policy applies solely to your rights concerning Personal Data or Personal Information (as defined under the applicable law) processed by us. If you wish to submit a request to exercise any of your rights please send it to us at: privacy@primis.tech.

You have the right to be informed with respect to our details (e.g. name, address, etc.), as well as why and how we process Personal Data. This right includes, among others, the right to be informed of the identity of the business, the reasons and lawful basis for processing Personal Data, and additional information necessary to ensure the fair and transparent processing of Personal Data. You also have the right to receive information about public and private entities with which we shared your Personal Data. Furthermore, you have the right to be informed of the categories of Personal Information collected, sold, disclosed by us in the previous 12 months, therefore we ensure our Privacy Notice discloses all of the above and is updated every 12 months.

You have a right to request us to confirm whether we process certain Personal Data related you, as well as a right to obtain a copy of such Personal Data, with additional information regarding how and why we use this Personal Data. After we receive such request, we will analyze and determine the veracity and appropriateness of the access request and provide you with the applicable confirmation of processing, the copy of the Personal Data or a description of the Personal Data and categories of data processed, the purpose for which such data is being held and processed, and details about the source of the Personal Data if not provided by you. Our response detailed above will be provided within the period required by law (please see additional information under “Response Timing and Format” below). Notwithstanding the above, the GDPR and CCPA provide different protections, the GDPR enables access to all Personal Data processed by a controller, however the CCPA access right applies only to Personal Information collected in the 12 months prior to the request.

If Personal Data held by us is not accurate, incomplete or out-of-date, you may require us to update such data so it will be correct. Furthermore, in the event we have passed on incorrect information about you to a third party, you also have a right to oblige us to inform those third parties that the applicable information should be updated.

We are legally obligated to comply with a request to delete Personal Data if: the data is no longer needed for the original purpose and no new lawful purpose exists for continued processing; the lawful basis for processing is consent of the data subject and such consent is withdrawn; the data subject exercises his or her right to object to our processing of his or her Personal Data, and we have no overriding grounds for processing the data; the Personal Data is processed unlawfully; or the erasure of the Personal Data is necessary to comply with applicable laws.

In addition, if we transferred Personal Data to a third party, a data subject also has a right to oblige us to tell those third parties that the information should be erased. The right to erasure is not absolute. Even if a data subject falls into one of the categories described above, we are entitled to reject the data subject’s request and continue processing data if such processing is (depending on the relevant law that applies to you): necessary to comply with legal or regulatory obligations; necessary to establish, exercise or defend legal claims; is necessary for scientific research etc.; necessary to perform a contract between you and us; necessary to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity; necessary to debug to identify and repair errors that impair existing intended functionality; or solely for our internal use that are reasonably aligned with your expectations based on our relationship with you (under the LGPD your Personal Data will have to be anonymized if used for this purpose) – all subject to applicable laws.

With regards to Personal Data processed by us under the lawful basis of our legitimate interests (such as direct marketing), you may object to our processing on such grounds. However, even if we receive your objection, we will be permitted to continue processing the Personal Data in the event that (subject to applicable laws and regulations):

(i) our legitimate interests for processing override your rights, interests and freedoms.

(ii) the processing of such Personal Data is necessary to establish, exercise or defend a legal claim or right, etc.

A data subject may limit the purposes for which we may process his/her Personal Data. Our processing activities may be restricted if: the accuracy of the data is contested; processing is unlawful and data subject requests restriction instead of erasure; we no longer need the data for its original purpose, but the data is still required to establish, exercise or defend legal rights; or consideration of overriding grounds in the context of an erasure request.

You may request us to send or “port” your Personal Data that is held by us to a third-party entity, however note, the GDPR, the LGPD and the CCPA apply differently to this right, thus, we will handle this according to your relevant jurisdiction.

Do Not Sell You have the right to know what Personal Data is sold, to whom and for what purpose. You also have the right to request the data not to be sold. Note, “selling” data under the CCPA includes any transfer of data for the purpose of receiving valuable goods.

