Privacy Policy for Visitors, Platform Users, and End Users (September 2021)
Visarity Technologies GmbH
Wenzel-Hablik-Str. 30
25336 Elmshorn
T: +49(0)41212643539

Visarity Technologies GmbH (“Primo,” “we,” “us,” or “our”) respects your privacy, and we take our responsibility of caring for it seriously. This Privacy Policy helps you make informed decisions about your relationship with us, so we encourage you to read it carefully. The information we collect depends on what products or services you use and how you use them. This Privacy Policy applies to visitors of our website located at (the “Website”), who view only publicly-available content (the “Visitors”); users of Primo’s advertising and creative management platform and related documentation (“Platform Users”) provided through our web sites and applications (the “Primo Services”), and end users of digital advertisements created and/or trafficked through the Primo Services (the “End Users”). By using or accessing our Website or using the Primo Services (as defined below), you agree to our privacy practices outlined herein.

We designed this Privacy Policy with these key principles in mind:

1. To explain important disclosures about the way we use information that you share with us as Visitors, Platform Users, and End Users.

2. To ensure that you understand what information we collect with your permission, and what we do and, most importantly, do not do with that information.

3. To hold us accountable for protecting your rights and your privacy under this policy.

End Users / Ad Viewers what do we collect and what not:

This is what we collect:
1. Hostname
2. User-Agent of the Browser
3. All kind of interaction inside the Ad canvas: hover, clicks etc.
4. Overal interaction time
5. Location: country and city - derrived from IP address
6. Video Completion Rate

This is what we DO NOT collect:
1. IP address
2. Device Id
3. GPS Coordinates
4. Advertiser Id

Cookies? We are not storing any cookies nor does Primo deal with cookies at all.

Our Ad-Serving Domains:
1. - Ad content delivery
2. - Ad content delivery. Specifically for In-Banner-Video formats
3. - Used for event collection
4. - Used to fetch feed data

IAB Transparency and Consent Framework
Visarity is registered on the global-vendor-list. (click here for more information)

Highlights of what you’re consenting to (not applicable for End Users):
1. The use of cookies and other tracking technologies.
2. The transfer of your information outside of the country where you live.
3. Collection, use, processing and retention of your information by the entities described in this Privacy Policy, including Primo, as Data Controller (where applicable), as indicated at the bottom of this document.

For purposes of this policy:
“Personal Data” for non-residents of the European Economic Area means any information that can be used to identify, contact, or precisely locate a person, including name, email, address, and telephone number.
“Personal Data” for residents of the European Economic Area means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. This includes IP address.
“Non-Personal Data” means information not included in the definition of Personal Data, such as pages or ads visited, time spent on pages, browser and device type, and referring and exit pages. For non-residents of the European Economic Area, IP address and advertising IDs (IDFA/AAID) are Non-Personal Data.

