PRIVACY POLICY – Primo Management Group LLC

Primo Management Group LLC, and/or affiliates, successors, or assigns [hereinafter “PMG”]) provide certain services (herein “Service or Services”) including: assists timeshare owners in terminating their timeshare relationship, provides insurance products from insurance companies across the country to consumers, provides mortgage and financial services, and provides credit repair services for the purpose of the removal of errors, misrepresentations, or unverifiable information that a client claims to have appeared on their credit report. Respect for the privacy of personal information is very important to PMG.PMG is committed to collecting, maintaining, and securing personal information about you in compliance with State and Federal law. This policy applies to personal information collected by PMG via its website, email, chat, or other online tools. This policy does not apply to any website links operated by third parties with whom PMG has no affiliation or control.

What is “personal information”?

Personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include content a customer or other person uploads to any PMG blog or forum for viewing by the public, such as customer testimonials or online discussions. Personal information does not include publicly available information or aggregate consumer information from which individual identities have been removed.

How does PMG collect personal information online?

PMG collects personal information through its online services, including its contact forms on PMG’s website, through forms that appear when a customer clicks on a PMG advertising banner on a third- party website, by chat, and by email. At this time, there are three primary types of information that PMG collects through online services:

Information from you: PMG collects personal information and other data that you voluntarily enter in to forms or data fields on online services. This includes identity and contact information such as your name, address, email address, telephone number, date of birth, gender, job title, profession, financial information, preferences and interests, and other related information that PMG deems appropriate to further the purposes of its online services.

We may also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal information as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. If we combine or connect aggregated data with your personal data so it can directly or indirectly identify you, we treat the combined data as personal data used under this privacy policy.We collect no special categories of personal data about you. This includes your race or ethnicity, religious beliefs, sexual orientation, or information about your health. We collect no information about criminal convictions and offenses.

Information from others: PMG may collect personal information from public or third-party information sources. For example, if users use a credit card on our website, PMG or its agent verifies the validity of the credit card information with financial or credit organizations. Sometimes, we may augment our existing user databases with information from third parties. Some of this information may be personal information, such as change of postal address information.
Information collected from your computer or electronic device: We may collect information about your computer or other electronic device when you use our online services. This information may include your IP address, domain name, browser type, and date and time of your request. If you use a mobile device to access our online services, we also may collect information about your device, such as your device ID and device type, and usage information about your device and your use of our online services.

Cookies

We use “cookies” on this site. A cookie is a piece of data stored on a site visitor’s hard drive to help us improve access to our site, track usage of our site, and identify repeat visitors to our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Cookies are sent to your browser from the website that you visit and are stored on your computer’s hard drive. Usage of a cookie is not linked to any personally identifiable information on our site. You may control or reset your cookies through your web browser.

Why does PMG collect, use, and disclose personal information?

PMG collects personal information online as necessary to enable individuals to contact PMG, learn about PMG and learn more about the timeshare cancellation industry, mortgage industry, insurance industry, credit repair industry, and view testimonials and/or calculate financial information. PMG uses personal information to provide products, services, or features that individuals have requested, or to communicate with individuals. PMG may share personal information with third parties who provide services to us in our normal course of business including payment processors, customer service, timeshare services, insurance services, credit repair or debt relief services, and statistical analysis. However, PMG will not sell, rent, or otherwise distribute your personal information to third parties for purposes not related to our services or otherwise permitted by this policy.A general description of the collection and basis for use of your information is summarized below:

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate intertest
To register you as a new customer	(a) Identity(b) Contact information	Performance of a contract with you
To process and deliver payments for services including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us	(a) Identity(b) Contact information(c) Financial information(d) Transaction needs(e) Marketing and Communications	(a) Performance of a contract with you(b) Necessary for our legitimate interests
To manage our relationship with you which includes:(a) Notifying you about changes to our terms or privacy policy(b) Asking you to leave a review or take a survey	(a) Identity(b) Contact(c) Profile(d) Marketing and Communications	(a) Performance of a contract with you(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products or services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity(b) Contact(c) Technical	(a) Necessary for our legitimate interests (for running our business, providing administration and IT services, network security, to prevent fraud, and for business reorganization or restructuring)(b) Necessary to comply with a legal obligation
To deliver website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) Technical	Necessary for our legitimate interests (to study how customers use our products or services, to develop them, to grow our business, and to improve our marketing strategy)
To use data analytics to improve our website, products or services, marketing, customer relationships and experiences	(a) Technical(b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may interest you	(a) Identity(b) Contact(c) Technical(d) Usage(e) Profile(f) Marketing and Communications	Necessary for our legitimate interests (to develop our products or services and grow our business)

Do I have choices about how PMG collects, uses, and discloses personal information about me?

