Privacy policy

PRIMEX PRIVACY POLICY

Primex Wireless, Inc. (“Primex”, “Company”, “we” or “us”) is committed to the privacy of our clients, website visitors, and users of our applications, products, and services. This privacy policy (“Privacy Policy”) discloses what information is gathered about visitors to our website (“Website”) and users of our applications, products and services (collectively the “Service(s)”), however accessed, and how that information is used.

We have designed this privacy policy to identify how we collect, use, store and share your personal information.

SCOPE OF PRIVACY POLICY

We obtain and process Personal Information in different capacities. When we collect or process Personal Information for our own purposes, meaning that we determine how and what Personal Information is processed, we are the data controller. This Privacy Policy applies to our collection, use, disclosure, and protection of Personal Information where we are the data controller. It does not apply to Personal Information we process on behalf of our customers who are using our Services (“Clients”) based on their instructions. Any Personal Information we collect or process on behalf of our clients is covered by our Clients’ privacy policies and notices.

WHAT IS PERSONAL INFORMATION?

For purposes of this Privacy Policy, “Personal Information” means information that alone or in combination identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

CATEGORIES OF PERSONAL INFORMATION WE COLLECT

We collect certain categories of Personal Information. The categories and a description of the types of data collected in each category are as follows:

Category	Examples of personal information collected
Identifiers	A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Customer Records	Name, address, telephone number and employment.
Commercial Information	Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories and tendencies.
Employment Information	Employment history, resume, references, contact information, emergency contact information, professional certifications, associations, disciplines, pay requirements, licenses and certifications held, skills, and experience.
Internet Activity	Browsing history and information on a consumer’s interaction with our website.
Geolocation Data	Imprecise location information, like the city, state and ZIP code associated with your IP address.

SOURCES OF PERSONAL INFORMATION AND THE PURPOSES FOR WHICH WE COLLECT AND USE IT

Primex obtains the categories of Personal Information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase
Indirectly from you. For example, from observing your actions on our Website or from information your computer or mobile device transmits when interacting with our Website or mobile applications, among other things.
From third-party data sources. For example, from consumer reporting agencies when we conduct credit checks or employee background checks.

We collect this Personal Information from you for the purposes described below.

Purpose for Collection and Use	Examples	Category of Data
Business Purpose	To facilitate transactions To improve products and services To provide customer service To create accounts To inform our business strategies To engage in product research and development To monitor and improve our products and services To administer surveys	Identifiers Customer Records Internet Activity
Communication Purposes	To respond to your requests or inquiries To send you newsletters and updates To provide information about our products and services	Identifiers Customer Records
Website Management Purposes	To troubleshoot problems with the Website To help improve the Website	Identifiers Internet Activity
Marketing and Advertising Purposes	To serve you targeted advertising To send you e-mail promotions	Identifiers Internet Activity
For Compliance and Legal Purposes	To protect our legal rights and the rights of third parties	Identifiers Customer Records
Analytics	To perform analytics on your use of the Website To understand the demographics and user preferences of Website visitors	Identifiers Internet Activity Geolocation Data

INFORMATION WE COLLECT FROM THIRD PARTY SOURCES

We collect Personal Information from various third-party companies and public sources as described below.

Purpose for Collection and Use	Examples	Category of Data	Third Party Source
Marketing and Advertising Purposes	We may receive information from our third-party advertising service providers.	Identifiers	Service Providers Third Party Marketing and Analytics Companies
Website Management	We may also receive Personal Information from our third-party analytics providers.	Identifiers Internet Activity	Website related Analytics providers, including analytics providers Third Party Marketing and Analytics Companies

HOW LONG DO WE KEEP YOUR INFORMATION

We retain Personal Information only as long as we have a legitimate business purpose to do so. These purposes may include retaining Personal Information in order to:

complete the transaction for which the Personal Information was collected;
continue our ongoing business relationship with you; and
satisfy any legal, regulatory, tax, accounting, or reporting requirements

To determine the appropriate retention period for individual categories of Personal Information we collect, we consider the nature and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure of the Personal Information; the purposes for which we process that Personal Information and whether we can fulfill those purposes through other means; and applicable legal, regulatory, tax, accounting, reporting and other requirements.

Privacy Impact Assessments (PIA)

At Primex, we are committed to regularly evaluating the privacy risks associated with the collection, use, and storage of personal information. We conduct Privacy Impact Assessments (PIA) on an ongoing basis to ensure that potential privacy risks are identified, mitigated, and properly managed. These assessments are used to analyze new systems, applications, or data collection processes that may impact the privacy of individuals.

