Privacy Policy

1. Introduction

The Institute for Primary Facts ("The Institute," "we," "us," or "our") respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you.

This policy applies to visitors from all countries, including those in the European Union (subject to GDPR), the United Kingdom (UK GDPR), California (CCPA/CPRA), and other jurisdictions with data protection laws.

2. Data Controller

The Institute for Primary Facts is the data controller responsible for your personal data. For questions about this policy or your data rights, contact us at:

3. Data We Collect

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier.
• Contact Data includes email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website and services.

4. Cookies and Analytics

Our website uses cookies and similar tracking technologies. We categorize these as:

4.1 Necessary Cookies

These cookies are essential for the website to function properly. They enable basic features like page navigation and access to secure areas. The website cannot function properly without these cookies, and they cannot be disabled.

4.2 Analytics Cookies

We use Google Analytics 4 (GA4) to understand how visitors interact with our website. These cookies collect information including:

• Pages visited and time spent on each page
• How you arrived at our website
• Device and browser information
• Geographic location (country/city level)

Important: Analytics cookies are only placed on your device after you provide explicit consent through our cookie banner. We have configured Google Analytics with the following privacy protections:

• IP addresses are anonymized
• Data retention is set to the minimum period (2 months)
• Data sharing with Google for advertising purposes is disabled
• We do not use remarketing or advertising features

4.3 Your Cookie Choices

When you first visit our website, you will see a cookie consent banner that allows you to:

• Accept All: Enable all cookies including analytics
• Reject Analytics: Only allow necessary cookies
• Preferences: Customize your cookie settings

Withdraw or Change Consent: You can change your cookie preferences at any time by clicking the "Cookie Settings" link in the footer of any page. This allows you to enable or disable analytics cookies whenever you choose. If you disable analytics, existing Google Analytics cookies will be removed from your device.

5. How We Use Your Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To respond to your inquiries and provide you with requested information.
• To send you newsletters or announcements (only if you have opted in via our double opt-in process).
• To improve our website and services based on aggregated analytics data.
• To comply with legal obligations.

6. Legal Basis for Processing (GDPR)

For visitors from the European Union and United Kingdom, we process your data under the following legal bases:

• Consent: For analytics cookies and newsletter subscriptions.
• Legitimate Interest: For improving our website and services, and for responding to contact form inquiries.
• Legal Obligation: To comply with applicable laws and regulations.

7. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

• Right of Access: Request a copy of your personal data.
• Right to Rectification: Request correction of inaccurate data.
• Right to Erasure: Request deletion of your personal data.
• Right to Restrict Processing: Request limitation on how we use your data.
• Right to Data Portability: Request transfer of your data in a machine-readable format.
• Right to Object: Object to processing based on legitimate interests.
• Right to Withdraw Consent: Withdraw consent at any time for consent-based processing.

To exercise any of these rights, please contact us at legal@primary-facts.org.

8. International Data Transfers

We are based in the United States. If you access our website from outside the US, your data may be transferred to, stored, and processed in the United States. By using our website and providing consent for analytics, you agree to this transfer.

For EU visitors: Google Analytics data is processed by Google LLC. Google has implemented appropriate safeguards for international data transfers, including Standard Contractual Clauses.

9. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

10. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for:

• Contact form submissions: 2 years
• Newsletter subscriptions: Until you unsubscribe
• Analytics data: 2 months (Google Analytics setting)

11. Children's Privacy

Our website is not intended for children under 13 years of age. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without parental consent, we will take steps to delete that information.

12. Changes to This Policy

We may update this privacy policy from time to time. We will notify you of any significant changes by updating the "Last Updated" date at the top of this page. We encourage you to review this policy periodically.

13. Contact Us

If you have any questions about this privacy policy or our privacy practices, please contact us at:

14. Complaints

If you are in the European Union and believe we have not adequately addressed your concerns, you have the right to lodge a complaint with your local Data Protection Authority.