Privacy Policy

For PRIMARY metaverse d.o.o. / PRIMARY DMCC, hereinafter referred to as “Primary”, the protection of personal data of users has the highest priority. This Privacy Policy explains the collection, use, disclosure, storage and protection of your personal information.

§ 1 Scope

This Privacy Policy applies to all Primary websites, applications, services or tools (collectively, “services") that make reference to this Privacy Policy, regardless of how you access or use those services, including access through mobile devices.

§ 2 Name and contact details of the responsible person

PRIMARY metaverse d.o.o. (hereinafter Primary)
Trg zrtava fasizma 1
10000 Zagreb
Croatia

PRIMARY DMCC (hereinafter Primary)
Almas tower, 48th floor
Jumeirah Lake Towers
Dubai
United Arab Emirates

Email: [email protected]

The company data protection officer of Primary can be contacted at the address mentioned above under the above-mentioned address by adding “data protection officer" and via [email protected].

§ 3 Collection and storage of personal data as well as the nature and purpose of their use

(1) When visiting the website

When you visit our website www.primary.io, the browser used on your device automatically sends information to the server of our website. This information is temporarily stored in a so-called log file. The following information is collected without your intervention and stored until automated deletion:

• IP address of the requesting computer,
• date and time of access,
• name and URL of the retrieved file,
• the website from which access is made (referrer URL),
• used browser and, if applicable, the operating system of your computer as well as the name of your access provider.

The data mentioned are processed by us for the following purposes:

• Ensuring a smooth connection of the website,
• ensuring comfortable use of our website,
• evaluation of system security and stability as well as for further administrative purposes.

The legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest follows from the data collection purposes listed above. In no case, we use the collected data for the purpose of drawing conclusions about you.
In addition, we use cookies and analysis services when visiting our website. Further details can be found under § 4 and 5 of this privacy policy.

(2) When registering for our newsletter

If pursuant to Art. 6 para. 1 sentence 1 lit. a GDPR has expressly consented or this represents a contractual obligation on our part pursuant to Art. 6 para. 1 sentence 1 lit. b GDPR, we use your e-mail address and – as far as you have voluntarily stated – first and last name and address for regularly sending you our newsletter. For the receipt of the newsletter, the indication of an e-mail address is sufficient. The processing of this personal data takes place exclusively for the purpose of being able to offer you the desired information and services, and only in the manner and extent to which you have expressly consented in advance or we are contractually obligated.

Your personal data will only be passed on to a carefully selected service provider for the purpose of sending the newsletter and only in compliance with data protection regulations in accordance with the GDPR or similar with a comparable level of protection.

You can revoke your consent at any time with effect for the future. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until the revocation. The deregistration is possible at any time, for example via a link at the end of each newsletter. Alternatively, you can also send an unsubscribe request to [email protected] by e-mail. The personal data will be deleted immediately upon cancellation of the newsletter.

(3) By using our contact form or booking a tour

For requests of any kind regarding our services, we offer you the possibility to contact us via a form provided on the website. We also offer the opportunity to book a tour of one of our locations through our website to get an insight into our coworking world. This is also done via a form provided on the website. These forms require the full name, valid e-mail address and phone number to let us know who the request came from and to respond to it.

The data processing for the purpose of contacting us is in accordance with Art. 6 para. 1 p. 1 lit. a GDPR based on your voluntarily granted consent.

The personal data collected by us for the use of the contact form will be automatically deleted after completion of the request made by you.

(4) Supplementary information regarding video surveillance

We would like to inform you about the video surveillance on our premises. This information is in reference to the European General Data Protection Regulation (hereinafter referred to as GDPR) and the Federal Data Protection Act (abbreviated to BDSG below).

(a) Purposes and Legal bases of data processing and it’s legitimate interests

Video Surveillance serves our legitimate interest in preventing and informing the entry of unauthorized persons into the premises and in preventing and resolving crimes and in preventing and resolving vandalism on our premises. The legal basis for video surveillance is Art. 6 para. 1 lit. d) and f) GDPR.

