Primilink
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Privacy Policy

Last updated: May 06, 2026

Effective date: May 06, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.

  • Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

  • Business for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' Personal Information and determines the purposes and means of the processing of Consumers' Personal Information.

  • CCPA/CPRA refers to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 and any applicable regulations issued by the California Privacy Protection Agency.

  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to Primilink LLC, PO Box 1251, Kailua-Kona, Hawaii.

  • Consumer, for the purpose of CCPA/CPRA, means a natural person who is a California resident.

  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

  • Country refers to: Hawaii, United States

  • Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.

  • Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

  • Global Privacy Control (GPC) is a browser-based signal that allows users to communicate their privacy preferences to websites, including their preference to opt out of the sale or sharing of their personal information.

  • Personal Data (or "Personal Information") is any information that relates to an identified or identifiable individual. Under CCPA/CPRA, Personal Information means any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household.

    We use "Personal Data" and "Personal Information" interchangeably unless a law uses a specific term.

  • Sale, for the purpose of CCPA/CPRA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's Personal Information by the Business to a third party for valuable consideration.

  • Sensitive Personal Information, for the purpose of CCPA/CPRA, means Personal Information that reveals a Consumer's social security, driver's license, or other government identifier; account log-in credentials; financial account information; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; contents of mail, email, and text messages; genetic data; biometric information for the purpose of uniquely identifying a Consumer; or information concerning a Consumer's health, sex life, or sexual orientation.

  • Service refers to the Website.

  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

  • Sharing, for the purpose of CCPA/CPRA, means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a Consumer's Personal Information by the Business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

  • Website refers to Primilink, accessible from primilink.com.

  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Business name
  • Information You voluntarily submit through contact, proposal request, or consultation forms

Categories of Personal Information Collected (CCPA/CPRA Disclosure)

In the past twelve (12) months, We have collected the following categories of Personal Information from Consumers, as defined under the CCPA/CPRA:

  • Identifiers: Name, email address, phone number, IP address, business name, and similar identifiers.
  • Customer Records (Cal. Civ. Code § 1798.80(e)): Information You submit through forms or correspondence, including business contact information.
  • Internet or Other Electronic Network Activity Information: Browsing history on Our Service, search history, and information regarding Your interaction with Our Service, advertisements, or emails.
  • Geolocation Data: Approximate (non-precise) location data derived from IP addresses.
  • Inferences: Inferences drawn from any of the above categories to create a profile reflecting Your preferences, characteristics, or behavior.

We do NOT collect Sensitive Personal Information as defined under CCPA/CPRA. We do not knowingly collect or process social security numbers, driver's license numbers, financial account credentials, precise geolocation, biometric data, health information, racial or ethnic origin, religious beliefs, union membership, genetic data, or information concerning sexual orientation or sex life.

Sources of Personal Information

We collect Personal Information from the following categories of sources:

  • Directly from You: When You complete forms, send Us emails, request a proposal, or otherwise communicate with Us.
  • Automatically through Your interaction with Our Service: Through cookies, web beacons, server logs, and similar technologies.
  • From Service Providers: Such as analytics providers and email service providers who collect data on Our behalf.

Business Purposes for Collection

We collect, use, and disclose Personal Information for the following business purposes, as defined under CCPA/CPRA:

  • Auditing related to the Consumer interaction with the Service
  • Detecting security incidents, protecting against malicious or illegal activity
  • Debugging to identify and repair errors
  • Performing services on behalf of the Business, including customer service and processing transactions
  • Internal research for technological development and demonstration
  • Activities to verify or maintain the quality or safety of Our Service
  • Marketing and advertising Our services to Consumers, where permitted

Sale or Sharing of Personal Information

Primilink does not sell Your Personal Information for monetary consideration.

However, certain analytics and advertising tools We use, including Google Analytics, may involve "sharing" of Personal Information for cross-context behavioral advertising under the broad definitions in the CCPA/CPRA. We disclose this for transparency. You have the right to opt out of any such Sharing at any time by using the "Do Not Sell or Share My Personal Information" link in Our website footer or by enabling Global Privacy Control in Your browser.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies We use include beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

Where required by law, we use non-essential cookies (such as analytics, advertising, and remarketing cookies) only with Your consent. You can withdraw or change Your consent at any time using Our cookie preferences tool or through Your browser/device settings. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies

    Type: Session Cookies | Administered by: Us

    Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts.

