I am afraid there is no simple answer to your question. However, as a general rule the cell lines, like the HEK293, are easier to transfect than the primary cells.
There is a number of hypothesis to explain the higher level of transfection in the cell lines. Most importantly is the cancerous nature of the cell lines make which makes them easier to accept foreign macro-molecules (DNA).
Furthermore, the higher transfection effeciency in HEK293, it is sometime attributed to the adherence of these cells to surface of the culturing flask which increases the chance of contact between the cells and the sedimented DNA at the bottom.
In addition to what I have said above, I think one of the causes of achieving high transfection effeciency with HEK293 is long experience of the researchers around the world with this cell line.
Furthermore, the development of high number of excellent transfection protocols and reagents by the different life science companies to be used for HEK293 transfection.