Privacy Policy

Last Updated: March 04, 2024

PE Primer, LLC (“PE Primer” we,” or “us“) recognizes the importance of data privacy, and this Privacy Policy sets forth the terms and conditions with respect to how we process personal information. This Privacy Policy describes, among other issues, the types of personal information that we collect, the purposes for which we use it, the types of third parties with whom we share it, and any rights and responsibilities you may have with respect to such personal information.

This Privacy Policy applies to the personal information you provide us when you (i) access and use our website: or (together, the “Website”), (ii) purchase or receive products or services through the Website, or (iii) otherwise contact or engage with us. For purposes of this Privacy Policy, the Website and all information and features provided for thereon shall be referred to collectively as the “Services.”


PE Primer is headquartered in the United States, and the personal information you provide to PE Primer may be processed and stored in the United States. For more information on our data transfer practices, please see Section 8 (Data Retention and Localization).

1.   Scope 

For purposes of this Privacy Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual or household and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual or household and that is not otherwise subject to a data protection law, statute, or regulation. PE Primer may anonymize or de-identify personal information, and such data is not subject to this Privacy Policy, and PE Primer may use such data for any purpose.

To the extent that PE Primer is providing learning management services as part of its contract with an organization, PE Primer will serve as a data “processor” and the organization will serve as the data “controller” and in such circumstances, PE Primer will collect and process any personal information derived from the organization’s employees in accordance with our Data Processing Addendum (and not this Privacy Policy). To the extent you are using our learning management services in an individual, personal capacity (i.e., you are not an employee, contractor, or agent of an organization to whom we have a contract to furnish services), then any and all of your personal information is collected and processed in accordance with this Privacy Policy (and not the Data Processing Addendum) and the term “Services” includes the learning management services we are furnishing to you.

2.   The Types and Categories of Personal Information We Collect 

PE Primer collects personal information in order to provide our Services, comply with our legal obligations, promote our business interests, and for the other reasons set forth in this Privacy Policy. When you do not provide personal information to PE Primer, we may not be able to provide you the Services or to complete a transaction you requested. Generally, we collect the following types and categories of personal information during our business operations:

Personal Information
Personal IdentifiersIdentifiers, such as your name, alias, address, email address, account name, and telephone number.
Registration DataInformation provided when you register for an account to use the Website, including usernames and passwords.
Online Identifiers (For more information, see “Technical Data” below)Persistent identifiers that can be used to recognize you or your device over time and across different services, including a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology.
Commercial InformationRecords of the Services you purchased, obtained, or considered, or your other purchasing or consuming histories or tendencies with respect to our Services.
LMS Usage InformationYour use of our online learning management services, including learning activity, bookmarks, notes, quiz results, and assessment results.
Business Contact DataInformation related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities.
Health and Disability DataYou may furnish us with health-related information, such as to accommodate a disability when you engage with us.
Marketing and Communications DataInformation with respect to your marketing preferences and your subscriptions to our publications and alerts.
Internet and Electronic Network DataData pertaining to your access or use of the Website, including browsing history, search history, and information regarding your interaction with the Website or advertisements embedded on the Website or other third-party websites, and information derived from any device that connects to our WiFi services.
Your FeedbackInformation you provide about our Services, which may include data gathered from any PE Primer surveys or reviews submitted by you. 
Visitor InformationInformation an individual provides when visiting any physical location or premises of PE Primer (e.g., visitor logs and registries, vehicle and parking information, security camera recordings) or when we visit a client location to provide training.
Video and ImagesIn some circumstances, you may provide us images (e.g., your use of a product) or we may record you via a video camera (e.g., on-premises security systems) or through video teleconferencing. 
Geolocation DataInformation about the general city, state, or region in which a user of the Website is located.
InferencesInferences drawn from some of the personal information categories identified herein and used to create a consumer profile reflecting your purchasing and marketing preferences, characteristics, and behavior.

Technical Data. When you access the Website, we collect certain data automatically using technical means and tools. This data relates to your device, as well as your experience on the Website and other websites, including the following:

Usage and Device Data. When you access and use the Website, we automatically collect details of your access to and use of the Website, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Website (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Website may collect “diagnostic” data related to your use of the Website, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.

Cookies and Tracking Data. We use “cookies” and other tracking technologies within the Website. A cookie is a small file placed on your device. It may be possible to refuse to accept cookies by activating the appropriate setting on your device. However, if you select this setting, some parts of the Website may become inaccessible or not function properly. In addition, the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of the Website (e.g., recording the popularity of certain content and verifying system and server integrity). The Website may collect data about the advertisements you have seen or engaged.

Website Monitoring. Please be aware that we, and our service providers and partners, use cookies and other tracking technologies within the Website to monitor and record any and all activities and communications to, from, and on, the Website in order to safeguard, improve, and analyze usage of, the Website, for marketing, and for the other purposes listed in this Privacy Policy. For the avoidance of doubt, you hereby acknowledge, agree, and consent to, such monitoring and recording by us and our service providers and partners.

Audio and Visual Materials. Our Website may, from time to time, display live or prerecorded videos or similar audio visual materials (“Videos”). We may collect personal information with respect to you requesting access to, and/or accessing, such Videos, and we may disclose such personal information to third parties, including to our third-party service providers through the use of cookies. By requesting access to, or accessing, such Videos, you hereby agree to our Video Information Disclosure Consent Form. The provision of Videos on our Website is not an admission by PE Primer and shall not otherwise be interpreted, in any form or manner, to mean that PE Primer is a “video tape service provider” for purposes of the Video Privacy Protection Act (codified as amended at 18 U.S. Code § 2710) (the “VPPA”) or PE Primer is otherwise subject to the VPPA.

PE Primer owns, licenses, and/or operates certain websites (each a “Site”) that may, from time to time, display live or prerecorded videos or similar audio visual materials (“Videos”). By requesting access to, or otherwise accessing, any such Video(s), you hereby acknowledge, agree, and consent to the following:

  • Collection. We shall, through the use of cookies and similar online tracking technologies, collect personal information with respect to you requesting access to, and/or accessing, Videos, and such personal information may include (i) identifiers that can be used to recognize you or the device you use to access our Site, over time and across different services, such as a device identifier, an IP address, mobile ad identifiers, and similar data, (ii) the Video(s) you accessed or to which you requested access, and the nature, scope, and duration of such access, and (iii) identifiers associated with your social media account, or similar online accounts.
  • Disclosure. We may, in our sole discretion, disclose personal information that we collect from you with respect to you requesting access to, and/or accessing, Videos to our partners, affiliates, and service providers, such as social media partners, to assist with the operability and functionality of our Site, to help us assess and improve our Site, products, and services, and to facilitate or assist with our marketing and advertising campaigns.
  • Withdrawal of Consent. You acknowledge and agree that you may prevent us from collecting and disclosing personal information from you with respect to you requesting access to, and/or accessing, Videos by changing your browser settings in accordance with the instructions set forth in our Privacy Policy. These options will prevent the deployment of cookies and similar online tracking technologies that are used to collect, process, and disclose your personal information in connection with the Videos you are requesting access to or otherwise accessing.

Non-Cookie Technologies. Our Website may deploy “Non-Cookie Technologies” to support our digital advertising programs. These technologies often include browser cache, locally stored objects, or the creation of a statistical identifier wherein an identifier, much like a cookie identifier, is calculated based on the characteristics of a browser or device that distinguishes it from other browsers or devices. These identifiers are calculated either from the data your browser or device shares automatically with the Website or with additional data specifically requested from your browser or device. For more information, see here

3.   Sources of Information

We collect the personal information identified herein directly from you when you use our Services, through automated means when you are using the Website, and from third parties, as follows:

First Party / Direct Collection. We collect personal information directly from you when you use our Services (e.g., registering accounts, completing purchases, signing up for subscriptions), when you provide a Product Review (as defined below), or whenever you directly engage with us, such as when you visit our offices or premises or otherwise contact us or we visit your office or premises (e.g., in-person training).

Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use the Website (see “Technical Data” above).

Third-Party Sources. We collect personal information from third parties, such as publicly available databases, social networking providers, advertising companies, our service providers, and third-party references.

4.   How We Use your Information / Purpose of Collection

We may use the personal information we collect about you in order to perform our Services, comply with our legal obligations, and promote our business interests.

How Your Personal Information Is Used
Provide, operate, maintain, improve, and promote our Services, including optimization of offerings presented to you.
Enable you to access and use our Services and fulfill your transactions.
Process and complete transactions, and send you related information, including purchase confirmations and invoices.
Provide learning management service activities (e.g., testing and survey results) to employers, accreditation bodies, and similar organizations and institutions. 
Send you messages and communications related to our Services (e.g., responses to your comments, questions, and requests, customer services).
Furnish technical notices, updates, security alerts, and support and administrative messages to you about our Services.
Provide you promotional and marketing communications (e.g., information about our Services, features, surveys, newsletters, offers, promotions, and events).
Research, monitor and analyze trends, usage, and activities in connection with our Services to promote our business interests.
Investigate and prevent fraudulent transactions, unauthorized access to or use of our Services, Website cybersecurity, and other illegal activities.
Personalize our Services, including providing features or advertisements that match your interests and preferences.
PE Primer may collect and use your personal information for any other purpose for which we obtain your consent.

5.   Sharing Information / Third-Party Disclosures

We share your personal information as described below and in this Privacy Policy, and as permitted by applicable law.

Category of RecipientPurpose of Disclosure
Intra-GroupWe may share your personal information with our parent company, and our affiliates, and subsidiaries.
Service ProvidersWe share personal information with third parties in connection with the delivery of our Services (e.g., credit card processing, customer service, business analytics, fraud prevention, legal compliance services, and advertising and marketing).
Employees; Accreditation BodiesWe provide learning management service activities (e.g., testing and survey results) to employers, accreditation bodies, and similar organizations and institutions.
Business PartnersWe may share your personal information with third parties that distribute our products and marketing materials.
Business RestructuringCircumstances may arise where, for strategic or other business reasons, we decide to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of our assets.
Legal; Compliance; Legitimate InterestsWe may disclose personal information (i) if required by law or government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, we may disclose your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests.
ConsentIn addition to the reasons for disclosure set forth herein, we may also disclose your personal information upon your consent.

In the event that you facilitate a transaction with PE Primer or request information from or otherwise engage with us, and such activities require PE Primer to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct PE Primer to intentionally disclose your personal information to the service provider or third party.

6.   Social Media/ Platform Data Rights

We may engage with you on various social media platforms (e.g., LinkedIn, Facebook, Twitter, Pinterest, Instagram). If you contact us on a social media platform for customer support or for other reasons, we may contact you via the social media’s direct message tools. Those communications to and from us are governed by this Privacy Policy. However, your use of a social media platform is also subject to the policies and terms of the relevant social media platform. Certain social media platforms may also automatically provide us with your personal information, the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Website includes social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on the Website. These features may collect your IP address and which Website page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Website. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.

According to the terms and conditions governing certain social media platforms, you may request that the information, data, or other content we obtain from or through the social media platform (“Platform Data”) be deleted or modified. If you would like Platform Data related to you deleted or modified, please contact us in accordance with the “Contact Us” section below and (i) identify the social media platform at issue and (ii) the Platform Data that you would like deleted and/or modified, and if modified, the modification to said Platform Data. We may also delete Platform Data if requested by the social media platform.

 7.   Links to Other Websites; Your Direct Third-Party Disclosures

As a resource to you, the Website may include links to third-party websites or provide you the opportunity to disclose information directly to third parties (e.g., credit card processors). Our Privacy Policy does not apply to such third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the Services. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.

 8.   Data Retention and Localization

The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information for as long as needed to provide you with our Services, to facilitate transactions you have requested, to comply with our legal obligations (e.g., tax filings), to engage in marketing activities, and for as long as is necessary to defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy.