Under the CCPA, you must not be discriminated against for exercising any of your rights, including: by being denied goods or services; being charged different fees for goods or services, including through the use of discounts or other benefits or imposing penalties; it being suggested that you will receive a different price or rate for goods or services if you exercise your rights. Notwithstanding the above, it is permitted to set up schemes for providing financial incentives and you can opt-in to become part of them.

You have the right to request that we anonymize, block, or delete unnecessary or excessive processing of your Personal Data or Personal Data that is not being processed in compliance with the LGPD. You also have the right to receive information from us about the possibility of your denying consent and the consequences of such denial.

1. Time. We endeavor to respond to a verifiable consumer request without undue delay and in any event within 30 days from the receipt of the request subject to GDPR, within 15 days (with respect to some of the rights above) from the receipt by us of your request, in accordance with the LGPD and between 10-45 days from the receipt by us of a request subject to CCPA.

2. Extension. If we require more time, we will inform you of the reason and extension period in writing.

3. Reponse. The response we provide you with will explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

4. Fees. If you were in Brazil at the time the relevant Personal Data was being processed you will not be subject to any fees in connection with your request. If you do not fall under the jurisdiction of the LGPD, we will also not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Furthermore, please note, that under the CCPA you are not entitled to submit more than 2 requests in a 12 month period.

Please submit a request by:
* Emailing us at privacy@primis.tech.

This Cookie Policy explains what cookies are and how we and third parties use them. For further information on how we use, store and process Personal Data, see our Privacy Notice.

This Cookie Policy includes the following information:
1. Cookies and similar technologies
2. Types of cookies
3. What Information Do We Collect?
4. How To Manage Cookies
5. Changes and Updates6. Cookies used on our Site
7. Cookies used through our Services

1.1. A cookie is a small text file that is placed on the browser of your computer or mobile device (or other end device), by websites you visit and applications you use. Other automated means often used on websites and applications are Pixel tags (also known as web beacons or clear GIFs). Pixel tags are typically transparent graphic images placed on a website. These pixels are used in combination with cookies to measure the actions of visitors on the website.

Most websites and applications use cookies and other automated means to collect certain data and facilitate services. Cookies are typically used in order to make websites function, or function more efficiently, make your experience when browsing the website or application more enjoyable and smooth, to remember your preferences, to autocomplete details so you don’t have to insert your full details every time you log in (such as user name and password), to tailor content and information that is displayed to you and otherwise work to personalize your experience of the website or application. Cookies are also commonly used a tools enabling websites and applications owners to better understand the use of their products and services, to conduct business analytics and to engage in advertising activities for their business purposes or on behalf of third parties.

1.2. There are different types of cookies. Some cookies come directly from the website or application you are browsing and others come from third parties which place cookies on such site. Such types of cookies are commonly categorized as “First Party Cookies” and “Third Party Cookies”, respectively.

1.3. Cookies can be stored for varying lengths of time on your browser or device. “Session Cookies” are limited to the duration of you visit to the relevant website or application, and are terminated when you exit the website or application. “Persistent Cookies” will remain stored on your computer or device until deleted or until they reach their expiry date.

2.1. Strictly Necessary Cookies – These cookies are necessary to enable the communication between the user’s device and the website or application, or to provide the user with services requested by him/her, such cookies are used for the sole purpose of carrying out a transmission of a communication over an electronic communications network, or to allow the provider of an online service to provide its services as explicitly requested by users.

2.2. Functionality Cookies – These cookies allow the website or application to remember choices the user made (such as username, password, language preferences, or region) and provide enhanced, more personal features, to improve the user’s experience on the website or application.

2.3. Performance (Analytic) Cookies – These cookies collect information about how visitors use the website or application, such as which pages visitors go to most often and if they are likely to get error messages from certain pages. These cookies collect aggregate information that does not identify a specific user personally. These cookies are used to improve how a website or application works, analyze use patterns of the website or application, and assist the provider to maintain and improve its services.