  • Cookies Policy / Notice Acceptance Cookies

    Type: Persistent Cookies | Administered by: Us

    Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

  • Functionality Cookies

    Type: Persistent Cookies | Administered by: Us

    Purpose: These Cookies allow Us to remember choices You make when You use the Website, such as remembering Your preferences.

  • Analytics Cookies

    Type: Persistent Cookies | Administered by: Third Parties (Google Analytics)

    Purpose: These Cookies help Us understand how visitors interact with Our Service, which pages are most popular, and how We can improve. See the "Google Analytics" section below for more detail.

Google Analytics

We use Google Analytics 4 (GA4), a web analytics service provided by Google LLC ("Google"), to analyze how visitors use Our Service. Google Analytics uses cookies and similar technologies to collect information about Your use of Our Service, including:

  • IP address (anonymized/truncated by default in GA4)
  • Device and browser information
  • Pages You visit and time spent on each page
  • Approximate (city-level) geographic location
  • Referring website or source
  • Interaction events (clicks, scrolls, form submissions)

Google Analytics processes this information to generate reports about Our Service's traffic and usage. We have configured Google Analytics with the following privacy-enhancing settings:

  • IP anonymization is enabled by default in GA4
  • Data retention is set to 14 months (the minimum allowed)
  • Google Signals (cross-device tracking) is disabled unless explicitly enabled
  • Advertising features (remarketing) are disabled unless You have provided consent
  • Google Consent Mode V2 is implemented to honor Your cookie preferences

To opt out of Google Analytics tracking, You may:

  • Decline analytics cookies through Our cookie consent banner
  • Install the Google Analytics Opt-out Browser Add-on
  • Enable Global Privacy Control (GPC) in Your browser
  • Block cookies in Your browser settings

For more information about Google's privacy practices, please review Google's Privacy Policy at policies.google.com/privacy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.

  • For the performance of a contract: the development, compliance and undertaking of any contract with Us through the Service.

  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products or services.

  • To respond to Your inquiries: To attend and manage Your requests, proposals, and questions submitted to Us.

  • To improve our Service: Through analysis, identifying usage trends, and evaluating effectiveness.

  • For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets.

We may share Your Personal Data in the following situations:

  • With Service Providers: Including hosting providers, email services, analytics services, and customer support tools, all of whom are contractually required to protect Your information.
  • For business transfers: In connection with any merger, sale of Company assets, financing, or acquisition.
  • With Affiliates: Who will be required to honor this Privacy Policy.
  • With Your consent: For any other purpose with Your express consent.

Your Privacy Rights Under CCPA/CPRA (California Residents)

If You are a California resident, You have specific rights regarding Your Personal Information under the CCPA/CPRA. These rights apply regardless of whether Primilink meets the formal CCPA "business" thresholds; We voluntarily honor these rights for all California residents as a matter of best practice and respect for Your privacy.

Your Rights

  • Right to Know: You have the right to request that We disclose what Personal Information We collect, use, disclose, sell, or share about You. This includes the categories and specific pieces of Personal Information collected, the categories of sources, the business purposes for collecting, and the categories of third parties with whom We share that information.

  • Right to Delete: You have the right to request that We delete any Personal Information We have collected from You, subject to certain exceptions (such as when retention is required for legal compliance, fraud prevention, or to complete a transaction You requested).

  • Right to Correct: You have the right to request that We correct inaccurate Personal Information We maintain about You.

  • Right to Opt Out of Sale or Sharing: You have the right to opt out of the sale or sharing of Your Personal Information for cross-context behavioral advertising. While Primilink does not sell Personal Information for monetary value, certain analytics tools may constitute "sharing" under CCPA's broad definition. You can exercise this right by clicking the "Do Not Sell or Share My Personal Information" link in Our footer, by enabling Global Privacy Control in Your browser, or by adjusting Your cookie preferences.

  • Right to Limit Use of Sensitive Personal Information: Although We do not collect Sensitive Personal Information, You have the right to limit Our use of any Sensitive Personal Information that may be inadvertently collected.

  • Right to Non-Discrimination: We will not discriminate against You for exercising any of Your CCPA/CPRA rights. We will not deny You services, charge different prices, or provide a different level of quality of services because You exercised Your privacy rights.

