Privacy Policy

Last updated: April 21, 2026

1. Who We Are

PrimeSets is the commercial brand of Cogni6 Inc. ("PrimeSets", "we", "us", or "our"), a corporation incorporated under the laws of Quebec, Canada. Our website is located at primesets-app.com.

For questions about this Privacy Policy or your personal data, contact us at: hello@primesets-app.com

2. Scope of This Policy

This Privacy Policy applies to information we collect through our website (primesets-app.com), email communications, and related marketing services. It does not cover the PrimeSets mobile application, which will have its own privacy documentation at launch.

3. Information We Collect

3.1 Information You Provide Directly

Email address (when subscribing to our newsletter or contacting us)
First name (optional, when subscribing)
Language preference (English or French)
Messages sent via our contact form

3.2 Information Collected Automatically

IP address (anonymized)
Browser type and version
Operating system
Pages visited, session duration, navigation path
Referring URL
Device type (desktop, mobile, tablet)
General geographic location (country, region)

4. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA) and United Kingdom, we process your personal data under the following legal bases:

Consent — Newsletter subscriptions and marketing communications.
Legitimate interests — Anonymized website analytics to improve our service (Google Analytics with IP anonymization).
Contract performance — Processing your data when you use our services.

5. How We Use Your Information

We use your information to:

Send newsletters and updates about PrimeSets (with your explicit consent)
Respond to your inquiries
Analyze website usage to improve our content and user experience
Comply with legal obligations
Enforce our Terms of Use

We do not sell your personal information to third parties. We do not use your data for automated decision-making or profiling that produces legal or similarly significant effects.

6. Third-Party Service Providers

We share limited data with trusted service providers who help operate our website:

Google Analytics (Google LLC)

We use Google Analytics 4 to understand how visitors use our website. Google Analytics collects anonymized usage data: pages visited, session duration, device type, and approximate location (country/region). We have enabled IP anonymization. Data is aggregated and does not personally identify you.

Privacy Policy: policies.google.com/privacy
Opt-out add-on: tools.google.com/dlpage/gaoptout

Mailchimp (Intuit Inc.)

We use Mailchimp to manage email subscriptions and send newsletters. When you subscribe, your email address and preferences are transmitted to Mailchimp. Mailchimp processes data in the United States under GDPR-compliant Standard Contractual Clauses (SCCs).

Privacy Policy: mailchimp.com/legal/privacy
Unsubscribe: use the link in any email you receive.

Sentry (Functional Software, Inc.)

We use Sentry for error monitoring and performance tracking of our server infrastructure (backend and mobile application). When you interact with our website (for example, when subscribing to our newsletter), our servers process your request. If a technical error occurs, Sentry may capture debugging data: error details, IP address, HTTP headers, and request body. This processing is based on our legitimate interest in ensuring service stability and security.

Vercel Analytics

Our website is hosted on Vercel. Vercel Analytics collects aggregated and anonymized performance metrics (Core Web Vitals: load time, interactivity, visual stability) via its Edge Network. This data does not personally identify you and no cookies are placed for this purpose.

Vercel Privacy Policy: vercel.com/legal/privacy-policy

Social Media Links

Our website contains links to social media platforms (Facebook, Instagram, X/Twitter, LinkedIn, Substack). These are plain hyperlinks — we do not embed any social pixel or share button on our website. When you click a link to one of these platforms, your browser connects directly to their servers, and those platforms may collect data according to their own privacy policies.

Facebook/Meta: facebook.com/policy
Instagram: privacycenter.instagram.com
X (Twitter): twitter.com/privacy
LinkedIn: linkedin.com/legal/privacy-policy
Substack: substack.com/privacy

We do not share your data with any other third parties except as expressly required by law.

7. Data Retention

Newsletter subscribers — Until you unsubscribe, then deleted within 30 days.
Contact form inquiries — 2 years from the date of last contact.
Analytics data — Aggregate anonymized data; individual sessions expire per Google Analytics settings (maximum 14 months).

8. International Data Transfers

Our service providers (Google, Mailchimp) may process data outside Canada, including in the United States. Where required, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs). Canada is recognized by the European Union as providing an adequate level of protection under GDPR.

9. Your Rights

Under PIPEDA — Canada

Access to your personal information
Correction of inaccurate data
Withdrawal of consent
Deletion of your data (subject to legal retention requirements)

Under Quebec Law 25

Quebec residents have additional rights under the Act respecting the protection of personal information in the private sector (Law 25):

Data portability — receive your data in a structured, commonly-used format
De-indexation — request removal of publicly disseminated personal information
Right to be informed of any automated decision-making affecting you

Under GDPR — EU/EEA Residents

Right of access (Art. 15)
Right to rectification (Art. 16)
Right to erasure / "right to be forgotten" (Art. 17)
Right to restriction of processing (Art. 18)
Right to data portability (Art. 20)
Right to object (Art. 21)
Right to withdraw consent at any time
Right to lodge a complaint with a supervisory authority

Under CCPA/CPRA — California Residents

Know what personal information is collected about you
Know whether personal information is sold (we do not sell your data)
Opt-out of the sale or sharing of your personal information
Request deletion of your personal information
Non-discrimination for exercising your rights

To exercise any of these rights, contact us at hello@primesets-app.com. We will respond within 30 days of receiving your request, or within the timeframe required by applicable law.

10. Cookies

We use cookies and similar tracking technologies on our website. For detailed information about the cookies we use and how to manage them, see our Cookie Policy.

11. Children's Privacy

Our website and services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from minors. If we learn we have collected such information without parental consent, we will delete it promptly.

12. Security

We take reasonable technical and organizational measures to protect your personal information, including HTTPS encryption for all data in transit and access controls for processors. No method of internet transmission is 100% secure. In the event of a data breach posing a real risk of significant harm, we will notify affected individuals and relevant authorities as required by law.

13. Changes to This Policy

We may update this Privacy Policy from time to time. For material changes, we will update the last updated date and, where required by law, notify you by email or prominent notice on our website. Your continued use of our services after such changes constitutes acceptance of the updated policy.

14. Contact

Privacy Officer
Cogni6 Inc. (PrimeSets)
hello@primesets-app.com