Legal

For Non-Child Users: (i.e. users aged 13 and older in the U.S., including parents.)

1. What information does Primer collect from non-Child Users?

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.

Third Party Services and Information Third Parties Provide About YouFor non-Child Users, the Services may permit interactions between the Services and a third-party feature or service. These third parties may provide us with information about you. Similarly, if you publicly post information on a third-party platform, such as a social media site, that references Primer or one of the Services, your post may be published on our Services in accordance with that third party’s terms. These features may collect your IP address or other unique identifier and which page you are visiting on our website, and may set a cookie to enable the third-party feature to function properly. Your interactions with third-party links and features are governed by the privacy policies of these third parties.The information collected and stored by these third parties remains subject to the third party’s privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third party website and service. The third party may allow you to remove the application or feature, in which case we will no longer collect information about you through the application or feature, but we may retain the information previously collected in compliance with all applicable laws.a. What information does Primer collect automatically?We and our analytics providers, vendors and other third-party service providers may automatically collect certain “Usage Information” (as defined below) whenever you access and use the Services.Usage Information may include the browser and operating system you are using, the URL that referred you to our Services (if applicable), the search terms you entered into a search engine that led you to our Services (if applicable), all of the areas within our Services that you visit, how often you access certain features, and the time of day you used the Services, among other information.In addition, we automatically collect your IP address or other unique identifier (“Device Identifier”) for any computer, mobile phone or other device (any, a “Device”) you may use to access the Services. A Device Identifier is a number that is automatically assigned to your Device used to access a Service, and our servers identify your Device by its Device Identifier. Some mobile service providers may also provide us or our third-party service providers with information regarding your internet service provider (ISP), date and time of your visit, browser language, browser type, referring and exit pages and URLs, amount of time spent on particular pages, which parts of our Services you use, which links you click, search terms, operating system, traffic and related statistics, keywords, and/or other general browsing or usage data. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, such as by connecting it to your Device Identifier, we treat it as Personal Information and process it according to this Privacy Policy. We may use Usage Information to operate and analyze the Services, and for other lawful business purposes, including sharing with third party service providers.Usage Information is collected via tracking technologies, such as cookies. We use “cookies” (a small file sent to your computer by a website or device to allow the website or app to store information which uniquely identifies you) or other similar software to collect data in order to provide you with a more personal experience visits in our Website or apps. For example, cookies help our systems recognize you if you return to our Services shortly after exiting them.b. How does Primer use the Personal Information it collects about non-Child Users?We may use Personal Information about non-Child Users for the following purposes:

1. To provide the Services. We may use your Personal Information to verify your registration, such as through the photo verification process described above, provide you with the Services, allow you to participate in features we offer, and contact you regarding the Services.
2. To operate and improve the Services. Your Personal Information may be used to tailor content and recommendations, as well as to maintain or improve our Services.

• Audio and video information. We may record the rooms or lessons hosted on the Services. We will only use these recordings to operate and improve the Services, including for customer support, quality control, and to ensure compliance with our terms (such as our Code of Conduct), including responding to any alleged Prohibited Behavior (as defined in the Terms of Service, such as bullying, harassment, etc.).

1. To send communications (including marketing communications) and display offers. We may use Personal Information about non-Child Users to send communications to consenting non-Child Users regarding new or existing offerings or other materials that may be of interest. Recipients may unsubscribe at any time by clicking on the unsubscribe link in any email.
2. To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified information from your Personal Information by excluding information that makes it personally identifiable to you, and we may use that anonymous, aggregated or de-identified data for our lawful business purposes, including sharing it with third parties.
3. For compliance, fraud prevention, and safety. We may use your Personal Information as we believe is necessary or appropriate to (a) enforce our Terms of Service; (b) protect our rights, privacy, safety or property, and that of you or others; and (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.
4. To comply with law. We may use your Personal Information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
5. For other purposes, with your consent. In some cases and where permitted or required by law, we may ask for your consent to collect, use, or share your Personal Information.

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