Privacy Policy

Last Updated: April 22, 2022

This Policy describes how Prim6 LLC ("Prim6," "we", "us" or "our") handles, stores, collects, and discloses personal information about you in the course of our business, including through our websites, application-based services, and through other means such as our partner’s events, sales, and marketing activities. It also details additional information regarding your privacy rights that relate to this Privacy Policy, including our website (collectively, the "Service"), as well as through social media, our marketing activities, and other activities described in this Privacy Policy.  

We define Personal Information (or “PI”) to mean any information that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with a specific individual or household of individuals. Depending on which Prim6 Applications or Services you use and/or other business interactions you may have with our other Company members and/or whether those activities are linked to a person’s identity. Personal Information generally does not include publicly available information, that is, information that is lawfully made available from federal, state, or local government records.

How We Collect and Use Personal Information

We will collect, use, and may share Personal Information in numerous ways, depending on what Applications or features of our Site that you use and the extent to which you may use our Services or otherwise have a relationship with us or another member of our Company. 

We may use your personal information to:

• provide, operate and improve the Service and our business;
• establish and maintain your user profile on the Service;
• facilitate your invitations to friends who you want to invite to join the Service;
• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages; and
• provide support for the Service, and respond to your requests, questions and feedback.

Research and development: We may use your personal information for research and development purposes, including to analyze and improve the Service and our business.

Marketing: We may send you direct marketing communications. You may opt-out of our marketing communications.

Security of Your Personal Information

We take all reasonable and appropriate steps to protect your personal information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration and destruction. We use appropriate technical and organizational measures to protect your personal information which may include: physical access controls, encryption, internet firewalls, intrusion detection and network monitoring depending on the nature of the information and the scope of processing. Our staff who may have access to your information are required to keep that information confidential.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims); 
• audit our internal processes for compliance with legal and contractual requirements or our internal policies; 
• enforce the terms and conditions that govern the Service; and 
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law. The chart below summarizes the Personal Information we collect by reference to the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140), and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. The terms in the chart refer to the categories of information, sources, purposes and third parties described above in this Privacy Policy in more detail. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.  

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To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business. 

Cookies and similar technologies. We may use these for the purposes outlined in the "Cookie Notice." 

Retention: We retain Personal Information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for Personal Information, we consider factors such as the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the Personal Information we have collected about you, we will either delete it, anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), securely store it and isolate it from further processing until deletion is possible. If we anonymize your Personal Information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

• Information obtained in connection with our Services and related Businesses from or on behalf of property owners, borrowers, guarantors, purchasers and potential purchasers of lenders, servicers, investors, other transaction participants, and their affiliates about themselves, their employees, their other representatives, their equity owners, their CRE and other assets (including, but not limited to, information about their tenants, lease applicants and related parties, vendors and other service providers), and their other business activities (which may include information about other third parties).
• Information obtained in connection with our Services and related Businesses from our third-party vendors and data providers.
• Information obtained from other private and public sources in connection with our Services and related Businesses.
• Identifiers such as real name, alias, postal address, unique personal identifier (e.g., cookies, beacons, pixel tags), IP address, device identifier, and email address.
• Transaction histories and related information, as well as personal and other property, products or services purchased, obtained and/or considered in connection with our other

Corporate Group Businesses, as well as transaction histories, preferences and other activities.

• Internet browsing history, search history, interactions with a web site, application, advertisement or other online activities.
• Geolocation data, such as property addresses, latitude-longitude coordinates, mapping data.
• Biometric information.
• Audio, electronic, visual, thermal, olfactory or similar information.
• Professional or employment-related information, such as certifications, affiliations with companies or professional societies.
• Characteristics of protected classifications (e.g., race, religion, sex, national origin, etc.).
• Educational information.
• Inferences drawn to create a profile of an individual reflecting the person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Sharing of Personal Information

We do not share your personal information with third parties other than as follows:

• Where it has been de-identified, including through aggregation or anonymization;

• When you instruct us to do so;

• With your consent, for example, when you agree to our sharing your information with other third parties for their own marketing purposes subject to their separate privacy policies;

• With Prim6 affiliates, in such case the information will be processed as otherwise described in this Notice;

• With third party vendors, consultants and other service providers who work for us and need access to your information to do that work. Examples include vendors and service providers who provide assistance with marketing, billing, processing credit card payments, data analysis, fraud prevention, network and information security, technical support and customer service;

• With third party business partners, such as distributors, and/or referral partners, who are involved in providing services to our prospects and/or customers, to fulfill product and information requests and to provide customers and prospective customers with information about Prim6 and its products and services. From time to time, we may engage in joint sales or product promotions with select business partners. If you purchase or specifically express an interest in a jointly-offered product, promotion or service, we may share relevant personal information with those partner(s). 

Where you have given your consent to do so, these business partners may send you marketing communications about their own products and services. Please be aware that we do not control our business partners’ use of such information. Our partners are responsible for managing their own use of the personal information collected in these circumstances. We recommend you review the privacy notices of the relevant partner to find out more about their handling of your personal information.

• To comply with laws or to respond to lawful requests and legal process, to protect our rights and property and that of our agents, customers, members and others including to enforce our agreements, policies and terms of use or in an emergency to protect the personal safety of any person;

• In order to protect any individual’s vital interests, but only where we believe it necessary in order to protect the vital interests of any person; and

• In connection with or during negotiation of any business transfer, merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company.

California Users Only: Your Privacy Rights 

The California Consumer Privacy Act of 2018 (“CCPA”), effective as of January 1, 2020, requires businesses that collect personal information of California residents to make certain disclosures regarding how they collect, use and disclose such information. 

This section addresses those requirements. For a description of all of our data collection, use and disclosure practices, please read this Privacy Notice in its entirety. 

Personal Information Collection and Sharing

Prim6 does not sell personal information as we understand sale to be defined by the CCPA and its implementing regulations. The categories of personal information we collect about you and the third parties with whom we share that personal information for a business purpose are as follows: