Privacy Policy

The Services may collect “Personal Information” (which is information that may reasonably be used, or capable of, alone or in combination with other information to identify or contact a specific individual) from non-Child Users when non-Child Users register for an account or engage with the Services. Such Personal Information may include, but is not limited to:

• Contact data, including first and last name, email address, and phone number.
• Demographic information, such as zip code.
• Profile data, such as the randomly-generated username and password that non-Child Users may modify or set, respectively, to establish an online account on the Service, date of birth, biographical details, pictures, photos, and any other information that non-Child Users add to the account profile or submit during account creation.
• Communications that we exchange with non-Child Users, including when non-Child Users contact us through the Service, social media, or otherwise.
• Transactional data, such as information needed to obtain verifiable parental consent.
• Marketing data, such as non-Child Users’ preferences for receiving our marketing communications and details about non-Child Users’ engagement with such communications.
• User-generated content, such as profile pictures, photos, images, music, videos, comments, questions, messages, works of authorship, projects the non-Child User has worked on, and other content or information that non-Child Users generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that non-Child Users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
• Relationship data, such as information about family members whose Personal Information non-Child Users may provide to us. For example, when a non-Child User is a Parent of a Child User, the Parent may provide us with certain information about their Child User to complete any necessary parental consents.
• Parent contact information, such as a Parent’s email address. For example, when a non-Child User between the ages of 13 and 18 would like to upgrade their account, we collect contact information about and payment information from that non-Child User’s Parent for the Parent to consent to the Terms of Service and pay for the upgrade on that non-Child User’s behalf.
• Payment information needed to complete transactions, including payment card information. We use Stripe as our payment processor, and Stripe receives and processes your payment information directly. By providing your payment card information, you understand and agree that Stripe will use your payment card information in accordance with its privacy policy, available at stripe.com/privacy.
• Audio and video information, collected with non-Child User’s consent from recorded sessions on the Service.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

** Photo Verification Process for non-Child Users between the ages of 13 and 18: A child between the ages of 13 and 18 may sign up for an account by using a randomly generated username, which they are able to immediately modify (we instruct such users not to use their full name), by creating a password, and by completing the photo verification process, all without being required to go through the verifiable parental consent process. As part of the photo verification process, the non-Child User submits photos to us, which we manually review to generally verify a non-Child User’s provided age. However, as required by the Terms of Service, such users use the Services under the supervision of a Parent or Guardian who agrees to be bound by the Terms of Service.

When a Child User signs up for an account by providing the Child User’s date of birth, the Child User is also required to provide their Parent’s contact information (i.e., parent’s email address) for parental consent purposes. Primer will then reach out to the Child User’s Parent via email to begin the process of obtaining the necessary parental consent. After Primer obtains verifiable parental consent, the Child User will then go through the photo verification process, where the Child User submits photos to us and which we manually review to generally verify a Child User’s provided age. Primer requires verifiable parental consent before permitting Child Users to further engage with the Services and provide any Personal Information.

As part of the parental consent process, we will establish contact with the Parent by email and then send the Parent a link to provide parental consent, which explains what information we are collecting, how we plan to use it, how the Parent can provide consent (through use of a credit card to provide a nominal fee that is refunded, as described above), and how the Parent can revoke consent. Once the Parent provides consent (through use of a credit card), we send an email to the Parent confirming the Parent’s consent, as well as providing information for the Parent’s records about what information we are collecting, how we plan to use it, and how the Parent can revoke consent.

Once the Parent has provided their consent and the Child User gains full access to the Services, the Child User may join clubs with other users in which they may post content for other users to see and provide mutual feedback and comments, participate in live events using voice, screensharing and chat features and a shared visual space, and work on project teams with other users.

Before a Parent has provided consent, we may collect the following Personal Information from Child Users:

• Parent contact information, such as email address, during the sign-up process to facilitate the parental consent process.
• Limited non-identifiable profile data, specifically a username (that is randomly generated by Primer and is not the Child User’s name) and password.

After a Parent has provided consent, we may collect the following Personal Information from Child Users:

• Contact data, including first and last name and email address.
• Profile data, such as the username and password that Child Users may modify after parental consent has been provided, biographical details, pictures, photos, and any other information that Child Users add to the account profile or submit during account creation.
• Communications that we exchange with Child Users, including when Child Users contact us through the Service, social media, or otherwise.
• User-generated content, such as profile pictures, photos, images, music, videos, comments, questions, messages, works of authorship, projects the Child User has worked on, and other content or information that Child Users generate, transmit, or otherwise make available to other users on the Service, as well as associated metadata.
• Audio and video information, collected with Child User’s consent from recorded sessions on the Service.