(b) Storage duration

The video recordings will be automatically deleted as long as there is no reasonable case for a longer storage period.

(c) Categories of recipients of your personal data and transmission to third countries

In certain cases, we may need video surveillance footage, in which case you might be visible, to give to certain people within our company and its affiliates to review and evaluate the material in the event of a crime. This includes, for example, not only the sighting of the material at our site by appropriate employees, but in certain circumstances also passing it on to the IT and Legal departments.

Disclosure to recipients outside of our company is only possible if the legal requirements apply. This is particularly the case if the disclosure is required to prosecute a criminal offense or to exercise, assert or defend civil claims (for example, to law enforcement agencies or external lawyers who advise us) and if the interests of the data subjects do not outweigh the legitimate interests of the responsible. In exceptional cases, personal data may be processed outside the EU or the European Economic Area, in which case we will ensure your privacy by providing adequate data protection safeguards (such as EU standard contractual clauses).

The legal basis for disclosure in such a case is Article 6 Para. 1 lit. f) GDPR in connection with Article 24 Para. 1 Nr. 1 and 2 BDSG and if applicable in conjunction with Art. 28 (3) GDPR.

(d) Your Rights in relation to data

You have the right to request information about the processing of your personal data from us at any time.

We will explain to you about the data processing activities and provide you with an overview of what data has been stored about you. If data stored with us should be incorrect or out of date, you have the right to have this data corrected. You may also request the deletion of your data if one of the reasons listed in Art. 17 GDPR is applicable, e.g. if the data is no longer needed for the purposes pursued. If there is no reason for the deletion or the deletion due to other legal provisions is not possible in exceptional cases, the data will be blocked, so that it only available for this legal purpose.

Finally, you have the right to complain to the Data Protection Authority. You may assert this right with a supervisory authority in the Member State of your place of residence, your place of work or the place of the alleged infringement. In Berlin, the supervisory authority is the Berliner Datenschutzbeauftragte (Berlin Data Protection Office), which can be reached by e-mail at [email protected].

§ 4 Disclosure of data

A transfer of your personal data to third parties, for purposes other than those listed below, does not take place.

We only share your personal information with third parties if:

• You have given express consent according to Art. 6 para. 1 p. 1 lit. a GDPR,
• the disclosure pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR is required to assert, exercise or defend legal claims and there is no reason to assume that you have an overriding interest in not disclosing your data,
• in the event that disclosure pursuant to Art. 6 para. 1 sentence 1 lit. c GDPR a legal obligation exists as well
• this is legally permissible and, according to Art. 6 para. 1 sentence 1 lit. b GDPR is required for the settlement of contractual relationships with you.

§ 5 Cookies

We use cookies on our site. These are small files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our site. Cookies do not harm your device, do not contain viruses, Trojans or other malicious software. In the cookie information is stored, each resulting in connection with the specific terminal used. However, this does not mean that we are immediately aware of your identity. On the one hand, the use of cookies serves to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages on our website. These are automatically deleted after leaving our page. In addition, to improve usability, we also use temporary cookies that are stored on your device for a specified period of time. If you visit our site again to use our services, it will automatically recognize that you have already been with us and what inputs and settings you have made, so you do not have to re-enter them.

On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer (see section 5). These cookies allow us to automatically recognize when you visit our site again that you have already been with us. These cookies are automatically deleted after a defined time.

The data processed by cookies are for the purposes mentioned in order to safeguard our legitimate interests as well as third parties pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR required.

Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a note always appears before a new cookie is created. However, disabling cookies completely may mean that you can not use all features of our website.

§ 6 Analysis Tools

The tracking measures listed below and used by us are based on Art. 6 para. 1 sentence 1 lit. f GDPR. With the tracking measures to be used, we want to ensure a needs-based design and the continuous optimization of our website. On the other hand, we use the tracking measures to statistically record the use of our website and evaluate it for the purpose of optimizing our offer for you. These interests are to be regarded as justified within the meaning of the aforementioned provision.

