Privacy Policy

1. Who we are

PRIMO ELEMENT LTD ("we", "us", or "our") is the data controller responsible for your personal data. We are a limited company registered in England and Wales. We respect your privacy and are committed to protecting your personal data when you visit our website or use our services.

2. What data we collect

We collect personal data that you provide to us directly, as well as data collected automatically when you use our website.

Data you provide to us

• Names, usernames, or similar identifiers.
• Email addresses, telephone numbers, and billing addresses.
• Details about payments to and from you and details of services you have purchased from us.
• Information contained in project briefs, files, or messages you send us regarding your requirements.

Data collected automatically

• Internet Protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform.
• Information about how you use our website, products, and services.

Cookies

Our website may use cookies and similar technologies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.

3. How we use your data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To respond to your enquiries submitted via our contact forms or email.
• To provide quotes, invoices, and process payments for services rendered.
• To deliver the digital services and web development projects you have requested.
• To manage our relationship with you, including notifying you about changes to our terms or privacy policy.

4. Legal bases for processing

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

• We need to process your data to perform the contract we are about to enter into or have entered into with you.
• Processing is necessary for our legitimate business interests (e.g., keeping our records updated, studying how customers use our products/services) and your interests and fundamental rights do not override those interests.
• We need to comply with a legal or regulatory obligation (e.g., tax reporting).
• Where we have explicitly asked for your consent to process your data (e.g., for marketing communications). You may withdraw consent at any time.

5. Who we share data with

We do not sell your personal data to third parties. We may share your personal data with:

• Companies that provide IT and system administration services (e.g., hosting providers, email service providers, analytics tools).
• Lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
• Trusted freelance developers or designers who assist in delivering your project. They are only provided with the information necessary to perform their specific tasks.
• Regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

6. International transfers

Some of our external third parties (such as cloud hosting or email providers) may be based outside the UK or the European Economic Area (EEA). Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring compliant safeguards are in place, such as the International Data Transfer Agreement (IDTA) or ensuring the country has been deemed to provide an adequate level of protection for personal data.

7. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

8. Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know.

9. Your rights

Under data protection law, you have rights including:

• You have the right to ask us for copies of your personal information.
• You have the right to ask us to rectify personal information you think is inaccurate or complete information you think is incomplete.
• You have the right to ask us to erase your personal information in certain circumstances.
• You have the right to ask us to restrict the processing of your personal information in certain circumstances.

To exercise any of these rights, please contact us at hello@primoelement.com.

10. Complaints

If you have any concerns about our use of your personal data, you can make a complaint to us at hello@primoelement.com.

You can also complain to the ICO if you are unhappy with how we have used your data.

11. Children

Our website and services are not intended for children, and we do not knowingly collect data relating to children.

12. Changes to this policy

We keep our privacy policy under regular review. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.