1. Information We Collect/Receive and How We Use that Information
In general, there are three categories of information we collect: (1) information that we can use to provide additional features and improved experiences if you choose to share that information; (2) information that we must have for you to use the Primo Services; and (3) information collected from your interaction with the Primo Services as an End User of a digital advertisement (hereinafter referred to as “ad” or “ads”). When you provide Personal Data directly to us, this information is used by Primo solely for the purposes identified at the point you provide it. Information we collect may be transferred, stored, used, and/or processed as follows:
I. Contact Information. When you contact us through the “Contact Us” page on the Website or become a Platform User of the Primo Services, you will be asked to provide us with certain Personal Data about yourself which may include your name, email address, job title, name of your organization, mailing address, or telephone number. Consistent with any permissions you may have communicated to us, we may use this information to directly communicate with you for marketing and promotional purposes via emails, notifications, or other messages, and to communicate with you for research purposes including via emails, notifications, or other messages. Platform Users may also receive communications concerning Primo product updates, training sessions, or events or webinars. If you want to stop receiving such materials from Primo, you can change your profile settings within the Primo Services or follow the unsubscribe instructions at the bottom of each email.
II. Billing Information. In certain circumstances, to use the Primo Services, you may be required to provide additional information which may include a credit card number, expiration date, billing zip code, activation code, and similar information (“Billing Information”). Primo uses this information to process payments. In certain circumstances, Primo uses third-party service providers to manage credit card processing. These service providers are not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing.
III. User Activity Data (Website, Platform). In an ongoing effort to improve the Website and the Primo Services, we automatically collect certain information when Visitors visit the Website and when Platform Users use the Primo Services (collectively, the “User Activity Data”). This information may include IP address, browser and device type and language, referring and exit pages and URLs, date and time, amount of time spend on pages, what sections of the Website Visitors visit, and other, similar aggregate user data concerning your use of the Website and the Primo Services. We may use this data to manage and improve your experience using the Website and the Primo Services. In some areas of the world, certain User Activity Data may be Personal Data. Where this is the case, we comply with applicable laws regarding our use and processing of Personal Data.
IV. Ad Interaction Data (End Users). When End Users interact with ads generated using the Primo Services, we may collect information on behalf of Primo’s customers which may be the advertiser, publisher, advertising agency, and/or their agents. Data collected through interaction with the Primo Services may include time spent viewing an ad, page views, video views, number of ads clicked and other information about your interaction with the ads (“Ad Interaction Data”). We are no storing the IP address, device ID, GPS coordinates or any Advertising ID at all. With respect to End User data, Primo is acting as a “Data Processor” on behalf of our customers, which may include the advertiser, publisher, and/or their agents who are the Data Controller of your data who may use this information for their lawful advertising purposes to provide you with a more tailored online advertising experience. We may also use the information internally to improve the functionality of the Primo Services.
V. Cookies and similar technologies. A cookie is a small text file that is placed on your computer or device when you visit certain websites. When we refer to “cookies” we include other technologies with similar purposes. In resepect to "End Users" Primos customers may use cookies to serve appropriate ads to you and to help track results or measure effectiveness of those ads. These third-parties may combine information collected in the context of delivering an ad to you with other information they have independently collected over time across different websites, including syncing or connecting behavior across different websites, mobile apps or devices. These third-parties collect and use information under their own privacy policies. As far as "End Users" are concerned Primo is not reading nor writing any cookies at all.

2. Sharing and Disclosure of your Personal Data
We may share your information at your direction or as described below at the time of sharing.
I. Customers. We share Ad Interaction Data with our customers who may use this information for their lawful advertising purposes to provide you with a more personalized online advertising experience.
II. Third-Party Service Providers. Primo may share your information with Third-Party Service Providers that support us in delivering the Primo Services to our customers. We may also share your information with companies that help us operate and market the Primo Services, such as to bill our customers, analyze our Website Visitors, provide customer and technical support, database, analytics, and hosting services, and other operational support. We ensure that such service providers are contractually required to protect your Personal Data at all times.
III. Safety and Compliance with the Law. Primo may disclose your information to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required to do so by law.
IV. Business Transfers. If Primo undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer, or share some or all our assets, including your Personal Data. In this event, we will notify you before your Personal Data is transferred and becomes subject to a different privacy policy.
V. Other. Primo may also may disclose your information under circumstances not mentioned here with prior consent of the person or third-party that submitted the information to us.

3. Your Choices
I. Cookies. Usually, you can stop your browser from accepting cookies in general or from accepting cookies from a particular website. All modern browsers allow you to change your cookie settings. You can typically find these settings in the “options” or “preferences” section of your browser. Please visit our Cookie Policy for more information on how to manage your cookie preferences in connection with the Primo Website. In some areas of the world, cookies and other identifiers may be Personal Data. Where this is the case, we comply with applicable laws regarding our use and processing of Personal Data. Except in the case of residents of the European Economic Area, by accessing and using our Website, you consent to the use of the cookies and other technologies described above. Residents of the European Economic Area will be able to accept or reject cookies each time they access the site.
II. Marketing Communications. You may choose to sign-up for marketing or other communications from Primo on the Website. Should you choose to unsubscribe from any lists for which you registered, you may do so by following the instructions on how to unsubscribe provided in all Primo communications or by emailing

4. Your Rights & the EU General Data Protection Act
We are committed to GDPR compliance when enforcement begins on May 25, 2018. If you are a resident of the European Economic Area, you have the following rights with respect to data for which Primo is the Data Controller:
1. The right to request access to, or ask us to provide you with copies of, Personal Data that we hold about you at any time, which may be subject to a fee specified by law for processing your request (but not for making a request for access). If Primo is the Data Controller with respect to your data, we will respond to your request within a reasonable period, and if Primo is the Data Processor with respect to your data, we may redirect your request to Primo’s customer acting as the Data Controller with respect to your data. We may decline a request for access to Personal Data in circumstances prescribed by relevant privacy laws. If we decline a request, we will provide you with a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint;