The respective data processing purposes and data categories can be found in the corresponding tracking tools.

(1) Google Analytics

We use Google Analytics, a web analytics service provided by Google Inc. (https://www.google.com/intl/en/about/) (1600 Amphitheater Parkway, Mountain View, CA 94043, for the purpose of customizing and continually optimizing our pages. USA, hereafter “Google"). In this context, pseudonymized usage profiles are created and cookies (see point 4) are used. The information generated by the cookie about your use of this website such as

• Browser type / version,
• the used operating system,
• referrer URL (the previously visited page),
• hostname of the accessing computer (IP address),
• time of server request,

are transferred to a Google server in the US and stored there. The information is used to evaluate the use of the website, to compile reports on website activity, and to provide other services related to website activity and internet usage for the purpose of market research and customization of these websites. This information may also be transferred to third parties if required by law or if third parties process this data in the order. Under no circumstances will your IP address be merged with any other data provided by Google. The IP addresses are anonymized so that an assignment is not possible (IP masking).

You can prevent the installation of cookies by setting the browser software accordingly; however, we point out that in this case not all features of this website may be fully exploited.

You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout).

As an alternative to the browser add-on, especially for browsers on mobile devices, you can prevent the collection by Google Analytics by clicking on this link. An opt-out cookie will be set which prevents the future collection of your data when you visit this website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again.

For more information about privacy related to Google Analytics, see the Google Analytics Help Center (https://support.google.com/analytics/answer/6004245?hl=en).

(2) Google Adwords Conversion Tracking

To statistically record the use of our website and to evaluate it for the purpose of optimizing our website, we also use Google conversion tracking. Google Adwords will set a cookie (see § 4) on your computer, provided that you have reached our website via a Google ad.

These cookies lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of the Adwords customer’s website and the cookie has not yet expired, Google and the customer can recognize that the user clicked on the ad and was redirected to this page.

Each Adwords customer receives a different cookie. Cookies cannot be tracked via the websites of Adwords customers. The information gathered using the conversion cookie is used to generate conversion statistics for Adwords customers who have opted for conversion tracking. Adwords customers hear the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, they do not receive any information that personally identifies users.

If you do not want to participate in the tracking process, you can also refuse the required setting of a cookie – for example, via a browser setting that generally deactivates the automatic setting of cookies. You can also disable cookies for conversion tracking by setting your browser to block cookies from the domain “www.googleadservices.com". Google’s privacy policy on conversion tracking can be found here (https://services.google.com/sitestats/en.html).

§ 7 Social Media Plug-ins

We rely on our website on the basis of Art. 6 para. 1 sentence 1 lit. f GDPR social plug-ins from the social networks Facebook, Twitter, Xing, Linkedin and Instagram to make our company better known. The underlying commercial purpose is to be regarded as a legitimate interest within the meaning of the GDPR. Responsibility for the operation compliant with data protection is to be guaranteed by their respective providers. The integration of these plug-ins by us takes place in the way of the so-called two-click method to protect visitors of our website in the best possible way.

(1) Facebook

Our website uses social media plugins from Facebook to personalize its use. For this, we use the “LIKE" or “SHARE" button. It is an offer from Facebook.

If you visit a page of our website that contains such a plugin, your browser establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by Facebook directly to your browser and integrated by this in the website.

By integrating the plugins, Facebook receives the information that your browser has accessed the corresponding page of our website, even if you do not have a Facebook account or are currently not logged in to Facebook. This information (including your IP address) is transmitted from your browser directly to a Facebook server in the US and stored there.

If you are logged in to Facebook, Facebook can assign the visit to our website directly to your Facebook account. If you interact with the plugins, for example by pressing the “LIKE" or “SHARE" button, the corresponding information is also transmitted directly to a Facebook server and stored there. The information will also be posted on Facebook and displayed to your Facebook friends.

