Privacy Policy

Who we are

Primo makes an operations app for multi-unit restaurant and retail operators. It includes checklists called missions, with photo proof and timers, plus maintenance tickets, training, leaderboards, and an AI agent called the Primo agent. "Primo," "we," "us," and "our" mean Primo, based in Las Vegas, Nevada, USA.

This policy covers our website, our web app, our iOS and Android apps, and kiosk mode on shared store tablets. It applies to:

• customers, meaning the businesses that sign up for Primo and the owners and admins who manage their accounts
• employees of our customers, such as crew and managers, who use Primo at work
• visitors to our website and anyone who contacts us

If you use Primo through your employer, your employer decides what data goes into Primo and how it is used. The section on employee data explains what that means for you.

What we collect

Information you or your organization give us

• Account data, such as your name, email address, and phone number.
• Business configuration and store data, such as store locations, missions, and settings.
• Employee names and roles, which admins add when they set up their team.
• A 6-digit PIN for signing in on kiosk tablets. We store PINs only as salted hashes, never in plain text.
• Mission answers, timers, maintenance tickets, and training progress.
• Photos taken as proof of work. These can show people who happen to be in the frame.
• Chat messages, dictation, and files you send the Primo agent, such as SOP binders and manuals.
• Audio from live voice calls with the Primo agent, and transcripts of those calls.
• Messages you send us for support.

Information the service creates or collects automatically

• Performance points, ratings, and leaderboard positions.
• Device information and push-notification tokens, which let us send notifications to your device.
• Usage logs, such as the actions taken in the app, when they happened, IP addresses, and errors.
• Cookies, as described in the section on cookies.

Information from other sources

• Your employer adds your name, role, and store when it sets up your account.
• Stripe processes payments and tells us payment status and limited card details, such as the card brand and last four digits. Primo never stores full card numbers.

How we use information

We use information to:

• provide the service, including missions, tickets, training, leaderboards, and the Primo agent
• sign you in, including PIN sign-in on kiosk tablets
• send push notifications and service emails, such as invitations and account notices
• bill customers through Stripe
• answer support requests
• keep the service secure, prevent abuse, and investigate incidents
• improve the service, using usage logs and service metrics
• comply with the law and enforce our Terms of Service

We do not sell personal information, and we do not use customer data to train our own AI models.

Legal bases under the GDPR

If the GDPR or UK GDPR applies to you, we rely on these legal bases:

• Contract, to provide the service to our customers.
• Legitimate interests, to secure and improve the service, prevent abuse, and communicate with business contacts.
• Legal obligation, to keep tax records and respond to lawful requests.
• Consent, where we ask for it, such as permission to send push notifications to your device. You can withdraw consent at any time.

For employee data we process for a customer, the customer decides the legal basis.

How AI processing works

The Primo agent and photo review use AI models from the providers in the subprocessor table below. To answer a question, review a photo, or run a voice call, we send an AI provider the content that task needs. That can include messages, photos, transcripts, files, and the business data relevant to the answer. The provider returns a result, which we show in the app.

• We use each provider's business API offering, and each provider handles the data under its API terms.
• We do not sell this data, and we do not use customer data to train our own models.
• Live voice calls stream audio to an AI provider, which runs the conversation and produces a transcript.
• When the Primo agent runs code to complete a task, the code runs in an isolated sandbox that is destroyed after each job.
• Photo review checks whether a photo shows the required work. Primo does not use facial recognition or any other biometric identification.
• AI output can be wrong. Our customers decide what to do with it, and our Terms tell them not to base decisions about employees on AI output alone.

How we share information

We share personal information only as this policy describes.

Subprocessors

These companies process personal information on our behalf to run Primo, under written agreements with us.

Subprocessor	Purpose	Location
Supabase	Database, authentication, and file storage	United States
Vercel	Hosting, serverless functions, and isolated code-execution sandboxes	United States
Stripe	Payments and billing	United States
Resend	Transactional email	United States
Expo	Push notifications and app updates	United States
Anthropic	AI models	United States
OpenAI	AI models, voice, transcription, and image generation	United States
Orbio	AI model routing	United States
OpenRouter	AI model routing and fallback	United States

We give at least 30 days' notice before we add a new subprocessor, through our changelog or by email to account owners.

Within your organization

Admins and managers in your organization can see work data such as mission answers, photos, tickets, and points, depending on the roles your organization sets. Leaderboards show names and points to others in your organization.

Legal requests and safety

We may disclose information when the law requires it, such as in response to a subpoena or court order. We may also disclose it when we believe disclosure is needed to protect someone's safety or the security of the service. Where the law allows, we tell the affected customer first.