PE Primer is based in the United States, and the personal information that we collect and process is retained and stored in the United States. PE Primer uses service providers that store personal information on our behalf in the United States and in other countries where you may not reside (each a “third country”). Please be aware that the United States, and these other third countries, may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. By continuing to provide us such information, you hereby acknowledge and agree that your personal information will be transferred to, and stored in, the United States and in such other third countries.

 9. Security 

We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE, AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE SITE AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION CAUSED BY A THIRD PARTY. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately (and in any event within twenty-four (24) hours) if you have reason to believe that your username or password to our Services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.

10.   No Data Collected from Children

The Website is not directed at, nor intended for use by, children. As a result, if you are under the age of eighteen (18), you are prohibited from accessing or using the Services (including the Website) or with providing us with your personal information.

11.   Publicly Posted Information; Product Reviews

You may, from time to time, have the ability to submit via the Website a comment on, provide an opinion about, rate, or otherwise discuss our Services (a “Product Review”). In other circumstances, you may directly provide us feedback on our business, our business sector, or the Services (“Feedback”). Any information or content you post in a Product Review or in your Feedback may be available to other users of the Website (and our social media platforms) and may be retrievable by third-party search engines, and third parties may also be able to download or share your Product Review and Feedback to social media websites or elsewhere. We recommend that you guard your privacy and anonymity and not upload any information in your Product Review and Feedback that you wish to remain confidential. Any third party with access to your information via the Website will be permitted to use the information in the same manner as if you submitted the information directly to that third party. Publicly posting any information on the Website is entirely voluntary on your part, and we recommend you carefully consider the information you choose to make publicly available. As between you and PE Primer, any and all Product Reviews and Feedback shall be considered our confidential and proprietary information. In order for PE Primer to utilize such Product Reviews and Feedback, you grant to PE Primer a non-exclusive, perpetual, irrevocable, worldwide, royalty-free license, with the right to sublicense, under all relevant intellectual property rights, to use, publish, and disclose such Product Reviews and Feedback in any manner we choose and to display, perform, copy, make, have made, use, sell, and otherwise dispose of PE Primer’s and our sub-licensees’ products or services embodying such Product Reviews and Feedback in any manner and via any media we choose, without reference to the source. PE Primer shall be entitled to use Product Reviews and Feedback for any purpose without restriction or remuneration of any kind with respect to you and/or your representatives.

12.   Your Responsibilities


13.   Updating Your Information

It is important that the personal information that you provide to us is accurate and reliable. In certain circumstances, you may have the ability to directly edit your account to update and change your personal information (e.g., name, telephone number, email, shipping address), and you must do so when such changes are warranted. You may review, update, or modify your personal information, including profile and contact information, at any time by logging into your account. You may request deletion of your personal information or Company account by emailing

14.  European Data Protection Rights

If you are located in the EU, Switzerland, or the UK, you have the following data protection rights and privileges:

  • Right to Know. You may have the right to know about what personal information PE Primer collects and processes about you, including the types and categories of personal information we collect and process, the sources of such personal information, our retention criteria, with whom we share your personal information, cross-border data transfers, and how to file complaints and inquiries.
  • Access Rights. You may have the right to ask us whether we process any of your personal information and, if so, receive access to such personal information. When complying with an access request, we will also provide you with additional information, such as the purposes of the processing, the categories of personal information concerned as well as any other information necessary for you to exercise the essence of this right.
  • Rectification. You may have the right to have your personal information corrected/rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate personal information about you and, taking into account the purposes of the processing, update any incomplete personal information, which may include the provision of a supplementary statement.
  • Erasure. You may have the right to have your personal information erased, which means the deletion of your personal information by us. However, your right to erasure is subject to statutory limits and prerequisites (e.g., where your personal information is no longer necessary in relation to the initial purposes for which it was processed, your personal information was processed unlawfully).
  • Restriction of Processing. You may have the right to obtain the restriction of the processing of your personal information, which means that we suspend the processing of your personal information for a certain period of time. Circumstances which may give rise to this right include situations where the accuracy of your personal information is contested, but we need time to verify the inaccuracy (if any) of your personal information.
  • Data Portability. You may have the right to request we provide you with your personal information in a structured, commonly used and machine-readable format and to have such data transmitted directly to another controller, where technically feasible.
  • Right to Object. You may have the right to object to the processing of your personal information, which means you may request we no longer process your personal information. This only applies in case the “legitimate interests” ground (including profiling) constitutes the legal basis for processing (see below “Legal Basis for Processing”). However, at any time (and free of charge) you can object to having your personal information processed for direct marketing purposes.
  • Automated Decision Making. You may have the right to object to having us use your personal information to conduct automated decision making. However, PE Primer does not engage in any activity that subjects our customers, website users, survey participants, or others to a decision based solely on automated processing, including profiling, which produces legal effects, or similarly significant results, impacting them.
  • Withdrawing Consent. You also may withdraw your consent at any time if we are solely relying on your consent for the processing of your personal information. However, this will not impact our legal basis to process such personal information prior to the withdrawal of your consent.