If you do not want PMG to collect personal information from you, use no PMG online services and do not submit personal information to PMG.

Who will have access to personal information about me?

Personal information about you will be accessible to PMG, including its parent companies, subsidiaries, successors, affiliates, or assigns, and to others that use personal information solely for and at the direction of PMG.

Sharing personal information

PMG does not sell or share personal information about you except as described in this policy. However, PMG may reorganize or divest its business through sale, merger, or acquisition, or through bankruptcy. If so, personal information is an asset of PMG and may be shared with actual or prospective purchasers, or others deemed necessary to receive the personal information for a purpose stated in this section. PMG will use its best efforts to obtain written assurances that personal information will be protected if disclosed under this section. PMG reserves the right to retain and disclose personal information about you for reporting to government authorities or in legal proceedings as authorized or required by law. Except as provided in this policy, personal information about you will not otherwise be shared without your permission.

Securing personal information

PMG will take reasonable steps to protect personal information as it is collected and transmitted between your device and our online services and servers, and to protect personal information in its possession from unauthorized access, disclosure, alteration, or destruction.

May I correct personal information about me?

To access personal information about you collected online, to keep it accurate, or to request deletion, you may contact us at the phone number, email and/or address below. Sometimes, we may not be able to delete certain personal information about you. Where permitted by law, your ability to access and correct personal information will be limited where access and correction would inhibit PMG’s ability to comply with a legal or ethical obligation; inhibit PMG’s ability to investigate, make, or defend legal claims; result in disclosure of personal information about a third party; or result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to PMG or a third party.

How long does PMG retain personal information?

We retain personal information for as long as needed for the business purposes for which it was collected. Sometimes, we may have to retain information longer based on laws or regulations that apply to our business. Where possible, we try to remove unnecessary identifiers from records we may need to keep for periods beyond our normal retention period.

Third-Party Links

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Promotional Communications

We may use your personal information to send you updates (by email, text message, telephone, or mail) about our services, including exclusive offers, promotions, or new services.We have a legitimate interest in processing your personal information for promotional purposes (see above “How does PMG collect personal information online?” and “Why does PMG collect, use, and disclose personal information?”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.We will always treat your personal information with the utmost respect and never sell or share it with other organizations for marketing purposes or for purposes not described in this policy.You have the right to opt out of receiving promotional communications at any time by:Contacting us consultation@pmanagementgroup.com ; orUsing the “unsubscribe” link in emails or “STOP” number in texts.We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, altered, or accessed in an unauthorized way. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties with a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you of a breach where we are legally required to do so.

FOR CALIFORNIA USERS – CCPA

This section describes the personal information under the California Consumer Privacy Act of 2018 [“CCPA”] we collected about California residents in the last 12 months, the sources of that information, our business or commercial purposes for collecting the information, and the third parties with whom we shared that information.

How does PMG collect personal information online?

The sections above describe the categories of personal information we collect and the sources from which the information was collected.

Does PMG collect, use, and disclose personal information?

The sections above describe when PMG collects personal information and the purposes for which we use collected personal information.

Sharing Personal Information.

The sections above describe how PMG may share your information.Your Rights and How to Exercise Them California residents have certain rights under the CCPA. Those rights may only apply in certain circumstances and may be limited. A summary of those rights is provided below as well as information on how to exercise your rights. We may contact you to verify your identity if you exercise any rights under this section.a. Right to Know.You have the right to know what personal information we collect, use, or disclose about you. To exercise this right, please email us at consultation@pmanagementgroup.com or send a written request with your name, email, address, and California postal address to PMG at the address listed below. We may contact you to verify your identity when you exercise your right to know under this section.b. Right to Opt-Out of Sale:We do not sell your personal information to third parties in exchange for money or other consideration. However, the CCPA broadly defines the concept of “selling” information, so we offer the opportunity for California residents to opt out of selling information to third parties. Please email us at consultation@pmanagementgroup.com or send a written request with your name, email, address, and California postal address to our address below to opt out of having your information sold to third parties. If you are located in California, you can choose to opt-out of cookie tracking by clicking Cookie Settings.

Right to Edit or Delete: You have the right to request that we edit or delete the personal information we collect or maintain about you. Please email us at consultation@pmanagementgroup.comor send a written request with your name, email, address, and California postal address to our address below to request we edit delete your information. Please note that certain exceptions may apply to your right to have information edited or deleted, including when we must retain your information to comply with legal obligations. We may contact you to verify your identity when you request that we edit or delete your personal information.
Right to Non-Discrimination: We will not discriminate against you if you exercise any of your rights under the CCPA. However, we may offer financial incentives for the collection of personal information, the sale of personal information, or the deletion of personal information. You may exercise these rights yourself or you may designate an authorized agent to make a request on your behalf. Your authorized agent must be able to demonstrate authority to act on your behalf when submitting a request on your behalf.

FOR NEVADA USERS This notice is provided under Nevada state law. You may be placed on our PMG Internal Do Not Call List by contacting us at PMG’s address, email, and/or phone number below. Nevada Law requires that you are provided with the following contact information:Bureau of Consumer Protection Office of the Nevada Attorney General 555 E. Washington Street, Suite 3900 Las Vegas, NV 89101 Phone (702) 486-3132 Email: aginfo@ag.nv.govFOR EU USERS – GDPR This privacy policy is used to inform website visitors regarding our policies with the collection, use, and disclosure of Personal Information.If you choose to use our Services (as is defined in the first paragraph of this Privacy Policy), then you agree to the collection and use of information in relation with this policy. The Personal Information that we collect are used for providing and improving the Services. We will not use or share your information with anyone except as described in this Privacy Policy.Information Collection and Use For a better experience while using our Services, we may require you to provide us with certain personally identifiable information, including but not limited to your name, phone number, and postal address. The information that we collect will be used to contact or identify you.Depending upon your use of our site, we may collect some or all of the following data:first and last name;contact information such as email addresses and phone numbers;address information such as country, street address, town/city, state/region, zip or postal code;date of birth, age and gender;job title, profession and company name;other demographic information such as preferences and interests;financial information;IP address (automatically collected);geographic location (automatically collected);web browser type and version (automatically collected);operating system (automatically collected);devices used (automatically collected);access times (automatically collected);a list of URLs starting with a referring site, your activity on our site, and the site you exit to (automatically collected);marketing campaign and traffic source data (automatically collected);other anonymous, automatically collected, non-personally identifiable data.Log Data We want to inform you that whenever you visit our Services, we collect information that your browser sends to us that is called Log Data. This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser version, pages of our website that you visit, the time and date of your visit, the time spent on those pages, and other statistics.Cookies Cookies are files with small amount of data that is commonly used an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your computer’s hard drive. Learn more about how we use cookies at https://wesleyfinancialgroup.com/cookie-declaration/.Our website uses these “cookies” to collect information and to improve our Services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your computer. If you choose to refuse our cookies, you may not be able to use some portions of our Services.Service Providers We may employ third-party companies and individuals due to the following reasons:To facilitate our Services; To perform service-related services; or To assist us in analyzing how our Services are used.

We want to inform our Service users that these third parties have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

As an EU user, you have certain rights:

Right to Know.

You have the right to know what personal information we collect, use, or disclose about you. To exercise this right, Please email us at consultation@pmanagementgroup.com or send a written request with your name, email, address, and EU postal address to PMG at the address listed below. We may contact you to verify your identity when you exercise your right to know under this section.

Right to Opt-Out of Sale:

We do not sell your personal information to third parties in exchange for money or other consideration. However, the EU broadly defines the concept of “selling” information, so we offer the opportunity for EU residents to opt out of selling information to third parties. Please email us at consultation@pmanagementgroup.comor send a written request with your name, email, address, and EU postal address to our address below to opt out of having your information sold to third parties.

Right to Edit or Delete:

You have the right to request that we edit or delete the personal information we collect or maintain about you. Please email us at consultation@pmanagementgroup.comor send a written request with your name, email, address, and EU postal address to our address below to request we edit delete your information. Please note that certain exceptions may apply to your right to have information edited or deleted, including when we must retain your information to comply with legal obligations. We may contact you to verify your identity when you request that we edit or delete your personal information.

Security

We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

Links to Other Sites Our Services may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Children’s Privacy

Our Services do not address anyone under the age of 13. We do not knowingly collect personal identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

What is PMG’s contact address for privacy questions? If you have questions about this policy or PMG’s information collection, you may contact the data controller and owner of the website in these ways:

Email us at consultation@pmanagementgroup.com

Policy updates

PMG reserves the right to modify this privacy statement at its discretion, without notice. If we change this policy, we will post changes on this site so you always will know what information we gather, how we might use that information, and whether we will disclose it to anyone. We may also email any significant modifications. These changes are effective immediately, after they are posted on this page. You can always see when we last updated the privacy policy by referring the below date.

This policy was last updated in March 2023.