Business transfers

If Primo is involved in a merger, an acquisition, or a sale of assets, personal information may transfer to the new owner. We will tell customers before their information becomes subject to a different privacy policy.

With permission

We share information for other purposes when you or your organization asks us to.

Employee data

Our customers are employers. When an employer uses Primo, it decides which employee data goes into the service and why. For that data, the employer is the controller and Primo is its processor. Under California law, the employer is the "business" and Primo is its "service provider." Our Data Processing Addendum limits us to processing employee data to provide the service to the employer.

Employers must tell their employees about photo proof, voice calls, and AI review, and must get any consent their local law requires.

If you are an employee and want to see, correct, or delete your data, ask your employer first. If you contact us instead, we will send your request to your employer and help it respond. We act on employee data at the employer's direction, unless the law requires otherwise.

How long we keep information

• We keep account data and customer data while the customer's account is active.
• After a customer cancels, it has 30 days to export its data. We then delete the data from our production systems within a further 30 days. Copies in our backups roll off within 30 days after that.
• We keep billing records as long as tax law requires.
• We may keep information longer when the law requires it or to resolve a dispute.

How we protect information

• We separate each customer's data by organization, using row-level security in our database.
• We encrypt data in transit with TLS, and our infrastructure providers encrypt it at rest.
• People and systems get only the access they need.
• We store PINs only as salted hashes, and Stripe holds card numbers.
• Code that the Primo agent runs executes in a fresh sandbox that is destroyed after each job.
• If we confirm a breach of a customer's data, we notify affected customers without undue delay and within 72 hours.

No system is perfectly secure. To report a security issue, email ryannovak07@gmail.com.

Your privacy rights

Your rights depend on where you live. If your employer uses Primo, send requests about your work data to your employer first.

California and other US states

The California Consumer Privacy Act, as amended by the California Privacy Rights Act, gives California residents the right to:

• know what personal information we collect, use, and disclose, and get a copy of it
• delete their personal information
• correct inaccurate personal information
• opt out of the sale or sharing of their personal information
• limit the use of their sensitive personal information
• not be treated differently for using these rights

We do not sell personal information or share it for cross-context behavioral advertising, and we have not done so in the past 12 months. We use sensitive personal information, such as account sign-in credentials and PIN hashes, only to provide the service and keep it secure. California law permits that use without an opt-out.

We collect these categories of personal information:

Category	Examples
Identifiers	Name, email address, phone number, IP address, and device and push-notification tokens
Commercial information	Subscription and billing history
Internet or other electronic activity	Usage logs
Audio and visual information	Proof-of-work photos and voice call audio
Professional or employment information	Role, store, mission answers, points, and ratings
Sensitive personal information	Account sign-in credentials and PIN hashes

We collect each category from the sources, use it for the purposes, disclose it to the recipients, and keep it for the periods this policy describes. We disclose each category to our subprocessors only for business purposes.

Residents of other US states with consumer privacy laws may have similar rights. These can include the right to access, correct, or delete their data, to get a portable copy, and to appeal our decision on a request.

EU, EEA, and UK

If the GDPR or UK GDPR applies to you, you have the right to access your personal data, correct it, erase it, restrict or object to our processing of it, and receive a portable copy. Where we rely on your consent, you can withdraw it at any time. You can also complain to your local data protection authority.

How to make a request

Email ryannovak07@gmail.com. We verify your identity before we act on a request, usually by confirming that you control the email address on the account. An authorized agent can make a request for you with your signed permission, and we may still confirm your identity with you directly.

We respond within 45 days under US state laws and within one month under the GDPR. If we need the extra time the law allows, we will tell you. If we decline your request, you can appeal by replying to our decision, and we will respond within the time your state's law requires.

Cookies

The Primo web app sets only essential cookies, which keep you signed in and protect your session. We do not use advertising cookies or third-party ad trackers on our website or apps. If you block cookies in your browser, you will not be able to sign in to the web app.

International transfers

Primo is based in the United States, and our subprocessors process data in the United States. If you use Primo from another country, we transfer your information to the United States and process it there. Where the GDPR or UK GDPR requires a transfer mechanism, we rely on the European Commission's Standard Contractual Clauses and the UK Addendum, as our DPA describes.

Children

Primo is not for children under 13, and we do not knowingly collect personal information from them. If we learn that we have, we delete it. Minors may use Primo only as a customer's employees where local labor law allows, and the customer is responsible for that. If you believe a child under 13 has given us personal information, email us.

Changes to this policy

We may update this policy. The date at the top shows the latest version. For material changes, we give customers at least 30 days' notice by email or in the app before the changes take effect.

Contact us

Send privacy questions, requests, and security reports to ryannovak07@gmail.com. Primo is based in Las Vegas, Nevada, USA.