WHO WE SHARE YOUR INFORMATION WITH

Primex limits the release of information, and we require privacy protections in our business relationships. We may share your Personal Information when required by law, or with third parties that perform functions on our behalf or for whom we perform services. We may also share information to protect the interests of individuals or in connection with a sale of our business or a merger or acquisition.

With Whom We Disclose Personal Information	Purpose for Disclosing	Category of Information
Employees	Business Purposes: processing orders; communicating with you; providing customer service; and improving our products and services. Website Management: troubleshooting problems; improving the content and functionality of the Website; customizing the ways our Website is presented to you and other users.	Identifiers
Service Providers	Business Purposes: processing orders; providing customer service; and performing analytics. Website Management: hosting our Website; troubleshooting problems with our Website; improving the content and functionality of the Website; and performing statistical and other analyses of the Website.	Identifiers Internet Activity Customer Records
Third-Party Advertising Networks and Social Media Platforms	Marketing & Advertising Purposes: sending targeted advertisements and other marketing communications. Business Purposes: performing statistical and other data analytics for us.	Identifiers Internet Activity
Government and Law Enforcement	Legal Purposes: cooperating with law enforcement and other governmental agencies and disclosing Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information; (ii) if we are advised to disclose Personal Information by our legal counsel; or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Primex or any other person or entity. We may also disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.	Identifiers Internet Activity Customer Records
Professional Advisors	Business Purposes: as necessary to receive advice from our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to us.	Identifiers Customer Records
New Owners or Successors in Interest	Business Purposes: in the event of a change in ownership or control of our business, we may disclose your Personal Information in connection with a contemplated or completed strategic business transaction such as a merger, acquisition, sale of all or substantially all of our assets or stock to a subsequent owner or operator, a dissolution, bankruptcy, liquidation or other similar business transaction where Personal Information may be shared, sold or transferred to that third party, including during the due diligence process.	Identifiers Internet Activity Customer Records
Business Affiliates including Combex, Inc. d/b/a Chaney Instrument Company and Primex, Inc.	Business Purposes: to facilitate business continuity and transactions amongst the corporate structure.	Identifiers Internet Activity Customer Records

SITE ANALYTICS, COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use Cookies, beacons, tags, pixels, session replay and other tracking technologies on our Website to operate the Websites, to gather analytical data about use of the Websites and to service targeted advertising.

The below companies may collect Personal Information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection and use of your Personal Information and your rights, please use the below links.

Google Analytics

We use a tool called "Google Analytics" to collect information about use of the Webset across devices. We have implemented the Remarketing and AdWords features of Google Analytics. The Remarketing feature allows us to serve you relevant advertising on third party websites if you have visited our Website, however accessed, but does not personally or directly identify you. AdWords allow us to manage our advertising and collect information about your visit to our Website. Visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ad Settings. You can opt out of Google Analytics without affecting how you visit the Website. For mor information on opting out of being tracked by Google Analytics, visit this Google page.
Facebook (Meta) Custom Audiences

We use remarketing services of Facebook (Meta, Inc.) on our Site. We use Facebook Custom Audiences to deliver targeted advertising to visitors to our Site across those Meta-owned Social Media platforms based on email address and other identifiers that we have collected. You may learn more about Facebook Custom Audiences by visiting here. To learn more about Meta's privacy policy, including their services and your rights, please click here.
Microsoft Clarity

We use session replay technology from Mircrosoft Clarity that allows us to collect information about how your navigate and use our Site in real-time. Session replay technology collects information including the date and time you visited the Site, mouse clicks, mouse movements, keystrokes, and text input, scrolling, webpage or content loading times and site errors. Other Personal Information collected by Clarity and other session replay providers includes IP address, browser information, device IDS, operating system, Cookies, and customer IDs. Additionally, session replay providers collect or receive Personal Information from us to provide their own advdertising services to others. For information about how Microsoft collects and uses your data using Microsoft Clarity, visit the Microsoft Privacy Statement.

Statements regarding our practices do not apply to the methods for collecting information used by these third parties or the use of the information that such third parties collect. We do however work with third parties to make efforts to have you provided with information on their practices and any available opportunity to exercise choice. We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties.

YOUR CONSUMER PRIVACY CHOICES

Updating your Personal Information. If your personal information changes, or if you no longer desire our service, you may correct, update, amend, delete/remover or deactivate it by making the change on our member information page or by emailing us at service@primexinc.com. We will respond to your request within a reasonable timeframe.
Opt Out of Digital Ads. You can opt out of a third-party vendor's use of cookies by visiting the Network Advertising Iitiative opt out page at https://www.networkadvertising.org/managing/opt_out.asp.
- Change your settings with individual browsers or ad networks; and
- Visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to your other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. In addition to the methods described above, if you wish to limit receipt of targeted advertisements you may click on the displayed icon on that advertisement to receive more information and you may choose to opt-out.
If you opt-out, you may still receive online advertising from us, which is based on your preferences or online behavior. We use multiple online advertising programs, so opting out of one program does not opt you out from all online advertising. I fyou opt out of your marketing and advertising, this does not affect third-party advertising practices, so you may still see our advertisements.