Facebook may use this information for the purpose of advertising, market research, and tailor-made Facebook pages. For this purpose, Facebook uses user, interest and relationship profiles, eg. For example, to evaluate your use of our website in relation to the advertisements displayed on Facebook, to inform other Facebook users about your activities on our website, and to provide other services related to the use of Facebook.

If you do not want Facebook to assign the data collected via our website to your Facebook account, you must log out of Facebook before visiting our website.

The purpose and scope of the data collection and the further processing and use of data by Facebook, as well as your rights in this regard and settings options for the protection of your privacy, please refer to the privacy policy (https://www.facebook.com/about/privacy/) of Facebook.

(2) Twitter

On our website plugins of the short message network of Twitter Inc. (Twitter) are integrated. The Twitter plugins (tweet button) can be recognized by the Twitter logo on our site. An overview of tweet buttons can be found here (https://about.twitter.com/resources/buttons).

When you visit a page of our website that contains such a plugin, a direct connection is established between your browser and the Twitter server. Twitter receives the information that you have visited our site with your IP address. If you click on the Twitter “tweet button" while logged in to your Twitter account, you can link the contents of our pages to your Twitter profile. This allows Twitter to associate your visit to our pages with your user account. We point out that we as the provider of the pages are not aware of the content of the transmitted data and their use by Twitter.

If you do not want Twitter to associate your visit to our pages, please log out of your Twitter account.

Further information can be found in the privacy policy of Twitter (https://twitter.com/privacy).

(3) Instagram

Our website also uses so-called social plugins (“plugins") operated by Instagram LLC, 1601 Willow Road, Menlo Park, CA 94025, USA (“Instagram").

By integrating the plugins, Facebook receives the information that your browser has accessed the corresponding page of our website, even if you do not have a Facebook account or are currently not logged in to Facebook. This information (including your IP address) is transmitted from your browser directly to a Facebook server in the US and stored there.

If you are logged in to Facebook, Facebook can assign the visit to our website directly to your Facebook account. If you interact with the plugins, for example by pressing the “LIKE" or “SHARE" button, the corresponding information is also transmitted directly to a Facebook server and stored there. The information will also be posted on Facebook and displayed to your Facebook friends.

Facebook may use this information for the purpose of advertising, market research, and tailor-made Facebook pages. For this purpose, Facebook uses user, interest and relationship profiles, eg. For example, to evaluate your use of our website in relation to the advertisements displayed on Facebook, to inform other Facebook users about your activities on our website, and to provide other services related to the use of Facebook.

If you do not want Facebook to assign the data collected via our website to your Facebook account, you must log out of Facebook before visiting our website.

The purpose and scope of the data collection and the further processing and use of data by Facebook, as well as your rights in this regard and settings options for the protection of your privacy, please refer to the privacy policy (https://www.facebook.com/about/privacy/) of Facebook.

(4) Linkedin

Our website continues to use the Share feature of the LinkedIn network. Provided by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, United States. If you click on the LinkedIn “Share-Button" (plug-in), you will – if you are logged into your user account at LinkedIn – forwarded in a separate browser window on your user account and the deposited on our website electronic publication with the addition of a comment divide. The plug-in creates a direct connection between your browser and the LinkedIn server. LinkedIn receives the information that you have visited our website with your IP address. In addition, LinkedIn will be able to associate your visit to our website with you and your user account.

We point out that we have no knowledge of the content of the transmitted (personal) data and their use by LinkedIn. For more information, see the LinkedIn privacy statement at: https://www.linkedin.com/legal/privacy-policy.

(5) Xing

Our website also uses the share function of the network XING. The provider is the XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. If you click the XING “Share-Button" (plug-in), you will – if you are logged into your user account at XING – forwarded in a separate browser window on your user account and can the deposited on our website electronic publication with the addition of a comment divide. The plug-in establishes a direct connection between your browser and the XING server. XING receives the information that you have visited our website with your IP address. We point out that we have no knowledge of the content of the transmitted (personal) data and their use by XING.