2.4. Advertising (Targeting) Cookies – These cookies are used to deliver personalized advertisements to the user. Such cookies may be used to analyze a user’s preferences in accordance with the contextual information about the user’s activities on the website or application (for example, if a user is surfing a webpage displaying an article about a sporting event, cookies may be used to display to the user an advertisement associated with sports fans), or to correlate between a user and information about such user collected from other websites or applications (for example, to display to the user an advertisement associated with sports fans based on the user’s profile in other websites or applications). These cookies are used to promote advertising campaigns of website and application owners or those of third parties, as well as help measure the effectiveness of an advertising campaign.

Advertising cookies are usually placed by advertising networks, which connect between the relevant advertiser and the location of publication of the advertisement.

3.1. Cookies used on our Website – our Website contains both First Party Cookies and Third Party Cookies, Strictly Necessary Cookies, Functionality Cookies, Performance (Analytic) Cookies, and Advertising (Targeting) Cookies.

3.2. information collected through on our Website through the use of cookies includes:

• Information about your operating system and device;

• Webpages accessed within our Website, the link that led you to our Website, dates and times you accessed our Website, event information (e.g. system crashes) and general location information (i.e. city or region).

• Information provided on the Website by users in order to streamline the user’s experience and prevent user from having to re-enter information during the next visit to our Website;

• Number of visitors on our Website and which webpages have been viewed;

• Advertising user ID and information associated with targeted advertising.

3.3. Cookies used through our Services – In connection with digital advertising services provided to our Partners by us or other entities within the McCann group, we may use the information collected via cookies on the websites of our customers to make your use of their services and products more enjoyable, to promote their advertising campaigns, to improve the functionality of their services, and tailor the content and information that it displayed to you. We may also use pixel tags on the websites of our customers to track conversions or to create a custom audience for our advertiser customers to target on our network (i.e. retargeting).

See below links to common browsers enabling the control of cookies:

5.1. We may update this Cookie Policy from time to time. We encourage you to periodically review this Cookie Policy to stay informed about our use of cookies, the information we collect via cookies, and any updates in relation thereto.

5.2. We will post any changes to this Cookie Policy on our Website.

The following cookies are used on our Website:

You may also encounter McCann Cookies on websites that we do not control. Likewise, certain third parties may place their own Cookies in the Website and Services. Such third party Cookies are not subject to our control and this Notice does not cover them. If you are located in the EEA when accessing our Website, the use of persistent and third party cookies will comply with the laws applicable to you.

M.D. Primis Technologies Ltd. (previously known as McCann Disciplines Ltd.) (“Company”) values privacy rights. As required under applicable law, and specifically the EU General Data Protection Regulations (“GDPR”), the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2020 effective January 1, 2023 (“CPRA”), the Virginia Consumer Data Protection Act of 2021 (“CDPA”), the Colorado Consumer Protection Act (“CPA”) and other federal, state laws, the Israeli Protection of Privacy Law (“IPPL”), etc. (all collectively shall be defined as “Data Protection Laws”), individuals are permitted to make certain requests and exercise certain rights regarding their Personal Data or Personal Information (as such term is defined under Data Protection Regulations) and depending on their jurisdiction

In order to submit a request to exercise individual rights pursuant to the Data Protection Laws, please complete this form and send it to our privacy team at: privacy@primis.tech.

Upon receipt of your completed request, we will process it and respond within the timelines required under applicable Data Protection Laws. If additional information is necessary, we will contact you using the contact information you provided in this form. Information provided in connection with this request will be processed only for the purpose of processing and responding to your request and will be deleted immediately thereafter. For more information, please review our Privacy Notice.

1. CONTACT INFORMATION: 

Full Name:

Email Address: 

If applicable, US State:

2. WHAT IS YOUR RELATIONSHIP WITH US? 

• User 
• Customer
• Employee 
• Vendor 
• Other:

3. YOUR REQUEST: 

Detailed below are various rights and requests you may submit depending on your residence. Please check the applicable right you are requesting to execute. Please note by exercising your right to deletion, you will lose all account information.

1. CALIFORNIA: 

Note: Under the CCPA your rights only apply to the Personal Information collected 12 months prior to the request and you are not entitled to submit more than 2 requests in a 12 months period.

