Last updated: February 22, 2023
This Privacy Notice explains what information Prime Direct(“Prime Direct,” “we” or “us”) collects about you, what we do with it, and how you can control it in connection with our websites (including prime-direct.com) (collectively, our “Sites”). The term “personal data” can have different meanings depending on applicable law. In general, we use the term “personal data” to mean information that identifies an individual or that relates to an identified or identifiable individual, , but we will treat information we collect from you as personal data wherever necessary under applicable law.
You can navigate to any of the sections of this Privacy Notice using the links below:
- Why We Collect Your Information
- Information We Collect About You
- Interest-Based Advertising
- How We Share Your Information
- Third-Party Analytics
- How Long We Retain Your Information
- How You Can Control Your Information
- How We Protect Your Information
- Children’s Personal Data
- Changes to This Privacy Notice
- Additional Information for Residents of Certain Jurisdictions
- Contact Us
WHY WE COLLECT YOUR INFORMATION
We collect information about you for the following reasons:
- To manage and respond to your inquiries concerning our products and services.
- For our general administrative purposes. For example, we may need your information to tell you about important changes to the Sites, provide customer service to you, or respond to inquiries regarding our products and services.
- For research and development purposes, such as to develop and improve our products and services, assess and compare product performance, or analyze customer behaviors and market trends.
- For our internal efforts to operate and improve our business, such as improving the quality of our user experience, products and services, forecasting, and identifying ways we can operate more efficiently or expand our business.
- To evaluate your job application for anopen position.
- For advertising and marketing purposes. This could include sending you information about the products, services, promotions, surveys, and events we offer, enhancing and personalizing the content we provide to you, and enhancing and personalizing our communications with you about our products and services, including advertising and marketing communications. WE WILL NOT SHARE YOUR PERSONAL DATA WITH ANY NON-AFFILIATED THIRD-PARTY VENDOR OR WEBSITE OWNER FOR THEIR OWN MARKETING PURPOSES WITHOUT YOUR CONSENT.
- For security purposes, as necessary to help us protect against, identify, or investigate fraud or other criminal activity.
- For other legal purposes, if we have a legal obligation, or need to pursue or defend against legal claims, that involve the use of your information.
- For communication purposes, to get in touch with you in connection with any of the reasons discussed above.
- For other purposes to which you expressly consent.
INFORMATION WE COLLECT ABOUT YOU
We collect the following information about you:
- Information you provide. We may collect your first and last name, company name, email address, mailing address, zip code, phone number, or other information about you that you voluntarily send to us through the Sites or through communications with us.We may collect additional personal data when you fill out a job application on our Sites, such as a resume or CV, desired compensation, educational background, employment history, or social media profile, username, address, or similar identifier. If you are applying for a job through our Sites, please carefully consider the information that is contained within your resume and ensure that you are not providing any sensitive or other information that is not necessary for your job application or job search.
- Information provided by others. Those applying for jobs through our Sites may provide information about you as one of their references. Information provided by others in this manner may include your first and last name, company, and contact information.
- Information inferred. We may infer information from data described above (e.g., using job titles from a profile to infer industry, seniority, and compensation bracket; using graduation dates to infer age or using first names or pronoun usage to infer gender identity, etc.).
- Information gathered automatically. When you use the Sites, we may automatically collect information, such as your IP address, directly or through our third-party analytics providers.We (and third parties acting on our behalf) may collect this information directly from your browser interacting with our Sites. We may also collect this information through cookies and similar technologies, which typically work by placing a small file (like a text file or graphic) on your computer or smartphone, and the file is used to identify your device and to collect information. In this Privacy Notice, we use the term “cookies” in general to refer to these technologies. Cookies are typically assigned to one of four categories, depending on their function and intended purpose:
- Essential Cookies: These cookies are necessary for our Sites to operate properly and enable you to use its features.
- Performance Cookies: These cookies collect information about how you use our Sites and are used to improve and personalize future web experiences and deliver content more relevant to your interests. Our promotional communications may include these cookies to measure performance and deliver more relevant offers/content based on preferences.
- Functional Cookies: These cookies allow our Sites to remember choices you make and provide more personal features as well as services you have asked for. The information collected may be anonymized and is not used to track your browsing activities on other websites.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. We do, however, strive to provide you with choices regarding the personal information you provide to us and have created mechanisms to provide you with the following control over your information:
- Disclosure of Your Information for Third-Party Advertising: If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email with your request to [email protected].
- “Do Not Track” Signals. Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. Instead, we collect, use, and share information as described in this Privacy Notice regardless of a “do not track” choice.
- Location-based information. When you access the Sites, we may collect information related to your location through your device’s GPS, Wi-Fi, or Bluetooth. Your device may provide ways to prevent sharing your location, like disabling location-based services or turning off your GPS, Wi-Fi, or Bluetooth. You can disable location-based services on your device, however, you may not be able to use certain features of the Sites.
HOW WE SHARE YOUR PERSONAL DATA
We may disclose your personal information to a third party for a business purpose.We may share information about you:
- With others working for us, which includes third parties that perform services on our behalf such as running our Sites, sending communications for us, and executing marketing programs and promotions.
- With other third parties, such as law enforcement or other government entities: (1) if we believe there has been a violation of our policies; (2) if we believe that someone may be causing injury to our rights or property, to other users, or to anyone else; (3) to provide information to law enforcement; or (4) as required by law.
- As part of a corporate restructuring, such as a liquidation, reorganization, merger, sale of the company, consolidation, change of control, asset or stock acquisition/disposition, or other corporate combination. If that happens, we will use reasonable efforts to make sure the transferee uses your information in a manner consistent with this Privacy Notice.
We will not share information about you with any non-affiliated third-party vendor or website owner for their own marketing purposes without your consent.
We do not sell personal information.
We use third-party providers, including Google Analytics, to collect and analyze information about your use of the Sites. These providers may collect information about your online activities over time and across third-party websites and other online services using cookies and other tracking technologies discussed above in connection with your use of the Sites. You may be able to manage how these providers collect information by changing your browser’s cookie settings. Google’s Privacy & Terms (https://policies.google.com/privacy?hl=en-US) explains how Google Analytics collects and processes information.
HOW LONG WE RETAIN YOUR INFORMATION
In general, we keep information about you for as long as we need it to carry out the purposes described above, and as necessary to comply with our records-management policies. We also keep your personal data as we reasonably determine to be necessary to exercise or preserve our legal rights, or comply with other legal obligations we might have, such as in connection with litigation.
HOW YOU CAN CONTROL YOUR INFORMATION
Where you have provided your consent for us to use information about you, you may request to withdraw that consent for future uses of such information by contacting us at [email protected].
You may opt out of receiving future commercial email from us by following any opt-out instructions in emails we send you, or by contacting us at the address provided below. Please be aware that if you opt out of receiving commercial messages from us, it may take up to ten (10) business days for us to process your opt-out request, and you may receive commercial messages from us during that period.
Even if you opt out of receiving promotional and marketing material, we may still correspond with you about your existing or past business relationships with us. We may also access and view your information in the course of maintaining and improving the Sitesand our services.
HOW WE PROTECT YOUR INFORMATION
We have implemented technical, administrative, and physical security measures designed to protect your personal data from unauthorized access, disclosure, use, and modification. Although we strive to keep your personal data secure, no security measures are absolute. Use caution when transmitting personal data over the Internet.
CHILDREN’S PERSONAL DATA
In light of the importance of protecting children’s privacy, we do not collect, process or use on our Sites any information relating to an individual whom we know to be under 16years old without the prior, verifiable consent of his or her legal representative. Such legal representative has the right, upon request, to view the information provided by the child and/or to require that it be deleted by contacting us at the address provided below.
CHANGES TO THIS PRIVACY NOTICE
From time to time, we may update this Privacy Notice. When we do, we will post it on the Sites and include the effective date of the update. If there are material changes to our Privacy Notice, we will post a prominent notice on our Sites and provide other notice as required by law.
ADDITIONAL INFORMATION FOR RESIDENTS OF CERTAIN JURISDICTIONS
State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.
This section applies solely to all visitors to and users of the website who reside in the State of California. In addition, this section applies to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.
Categories of Information Collected Within the Last 12 Months
We have collected the following categories of personal information from California residents within the last 12 months:
|Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
|Protected classification characteristics under California or federal law.||
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
|Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|Geolocation data.||Physical location or movements.||NO|
|Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Use and Disclosure of Sensitive Personal Information
We do not use or disclose your sensitive personal information other than to:
- To perform the services or provide the goods reasonably expected by you whenyou request those goods or services.
- To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information, provided that the use of your personal information is reasonably necessary and proportionate for this purpose.
- To perform services on behalf of the business, provided that the use of your personal information is reasonably necessary and proportionate for this purpose.
Right to Access Personal Information
You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting personal information about you.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (a) sales, identifying the personal information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Right to Delete Personal Information
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Right to Correct Inaccurate Personal Information
You have the right to request that we correct any inaccurate personal information we maintain about you.
Right to Opt Out of Sharing Personal Information
You have the right to request that we stop all sharing of your personal information with third parties for purposes of cross-context behavioral advertising.
We will not discriminate against you for exercising any of yourrights under the California Consumer Privacy Act of 2018 (“CCPA”). Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permitsCalifornia 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 an email to [email protected]
Utah (effective December 31, 2023)
This section applies solely to all visitors to and users of the website who reside in the State of Utah and are acting in an individual or household context.
Utah provides their state residents with rights to:
- Confirm whether we process their personal information.
- Access and delete certain personal information.
- Data portability.
- Opt-out of personal data processing for targeted advertising and sales.
Exercising State-Specific Rights
To exercise any of the rights described above, please submit a verifiable consumer request to us by emailing us at [email protected] or writing to us at Prime Direct, 920 Third Street, Hammond, WI 54015.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do 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.
You may contact us at [email protected] for any additional information related to this Privacy Notice.