Privacy Policy for Primo Passo Holding GmbH & Primo Passo GbR

Effective Date: 18.04.2024

This Privacy Policy outlines how Primo Passo Holding GmbH & Primo Passo GbR, located at Girardet Str. 60, 45131 Essen, Germany (“we”, “us”, or “our”), collect, use, and share your personal information across our websites: www.primo-passo.de, www.upgradedcoach.com, www.digitallifeupgrade.com, www.primawomanbygio.com, and www.primowomanbyplus.com.

1. Information We Collect

1.1 Personal Information Provided by You

• Contact Information: Names, addresses, telephone numbers, email addresses.
• Payment Information: Details necessary to process your transactions.
• Account Information: Information you provide during account creation, such as usernames and passwords.
• Communication Data: Information from communications via emails, forms, or other interactions.

1.2 Information Collected Automatically

• Usage Data: Data on how you interact with our sites, such as pages visited and interactions made.
• Technical Data: IP addresses, browser types and versions, and device identifiers.
• Cookies and Tracking Technologies: Used to enhance user experience and analyze site traffic.

2. How We Use Your Information

• Service Provision: Managing accounts, transactions, and delivering services.
• Personalization and Marketing: Customizing experiences and sending promotional materials, subject to your consent.
• Communication: Responding to inquiries and sending updates.
• Analytics and Improvement: Analyzing usage to enhance our services.
• Compliance and Enforcement: Meeting legal requirements and enforcing our terms.

3. Sharing Your Information

3.1 Service Providers

We engage various service providers, contractors, and third-party services to assist in the operation of our websites and to manage how we interact with you. Here are the key third-party services we use:

• Kajabi: Serves as our CRM and email marketing platform. Kajabi stores contact details such as names, email addresses, and phone numbers to manage customer relationships and distribute marketing materials. Kajabi complies with GDPR by implementing strong data protection measures, including data encryption and regular security audits. Data is hosted on servers located in the United States. For more information, please visit Kajabi’s Privacy Policy.
• Rainmaker AI: Used as a CRM tool, Rainmaker AI helps in managing and analyzing customer interactions and data throughout the customer lifecycle. It stores and processes names, emails, and optionally phone numbers to enhance customer service and support. Rainmaker AI ensures GDPR compliance by using secure servers, encrypting data at rest and in transit, and providing users with access control and audit logs. Data transfer outside the EU is covered under the standard contractual clauses, ensuring compliance with EU data protection requirements. For more information, please review Rainmaker AI’s Privacy Policy.
• Google Analytics: Utilized to track and report website traffic. Google Analytics collects data such as IP addresses, user device information, and on-site behaviors. This data helps in optimizing our website to better serve our users. Google complies with GDPR under the Privacy Shield framework, ensuring appropriate data protection. Users can opt out of Google Analytics tracking with the Google Analytics opt-out browser add-on. More details can be found at Google’s Privacy & Terms.

3.2 Social Media Platforms and Advertising

• Facebook Lead Ad Forms: We use Facebook lead ad forms to collect names and email addresses for marketing purposes. Facebook adheres to GDPR through its robust data privacy and security measures, which are detailed at Facebook’s Business GDPR.
• Instagram: Owned by Facebook, used for marketing and audience engagement by sharing visual content. Instagram also follows GDPR standards as specified in their policies.
• YouTube: We embed YouTube videos on our websites. Owned by Google, YouTube processes information about the videos viewed on our website in compliance with Google’s Privacy Shield certification.

3.3 Legal and Regulatory Requirements

We may disclose your personal information if required by law or if we believe in good faith that such action is necessary to comply with legal processes served on our company or to protect and defend our rights or property.

4. International Data Transfers

Your data may be transferred outside the EU, primarily to the United States. We ensure all data transfers comply with GDPR through standard contractual clauses or similar mechanisms.

5. Your Rights Under GDPR

• Access and Control: You can review, amend, or delete your personal information.
• Restrictions and Objections: You have the right to restrict or object to our processing of your data.
• Portability: You have the right to receive your data in a portable format.
• Consent Withdrawal: You may withdraw your consent at any time, affecting only future processing.
• Exercise Your Rights: Contact us at info@primo-passo.de or via postal mail to exercise these rights.

6. Security Measures

We implement suitable technical and organizational measures to protect your personal data from unauthorized access or disclosure.

7. Cookies Policy

You can manage cookies through your browser settings, opting out where necessary.

8. Changes to This Policy

We may update this policy to reflect changes in legal or regulatory obligations or operational practices.

9. Contact Us

For any questions about this policy or our privacy practices, contact us at:

Address: Girardet Str. 60, 45131 Essen, Germany
Phone: +49 201 45866008
Email: info@primo-passo.de