You have the right  to submit a complaint to a data protection authority responsible for overseeing our compliance with data protection law in your jurisdiction. Please see a list of potentially applicable regulatory authorities:

We would, however, appreciate the opportunity to address your concerns, so please feel free to contact us regarding any complaint you may have. We will not discriminate against individuals for exercising their data privacy rights or filing a privacy complaint. 

We will facilitate your exercise of the rights that apply to you in accordance with applicable law.  If you have questions about your rights or wish to exercise your rights, you can contact us at, or otherwise in accordance with the “Contact Us” section listed below.

15. Legal Basis for Processing (EEA/UK/Switzerland Only)

For purposes of the EU/UK GDPR, we can collect and process your data under one of the following legal bases:

  • Consent. We can collect and process your data with your consent. For example, if you have given your consent to receiving marketing material from us at the point we collected your information.
  • Contractual Obligations. We need your personal information to comply with our contractual obligations. For example, if you have subscribed to one of our services, we use your personal information to fulfill and deliver that service to you.
  • Legal Compliance. If the law requires us to, we may need to collect and process your data.
  • Legitimate Interest. We may use your data as required in the normal course of operating our businesses and services unless our legitimate interests are overridden by your rights.
  • Vital Interests. We may need to process your personal information if the processing is necessary to protect your vital interests (for example, health and safety reasons if you attend a meeting at a PE Primer location).

16. California Privacy Rights

Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of personal information, as defined under Shine the Light, such as name, email address, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. However, PE Primer does not disclose personal data to third parties for their direct marketing purposes. Separately, PE Primer is not a “business” within the meaning of the California Consumer Privacy Act of 2018, as amended.

17. Marketing Opt-Out

You have the right to opt out of receiving email marketing communications from us. You can object to further marketing at any time by selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you. If you are paying for one of our services, please note that clicking the “unsubscribe” link will not cancel your paid subscriptions, but it is likely to affect deliverability of your newsletter messages, announcements, or other product related communications. If you purchase products or services from us, or if you register for an account with us, we may contact you to confirm your purchase, subscription, or registration, or to provide you with information about its terms or features. You may wish to keep these transactional or relationship emails, to help you use our products and services.

18.  Do-Not-Track Signals 

Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.

19.   Persons with Disabilities

PE Primer strives to ensure that every person has access to information related to our Services, including this Privacy Policy. Please contact us if you would like this Privacy Policy provided in an alternative format, and we will seek to meet your needs.

20.   Changes to the Policy

We reserve the right to amend this Privacy Policy at any time. We will notify you if this Privacy Policy is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto. Your use of the Services, and continued use of the Services after any amendments are made to this Privacy Policy, signifies your consent to this Privacy Policy and any amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Privacy Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto.

21.   Contact Us

If you have questions regarding this Privacy Policy, or would like to request more information from us, please contact us by mail at: PE Primer, LLC, Attn: Legal Department, 1317 Edgewater Dr, #2407, Orlando, FL 32804; or, use our interactive webform at:, or email us at