Privacy Notice

1. About this Privacy Notice

This privacy notice explains how Priimo Marketing Oy ("Priimo", "we", "us" or "our") collects, uses, shares and protects personal data when we contact you, when you visit our websites, when you become our customer, or when we provide services to your business.

This notice is written in line with the UK General Data Protection Regulation (UK GDPR), the European Union General Data Protection Regulation (Regulation (EU) 2016/679), the UK Data Protection Act 2018, the UK Privacy and Electronic Communications Regulations 2003, the California Consumer Privacy Act (CCPA), and the Australian Privacy Principles, depending on where you live.

If you have any questions, please contact us using the details in section 18.

2. Who we are

Priimo Marketing Oy is the controller of your personal data.

We do not have a Data Protection Officer (DPO) under UK GDPR Article 37, as our processing activities do not require one. Our Data Protection Lead is the point of contact for all privacy enquiries.

3. Quick reference summary

Here is a one-glance summary of what we do with your data. Each topic is explained in more detail below.

Topic	Summary
Who we contact	Decision-makers at registered limited companies in target markets (UK, EU, Australia, USA).
How we got your data	Primarily from publicly available business registers (e.g., UK Companies House) and B2B contact databases that comply with UK GDPR.
Why we use it	To send relevant B2B marketing communications about our website and digital marketing services.
Legal basis	Legitimate interest (Article 6(1)(f) UK GDPR) for B2B prospecting; consent or contract for our customers.
How long we keep it	36 months from collection (prospects) or duration of contract + 7 years (customers).
Your rights	Access, correction, deletion, objection, restriction, portability. Right to complain to your local data protection authority.
How to opt out	Click the unsubscribe link in any email, or email privacy@priimo.fi. We action requests within 48 hours.

4. What personal data we process

4.1 If you are a prospect we have not yet contacted

• Business email address
• Name and job title
• Company name, size, and industry
• Registered company address
• Company website URL
• Publicly available financial summary information
• LinkedIn profile URL (public profile only)
• Business phone number (where publicly listed)

4.2 If you have replied to us or visited our preview website

• Email open and click activity
• Website analytics data (pages visited, time on page)
• The content of your reply or enquiry

4.3 If you become our customer

• Billing name, address, and payment information
• Contract and project-related communications
• Website build and hosting configuration information

4.4 If you visit our websites

• IP address and approximate location
• Browser type and operating system
• Cookie and tracking data (see section 10)
• Form submissions and enquiries

We do not knowingly collect special category data (such as health, race, religion, or political opinion).

5. Where we get your data

5.1 Public business registers

We collect information from publicly available business registers, including Companies House (UK), the Finnish Patent and Registration Office (PRH), US Secretaries of State registers, and the Australian Securities and Investments Commission (ASIC).

5.2 Contact data enrichment providers

We use professional B2B data enrichment services, including Cognism and email verification providers such as NeverBounce and ZeroBounce, to ensure our contact data is accurate and up to date.

5.3 Search and web scanning

We may collect publicly available business information from company websites, professional directories, and publicly accessible web pages.

5.4 Directly from you

We collect personal data directly when you fill in a form on our website, reply to our communications, contact us by email or phone, or enter into a contract with us.

6. Why we process your data

6.1 B2B prospecting

We use business contact data to reach out to companies that may benefit from our services. Our legal basis for this is legitimate interest under UK GDPR Article 6(1)(f) and the equivalent provision of the EU GDPR. We have conducted a legitimate interest assessment and concluded that our interests are not overridden by your rights, given that we process only professional contact data and provide a clear opt-out in every communication.

6.2 Providing services

Where you are our customer, we process your data on the basis of contract (UK GDPR Article 6(1)(b)) and, where applicable, legitimate interest to manage and develop our service relationship.

6.3 Legal and compliance

We process certain data to comply with applicable legal obligations (UK GDPR Article 6(1)(c)), including tax, accounting, and anti-money-laundering requirements.

6.4 Improving services

We use analytics and usage data to improve our websites and services, on the basis of legitimate interest.

6.5 Transactional emails

We send service-related communications (such as invoices, project updates, and technical notices) on the basis of contract.