Further information can be found in XING’s privacy policy at https://www.xing.com/app/share?op=data_protection.

§ 8 Webtool

(1) Google Web Fonts

This site uses so-called web fonts provided by Google for the uniform representation of fonts. When you call up a page, your browser loads the required web fonts into your browser cache to correctly display texts and fonts. The provider is Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.

To do this, the browser you use must connect to Google’s servers. As a result, Google learns that our website has been accessed via your IP address. The use of Google Web Fonts is in the interest of a consistent and attractive presentation of our online services. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR.

If your browser does not support web fonts, a default font will be used by your computer.

More information about Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google’s Privacy Policy: https://www.google.com/policies/privacy/

(2) Google Maps

This site uses the mapping service Google Maps via an API. The provider is Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.

To use the features of Google Maps, it is necessary to save your IP address. This information is usually transmitted to and stored by Google on servers in the United States. The provider of this page has no influence on this data transfer.

The use of Google Maps is for the sake of an appealing presentation of our online offers and easy findability of the places we specify on the website. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR.

For more information on how to handle user data, please refer to the Google Privacy Policy: https://www.google.com/intl/en/policies/privacy/.

§ 9 Rights of the persons affected

You have the right:

• to request information about your personal data processed by us in accordance with Art. 15 GDPR. In particular, you may provide information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been disclosed, the planned retention period, the right of rectification, deletion, limitation of processing or opposition, the existence of a The right to complain, the source of their data, if not collected from us, and the existence of automated decision-making including profiling and, where appropriate, meaningful information about their details;
• to demand the rectification of incorrect or completed personal data stored by us immediately in accordance with Art. 16 GDPR;
• to require the deletion of your personal data stored by us n accordance with Art. 17 GDPR, except where the processing is for the exercise of the right to freedom of expression and information, for the fulfillment of a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal claims is required;
• to demand the restriction of the processing of your personal data in accordance with Art. 18 GDPR, as far as the accuracy of the data is disputed by you, the processing is unlawful, but you reject their deletion and we no longer need the data, but you to assert, exercise or defense of legal claims or you have objected to the processing in accordance with Art. 21 GDPR;
• to obtain your personal data provided to us pursuant to Art. 20 GDPR in a structured, common and machine-readable format or to request the transfer to another person responsible;
• your once granted consent to revoke against us at any time pursuant to Art. 7 para. 3 GDPR. As a result, we are no longer allowed to continue the data processing based on this consent for the future and
• to complain to a supervisory authority according to Art. 77 GDPR. As a rule, you can contact the supervisory authority of your usual place of residence or work or our company headquarters.

§ 10 Right of objection

If your personal data are based on legitimate interests in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR, you have the right to file an objection against the processing of your personal data in accordance with Art. 21 GDPR provided that there are reasons for this arising from your particular situation or if the objection is directed against direct mail. In the latter case, you have a general right of objection, which is implemented by us without stating a particular situation.

If you would like to exercise your right of revocation or objection, please send an e-mail to [email protected].

§ 11 Data security

We use the widely used Secure Socket Layer (SSL) method in conjunction with the highest level of encryption supported by your browser. In general, this is 256-bit encryption. If your browser does not support 256-bit encryption, we’ll use 128-bit v3 technology instead. Whether a single page of our website is transmitted in encrypted form is indicated by the closed representation of the key-related or lock symbol in the lower status bar of your browser.

We also take appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or total loss, destruction or against unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

§ 12 Updating and changing this privacy policy

This data protection declaration is currently valid and has the status of March 2019.

Due to the further development of our website and offers or due to changed legal or regulatory requirements, it may be necessary to change this privacy policy. The current privacy policy can be viewed and printed by you at any time on the website at https://www.primary.io/privacy/.