  • Right to Use an Authorized Agent: You may designate an authorized agent to make a request on Your behalf. We will require verification of the agent's authority and Your identity before fulfilling the request.

How to Exercise Your CCPA/CPRA Rights

To submit a verifiable consumer request under CCPA/CPRA, You may:

  • Email Us at elijah@primilink.com with "CCPA Request" in the subject line
  • Call Us at (808) 896-9125
  • Use the "Do Not Sell or Share My Personal Information" link in Our website footer

We will respond to verifiable consumer requests within 45 days of receipt. If We require an extension, We will notify You. To verify Your identity, We may ask You to provide information that matches what We already have on file.

Global Privacy Control (GPC)

We honor Global Privacy Control signals as a valid opt-out request for the sale or sharing of Personal Information. When Your browser sends a GPC signal, We will treat it as a request to opt out of any data sharing for cross-context behavioral advertising. You can enable GPC in supported browsers including Brave, Firefox, and DuckDuckGo. Learn more at globalprivacycontrol.org.

Confirmation of Opt-Out

When You exercise Your right to opt out, We will display a confirmation that Your request has been honored. The opt-out process will require no more steps than the path to grant consent, in compliance with the CCPA's symmetry requirement.

Your Privacy Rights in Other US States

If You are a resident of Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, or other states with comprehensive privacy laws, You may have rights similar to those described above for California residents. We voluntarily extend the rights described in the CCPA/CPRA section to all US residents to the extent applicable. To exercise Your rights, please contact Us using the information at the end of this Policy.

Do Not Track Signals

Some browsers offer a "Do Not Track" (DNT) feature that signals websites to disable tracking. Currently, no industry standard has been adopted for how DNT signals should be honored, and We do not respond to DNT signals at this time. However, We do honor Global Privacy Control signals as described above.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

Where possible, We apply shorter retention periods and reduce identifiability by deleting, aggregating, or anonymizing data. The retention periods below are maximum periods ("up to") and We may delete or anonymize data sooner when no longer needed:

  • Contact Form and Proposal Request Data: Up to 24 months from last interaction. Used to respond to inquiries and provide services.

  • Customer Communication and Project Data: Up to 7 years after the end of the client relationship, for legal, tax, and contractual reasons.

  • Website Analytics Data (Google Analytics): 14 months (configured to the minimum allowed by GA4).

  • Server Logs: Up to 12 months for security monitoring and troubleshooting.

  • Cookies: Vary by cookie type. Persistent cookies typically expire after 12 to 24 months unless You delete them sooner.

We may retain Personal Data beyond these periods where required by law (e.g., financial records for tax authorities), to establish or defend legal claims, or where You have explicitly requested retention.

When retention periods expire, We securely delete or anonymize Personal Data. Residual copies may remain in encrypted backups for a limited period consistent with Our backup retention schedule.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices in Hawaii, United States, and in any other places where the parties involved in the processing are located. This information may be transferred to and maintained on computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.

Where required by applicable law, We will ensure that international transfers of Your Personal Data are subject to appropriate safeguards. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

You may contact Us to request access to, correct, or delete any Personal Data that You have provided to Us. Please note, however, that We may need to retain certain information when We have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us. We use commercially reasonable means to protect Your Personal Data, including:

  • SSL/TLS encryption for data transmitted to and from Our Service
  • Secure hosting with reputable providers
  • Limited access to Personal Information on a need-to-know basis
  • Regular security reviews and updates

However, no method of transmission over the Internet, or method of electronic storage is 100% secure, and We cannot guarantee absolute security.

Children's Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from Our servers.

Under CCPA/CPRA, We do not knowingly sell or share Personal Information of Consumers under the age of 16 without affirmative authorization (opt-in) from the Consumer (if 13-15) or their parent or guardian (if under 13).

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top of this Privacy Policy. For significant changes, We may also provide email notice or a prominent notice on Our Service prior to the change becoming effective.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, or to exercise any of Your privacy rights, You can contact us:

  • By email: elijah@primilink.com
  • By phone: (808) 896-9125
  • By mail: Primilink LLC, PO Box 1251, Kailua-Kona, HI 96740

For CCPA/CPRA-related requests, please include "CCPA Request" or "Privacy Rights Request" in the subject line of Your email.