Please check the applicable right you are requesting to execute:

• Right to Know or Access;
• Right to Deletion;
• Right to Data Portability;
• Right to Non-Discrimination;
• Right to Rectification;
• Right to Limit the Use and Disclosure of Sensitive Personal Information; 
• Opt-Out of the Use of Automated Decision Making; or
• Other.

CCPA Opt-Out Rights: 

The Right to Opt-out of Sale; Opt-Out of Sharing for Cross-Contextual Behavioral Advertising; can be executed without filling the form by:  

• Use the “Do Not Sell or Share My Information” through the first-party business, i.e., through the cookie consent manager presented on the browser or app you are using.
• To opt out of the sale or share of Personal Information, you may also directly opt out from third party retargeting cookies or other ad-technology trackers through self-regulatory services. For more information, please visit:

Digital Advertising Alliance (US) HERE

Digital Advertising Alliance (Canada) HERE

Digital Advertising Alliance (EU)HERE 

Network Advertising Initiative HERE

• You can also opt out of interest-based advertising with some of the service providers we use, such as Google HERE, Google Analytic HERE. 
• In addition, you may opt out from our Search Partners at the following links: 

Microsoft (Bing): Microsoft’s opt out information which will enable you to limit data collection by Microsoft is available HERE. 

Oath (Yahoo): Oath’s opt out information which will enable you to limit data collection by Oath is available HERE. 

Please know that opting out of interest-based advertising does not mean that you will not receive advertising.  You may still receive ads, but those ads may be less relevant to your interests. 

Authorized Agency: you may submit the request by an authorized agency as detailed in the CCPA Notice.

2. VIRGINIA: 

• Right to Confirm if the Data is Being Processed and to Access That Personal Data;
• Right to Deletion; 
• Right to Data Portability;
• Right to Correct Inaccuracies; or
• Other.

The right to Opt-Out of “The Processing of the Personal Data for Purposes of Targeted Advertising, the Sale of Personal Data, or Profiling in Furtherance of Decisions that Produce Legal or Similarly Significant Effects Concerning the Consumer” can be done without filling this form, please see above the options under CCPA Opt-Out Section.

3. COLORADO: 

• Right of Access;
• Right to Correction;
• Right to Deletion of Personal Data;
• Right to Data Portability – to obtain a portable copy of the data; or 
• Other. 

Right to Opt-out of the Processing of Personal Data for the Purposes of: Targeted advertising; Sale for personal data; or Profiling used for decisions that produce legal or similarly significant effects on a consumer, can be done without filling this form, please see above the options under CCPA Opt-Out Section.

If you are a Colorado, Virginia, or Connecticut consumer, and we refuse to take action on your request, you may appeal our refusal within a reasonable period after you have received notice of the refusal.  

4. EU, UK, EEA AND OTHER JURISDICTIONS: 

• Right to be Informed to the Processing of Personal Data; 
• Right to Access to Your Personal Data;
• Right to Rectification and Amendment;
• Right to Deletion / Erasure; 
• Right to Restrict Processing;
• Right to Data Portability;
• Right to Object to the Processing of Personal Data; 
• Rights Related to Automated Decision-Making and Profiling; or
• Other.

4. VALIDATION 

The verifiable request must provide enough information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm the Personal Information or Personal Data is relates to you. 

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Substantiate the request – please provide additional information about your request: 

Thank you for filling in the form, please send it to: privacy@primis.tech. We will process the request within the time frame under the applicable Data Protection Law, we reserve the right to extend the aforementioned period by the time specified in the Data Protection Laws if the request is complex or numerous or we require additional information.

The processing of the request is free of charge; however, we may want to reserve the right to charge a reasonable fee to cover certain administrative costs (such as providing additional copies of the data) or for handling manifestly unfounded or excessive requests.

Note that, you might not be eligible to exercise all or part of the rights detailed above – this depends on your jurisdiction and the applicable Data Protections Law, our relationship, and our rights to refuse or retain data under applicable Data Protection Law. Where we are not able to provide you with the information for which you have asked or otherwise fulfil your request, we will endeavor to explain the reasoning for this and inform you of your rights.