We may also collect Personal Information about Child Users:

• From non-Child Users who are the Parents of a Child User, such as username, name, email, and date of birth of the Child User.
• From third party services. For more information, see “What information does Primer collect from third party services?” above.
• Automatically. For more information, see “What information does Primer collect automatically?” above.

As described in further detail in “How does Primer use the Personal Information it collects about non-Child Users?” above, after parental consent has been obtained, Primer may use the Personal Information it collects from Child Users:

• To provide the Services.
• To operate and improve the Services.
• To create anonymous, aggregated or deidentified data.
• For compliance, fraud prevention, and safety.
• To comply with law.
• For other purposes, with your Parent’s consent.
• In addition to the uses above, Primer may use the Personal Information it collects from Child Users to send newsletters to Child Users containing information about the Services and upcoming events on the Services.

As described in further detail in “Will Primer share any of the Personal Information it collects about non-Child Users?” above, Primer may share a Child User’s Personal Information with the following parties and as otherwise disclosed at the time a Child User provides us with information or as otherwise described in this Privacy Policy:

• Service Providers
• Administrative, Legal Reasons and Academic Integrity Investigations
• Affiliates; Business Transactions
• Testimonials. We will always obtain verifiable parental consent before posting any Child User’s testimonial.

No Child User’s Personal Information is made available or visible to other users of the Services unless parental consent has first been obtained.

Once parental consent has been obtained, the Child User gains full access to the Services and may post content for other users to see and provide mutual feedback and comments, participate in live events (including Room sessions), and work on project teams. Child Users participating in Room sessions may share or provide access to audio or video information, including the contents of their computer screen or the audio of their conversations, with other users. Other users may also be able to view information or content that Child Users choose to display with their profile, projects, comments, or posts. This may include but is not limited to a first name, profile photo, a bio written by the Child User, and information about the projects on which the Child User has worked.

Primer does not currently use any non-Child User or Child User data to target advertisements or marketing. In addition, we do not share any Personal Information of non-Child Users or Child Users with third parties for their own advertising or marketing purposes.

The Services may provide links to third party websites or content over which Primer has no control and which are governed by the privacy policies and business practices of those third parties.

Please also note that Primer content may be included on web pages and websites that are not associated with us and over which we have no control. These third parties may independently collect data. Primer is not responsible or liable for the privacy practices or business practices of any third party.

If you use the Services through a mobile device, Primer may store and use information about your mobile device (e.g., mobile device model number, etc.) to improve the Services.

Primer takes data security very seriously. Primer takes commercially reasonable security measures designed to protect your Personal Information, both during transmission and upon receipt, at rest. Such measures vary depending on the sensitivity of the Personal Information at issue.

Please note that no method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, while we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security.

Additionally, we make commercially reasonable efforts to verify that the parties with whom our mobile application shares personal information provide a level of protection of Personal Information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use your Personal Information as described in their own privacy policies.

You may be able to review the information you provided to us on a Service and make any desired changes to the information, or to the settings for your account on that Service, by logging in to your account for that Service and editing or deleting the information. Note that certain accounts may have limitations regarding the ability to delete information. Even after information is deleted, we may maintain it in backup or archive form.

If you are a California resident under the age of 18 and a registered user of the Service, you may have the right to request that we remove any content or Personal Information that you have publicly posted on the Service, subject to certain exceptions. If you wish to request the removal of such content or Personal Information, you may follow the steps described herein, or contact us at [email protected] and provide your username and email address you used to register for your account and specify which content or Personal Information you wish to be removed. Please be aware that after removal, you may not be able to restore removed content or Personal Information. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and there may be circumstances in which the law does not require us to enable removal of content or Personal Information.

If you have an account and you wish to close your account with one of our Services, please contact us via email at [email protected], and we will remove your Personal Information and profile, if applicable, from the active databases for the Service(s) you request. Please let us know which Service(s) you wish to close and, if applicable, send your request using an email account that you have registered with Primer under your name. You typically will receive a response to a request sent to this account within five business days of our receiving it.

We generally retain Personal Information as long as is reasonably necessary 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 may 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 may either delete it or create anonymous, aggregated or de-identified information.

Primer may update this Privacy Policy at any time and any changes will be effective upon posting. We will notify you of material changes to the Privacy Policy on our website and/or by email, and make additional efforts to notify customers of material changes that impact the treatment of data collected through our Services. Upon any update the date at the top of this policy will be updated. Your continued use of the Services following an update to this Privacy Policy will constitute your acceptance of the updated Privacy Policy.

The Services are not currently targeted to users outside the United States. If you are located outside of the United States, please be aware that the Services are operated in the United States and any information we collect will be transferred to and processed in the United States. By using the Services, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

If you have questions or comments about this Privacy Policy, please contact Primer via email at [email protected], by mail at 548 Market Street, PMB 38216, San Francisco, California, 94104, or by phone at (415) 358-7164.