2. The right to ask us to delete any Personal Data that we hold about you free of charge, unless we are required to maintain a copy of this data pursuant to applicable law;

3. The right to ask us to update and correct any out-of-date or incorrect or inaccurate Personal Data that we hold about you free of charge. We will take reasonable steps to correct the information so that it is accurate, complete and up to date. If we refuse to correct your Personal Data, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint;

4. The right to opt out of any marketing communications that we (or any third-party to whom we have disclosed your Personal Data with your consent) may send you or to withdraw your prior consent or object to any further processing of your Personal Data;

5. The right to request information about any automated decisions made using your Personal Data that have legal consequences for you or which significantly affect you; and

6. The right to lodge a complaint with your local Data Protection Authority concerning Primo’s processing of your Personal Data.

If you wish to exercise any of the above rights, send us an email at headed “Privacy Data Request.” Before we process any request, we may ask you for certain Personal Data to verify your identity, and in situations where Primo is the Data Processor, consult with the Data Controller of your data. Where permitted by local law, we may reject requests that are unreasonable or impractical. Please allow us a reasonable time to respond to your inquiries and requests.

5. Security of your Personal Data
Primo uses reasonable technical and organizational security measures to safeguard Personal Data that is submitted to us voluntarily through our Website or the Primo Services or collected through interactions with the Primo Services. However, no security measures are perfect or impenetrable. We cannot control the actions of third-parties with whom you elect to share your Personal Data and we cannot accept liability for for improper access to that data. We cannot guarantee that only authorized persons will view your Personal Data. We cannot ensure that information you share on our Website and/or through the Primo Services will not become publicly available.

6. Third-Party Social Media Features
Our Website may use social media features, such as “Like” and “Share” buttons, which are operated by third parties such as Facebook, Instagram, LinkedIn, Twitter, etc. These features may collect your IP address, which page you are visiting on our Website, and may set a cookie or employ similar technologies to enable the feature to function properly. If you are not logged into your account with the third-party, then the third-party might not know your identity. If you are logged into your account with the third-party, then the third-party might be able to link information about your visit to our Website to your account with them. Similarly, your interactions with these features may be recorded by the third-party. Your interactions with these features are governed by the privacy policy of the third-party providing the feature. Please refer to the respective third-party’s privacy policy to find out more about its data practices, such as what data is collected about you and how the third-party used such data.

7. Children’s Privacy
The Website is not intended for children under 13 years of age. You must be at least 13 years old to use the Website and/or the Primo Services. We do not knowingly collect Personal Data from any child under 13 years of age. If you are under 13 years of age, do not use the Primo Services and do not provide any Personal Data to us. If you are a parent of a child under 13 years of age and become aware that your child has provided Personal Data to Primo, please contact us at and you may request access, correction, deletion, and/or objection rights.

8. Links to Other Sites
Our Website and the ads we serve on behalf of customers may, from time to time, contain links to external websites. Primo encourages you to review the privacy and security policies of any externally linked websites whose information practices may be different from ours. Primo assumes no responsibility or liability for the information, collection, and disclosure practices of any external websites that a Visitor can access through the Website or the Primo Services. Please check the privacy policies of these external websites before you submit any Personal Data or other information to them.

9. Contact Information
If you have any questions regarding the Privacy Policy, our use of cookies, or our policies regarding the collection, use, processing, retention and/or disclosure of your Personal Data, you may contact us as indicated below:
Visarity Technologies GmbH Lerchenstraße 28a, Hamburg, Germany
Telephone: +49(0)4043095954

A note to data subjects residing in the European Economic Area: If you are not satisfied with our response, or believe we are processing your personal data not in accordance with the law, data subjects covered under the GDPR framework have the right to lodge a complaint with a supervisory authority in the Member State of their habitual residence, place of work, or place of the alleged infringement.

10. Changes to the Privacy Policy
We may, in our discretion, update this policy from time to time. We’ll notify you of material changes to the Privacy Policy via a notice on our home page ( In some cases, we will notify you in advance, and your continued use of the Website and the Primo Services after Primo posts a revised Privacy Policy signifies your acceptance of the revised Privacy Policy. We recommend reviewing this Privacy Policy regularly to ensure you are updated as to any changes.