7. Who we share your data with

7.1 Service providers (sub-processors)

We share personal data with trusted third-party service providers who process data on our behalf, bound by data processing agreements that require them to maintain appropriate technical and organisational security measures. These include email delivery platforms, CRM software, analytics tools, website hosting providers, scheduling and booking tools, payment processors, and the AI model provider (Anthropic) that generates the answers of the AI assistant on our website - messages you type into the assistant are sent to that provider to produce a reply, so please do not enter personal or confidential information there.

7.2 Other recipients

• Professional advisors (legal, financial, audit) under obligations of confidentiality
• Regulators and law enforcement, where required by law
• Successors in the event of a business sale or restructuring

We do not sell your personal data to any third party.

8. International data transfers

Where we transfer personal data from the UK to the USA, we use the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses as the appropriate safeguard.

Where we transfer personal data from the EU to the USA, we use the EU Standard Contractual Clauses (Commission Decision 2021/914) as the appropriate safeguard.

Transfers of personal data within the European Economic Area do not require an additional transfer mechanism.

9. How long we keep your data

We keep your data only as long as necessary for the purposes set out above. After these periods, we securely delete or anonymise your data.

Category	Retention period
Prospect data (public register + enrichment)	36 months from collection; reviewed annually
Engagement data (email open/click, preview visits)	24 months from last activity
Suppression list (people who opted out)	Indefinitely - required to honour your opt-out
Customer contract data	Duration of contract + 7 years (accounting law)
Customer support communications	3 years from last interaction
Call recordings	12 months from recording date
Website analytics	14 months
Tax and accounting records	7 years (statutory)

10. Cookies

We use cookies and similar tracking technologies on our websites. The categories we use are:

• Strictly necessary: Essential for the website to function. These cannot be disabled.
• Analytics: Help us understand how visitors use our website. Set only with your consent.
• Marketing: Used to personalise advertising and measure campaign performance. Set only with your consent.

A cookie consent banner is displayed on your first visit. You can change or withdraw your cookie preferences at any time via the "Cookie settings" link in the footer of our website.

11. Your rights

Depending on where you are located, you may have the following rights in relation to your personal data:

• Right of access: Request a copy of the personal data we hold about you.
• Right to rectification: Ask us to correct inaccurate or incomplete data.
• Right to erasure: Ask us to delete your personal data in certain circumstances.
• Right to restrict processing: Ask us to pause processing of your data in certain circumstances.
• Right to data portability: Receive your data in a structured, machine-readable format.
• Right to object: Object to processing based on legitimate interest, including direct marketing.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time.
• Right to complain: Lodge a complaint with your supervisory authority (see section 13).

If you are a California resident under the CCPA, you also have the right to know about personal information collected and disclosed, the right to delete personal information, the right to opt out of the sale of personal information (we do not sell personal information), and the right to non-discrimination for exercising your rights.

If you are in Australia, you have the right to access and correct your personal information under the Australian Privacy Principles, and to make a complaint to the Office of the Australian Information Commissioner (OAIC).

12. How to exercise your rights

12.1 Unsubscribe from marketing

Every marketing email we send includes a one-click unsubscribe link. Clicking this link will immediately remove you from our outreach lists. We honour all unsubscribe requests without delay.

12.2 Email

Send your request by email to sales@priimo.ai. Please include your full name, email address, and a clear description of the right you wish to exercise. We will acknowledge your request within 5 business days and respond in full within 30 days (or within the period required by applicable law).

12.3 Post

13. Supervisory authorities

If you believe we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the relevant supervisory authority:

• United Kingdom: Information Commissioner's Office (ICO) - ico.org.uk/make-a-complaint
• Finland: Office of the Data Protection Ombudsman - tietosuoja.fi
• EU/EEA: European Data Protection Board - edpb.europa.eu
• Australia: Office of the Australian Information Commissioner - oaic.gov.au
• California: California Privacy Protection Agency - cppa.ca.gov

We would, however, welcome the opportunity to address your concerns before you approach a regulator, so please do contact us first using the details in section 18.

14. Automated decision-making and AI

We use automated processes and AI tools to scale our outreach and improve our services. These include automated email sequencing, AI-assisted content personalisation, and data enrichment workflows.

These automated processes do not produce legal effects on you or significantly affect you in the sense of UK GDPR Article 22 or the equivalent EU GDPR provision. No automated decision-making produces a decision that could, for example, deny you a service, affect your credit, or have a comparable significant impact.

15. Children's data

Our services are intended for businesses, not for individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately at sales@priimo.ai and we will delete it promptly.

16. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• TLS 1.2 or higher for all data in transit
• AES-256 encryption at rest (via Supabase)
• Role-based access controls and the principle of least privilege
• Multi-factor authentication for all team members with access to personal data
• Regular internal security reviews
• Backup and disaster recovery procedures

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, and affected individuals without undue delay where required by law.

17. Changes to this notice

We may update this privacy notice from time to time to reflect changes in our practices, services, or legal obligations. The "Last updated" date at the top of this page shows when it was last changed.

We will notify you of material changes by email (where we hold your email address) or by a prominent notice on our website, giving you reasonable time to review the changes before they take effect.

18. Contact us

For any privacy-related questions, requests, or concerns, please contact our Data Protection Lead:

We aim to acknowledge all enquiries within 5 business days.

1. General

These terms of use apply to the use of the Priimo.fi website and any associated Priimo web properties. By using our site, you accept these terms in full. If you do not accept these terms, you must not use our site.

The site is owned and maintained by Priimo Marketing Oy, Finnish Business ID: 3589635-3, registered at Kullervonkatu 30, 33500 Tampere, Finland.

2. Use of the site

Our site is intended for providing information about our services and receiving enquiries from prospective and existing clients. You agree to use the site only for lawful purposes and in a manner that does not infringe the rights of others.

You may not:

• Use the site in a manner that damages, disrupts, or impairs its availability or functionality
• Attempt to gain unauthorised access to any part of the site or its underlying systems
• Copy, modify, or distribute content from the site without our prior written permission
• Use automated tools, bots, or scrapers to collect data from the site
• Use the site for spamming, phishing, or any other unsolicited or deceptive communication

3. Intellectual Property Rights

All content on this site - including but not limited to texts, images, graphics, logos, videos, and code - is the property of Priimo Marketing Oy or is licensed to us by the relevant rights holders. All rights are reserved.

Priimo 3.0 AI is a registered trademark of Priimo Marketing Oy.

You may not use, copy, modify, reproduce, republish, transmit, or distribute any content from this site for commercial purposes without our prior written permission. Quotation for non-commercial purposes with clear attribution is permitted.

4. Limitation of Liability

Content on this site is provided "as is" and without warranties of any kind, either express or implied, including but not limited to warranties of accuracy, completeness, fitness for a particular purpose, or non-infringement.

Priimo Marketing Oy is not liable for:

• Any direct or indirect damages arising from your use of or inability to use the site
• Technical malfunctions, interruptions, or errors on the site
• Inaccuracies or errors in the content published on the site
• Damages caused by third-party services linked from or integrated into the site
• Security breaches where due care and appropriate technical measures were exercised

Nothing in these terms limits liability that cannot be excluded under applicable law.

5. External links

Our site may contain links to external websites that are not operated by us. We include these links for your convenience only. We are not responsible for the content, accuracy, privacy practices, or operation of any linked external site. The inclusion of a link does not imply our endorsement of that site.

6. Third-party services

We use third-party services to operate and improve our website, including Google Analytics and Meta Pixel. These services may set cookies and collect data about your use of our site. Please see our Privacy Notice above for full details of how these services are used and your choices.

7. Changes to the terms

We reserve the right to change these terms of use at any time. Changes take effect immediately upon posting to this page. The "Last updated" date at the top of the Terms of Use section indicates when the terms were last revised. Your continued use of the site after any changes constitutes your acceptance of the new terms.

8. Applicable law

These terms are governed by and construed in accordance with Finnish law, without regard to its conflict of law provisions.

Any disputes arising from these terms or your use of the site shall first be subject to good-faith negotiation between the parties. If a dispute cannot be resolved through negotiation, it shall be submitted to the competent Finnish courts.

9. Contact