You may also opt-out of receiving Behavioral Ads on participating sites and services by visiting the Digital Advertising Alliance ("DAA") website at http://www.aboutads.info/choices/.
Limits on Targeted Advertising. Most browsers automatically accept Cookies. You can disable this function by changing your browser settings but disabling Cookies my impact your use of the Site. You cannot disable all Cookies, such as Cookies that are essential to to the functioning of the Site. You can manually delete persistent Cookies, or Cookies that track your activity across websites, through your browser settings. If you wish to limit receipt of targeted advertisements, you may click on the displayed icon on that advertisement to receive more information and you may choose to opt-out.
Opt-Out of Email Marketing. If for any reason you would no longer like to receive email marketing messages from the Company, you may Unsubscribe by following the instructions contained within our promotional emails. Please allow up to ten (10) days for us to process your request. Please note, if you opt not to receive marketing emails from the Company, you may still receive "transactional" email messages regarding your account, use of the Websites or your order (e.g., order confirmation, shipping information, recall notices, customer service notifications, etc.). To opt-out of receiving our direct mail, you may send us an email at service@primexinc.com.

LEAVING OUR WEBSITE AND/OR LINKING TO THRID PARTIES

When you leave our Website and go to another linked site, we are not responsible for the content or availability of the linked site. Please be advised that we do not represent either the third party or you, if you enter into a transaction on the third-party site. Further, the privacy and security policies of the linked site may differ from ours.

INFORMATION SECURITY

We take the security of your Personal Information seriously. We use reasonable technical, administrative, and physical safeguards to maintain the security and privacy of Personal Information we collect and use. When disclosing Personal Information, you should remain mindful that there is always risk in sending Personal Information using the internet.

Incident Response and Data Breach Notification

We take the security and privacy of personal information seriously. In the event of a data breach or any incident that may compromise personal information, Primex has established a comprehensive Incident Response Plan. This plan ensures that:

Affected individuals will be notified without undue delay, but no later than 30 days after becoming aware of the breach.
Law enforcement and regulatory authorities will be informed as required by applicable laws.
The breach will be investigated thoroughly to determine the scope and impact.
Corrective actions will be taken to mitigate the damage and prevent future incidents.

Additionally, in the event of a breach involving a third-party service-provider, Primex will ensure they follow similar protocols and provide timely notification of the breach.

DE-IDENTIFIED/ AGGREGATED DATA

We may aggregate or de-identify Personal Information we collect through our Website and when operating our business. For example, we may aggregate Personal Information to calculate the percentage of users in a particular zip code. Once information or data has been de-identified and/or aggregated, such information is no longer Personal Information.

INTERNATIONAL USERS

Our Website is operated in the United States and intended for users located in the United States. Like almost every website, our Website can be accessed by an international audience. If you are located outside of the United States, please be aware that information we collect, including personal information, will be transferred to, processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. In addition, such data may be stored on servers located outside your resident jurisdiction and in jurisdictions which may have less stringent privacy practices than your own.

CROSS BORDER DATA TRANSFERS

Primex may transfer personal information to recipients located in countries other than the country in which the information was originally collected. In such cases, we will ensure that the data transfer complies with applicable data protection laws and FedRAMP requirements, including implementing appropriate safeguards such as:

Standard Contractual Clauses (SCCs) or equivalent mechanisms aroved by regulatory authorities.
Adhering to applicable international frameworks that govern the transfer of personal data between jurisdictions.
Implementing additional security controls, including encryption, to protect personal data during the transfer process.

CALIFORNIA'S SHINE THE LIGHT ACT

California Civil Code Section 1798.83 permits customers of a Company who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for the third parties’ direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding twelve (12) calendar months. If you are a California resident and would like to make such a request, please submit your request in writing to:

Primex Wireless, Inc.
965 S. Wells St.
Lake Geneva, WI 53147
+1 (262) 729-4860
service@primexinc.com

CHILDREN'S PRIVACY

We do not direct or target any of our Site, products, or services to children under the age of 13. If we learn that we have collected the Personal Information of anyone under the age of 13, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 13 and discover that your child has submitted Personal Information to us, please contact us at service@primexinc.com. We will make reasonable efforts to remove such information from our databases.

NOTIFICATION OF CHANGES

We may revise this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post the revised policy here. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the top of this Policy or the top of the Website.

CONTACT INFORMATION

If you have any questions about the Privacy Policy or how we process Personal Information, please contact us at: