PRIVACY POLICY FOR PRIMAL PET GROUP

Effective April 28, 2025

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your personal data and information (“Personal Data”) when you use our products and services (collectively, the “Services”) and tells you about your privacy rights and how the law protects You. We use your Personal Data to provide and improve the Services. By using the Services, you agree to the collection and use of Personal Data in accordance with this Privacy Policy. 

SECTION 1 -- SCOPE OF THIS POLICY

This Privacy Policy governs Primal Pet Group, Inc. and its affiliates’ respective collection (and/or processing), use and disclosure of personal information from each’s website and other identified sources.  To the extent required by applicable law, this Privacy Policy is also intended to serve as a Notice of Collection of Personal Information.  Also, to the extent required by applicable law, this Privacy Policy applies to both consumers and businesses (and their employees).

Primal Pet Group, Inc. is a Delaware corporation, www.primalpetgroup.com.  Primal Pet Group, Inc.’s affiliates include Primal Pet Foods, Inc., which is a California corporation, www.primalpetfoods.com (also including its Primal Pets, www.primalpets.com, brand), Prairie Dog Pet Products, LLC, a Delaware limited liability company, www.prairiedogpetproducts.com, and Himalayan Dog Chew, LLC, a Delaware limited liability company, www.himalayan.com (also including its Ecokind Pet Treats, www.ecokindpettreats.com, Yellow Yak, www.yellowyak.com and Chewmeter, www.chewmeter.com, brands).  In this Privacy Policy, each of Primal Pet Group, Inc. and its affiliates are referred to as “Primal” or a “Primal affiliate,” as may be applicable in the context. The terms “we”, “us” or “our” refers also to Primal or a Primal affiliate (whether capitalized or in lower case).

Please note that each Primal affiliate is a separate company and a separate legal entity from each and all the companies that are other Primal affiliates.  When you access or use a Primal affiliate’s website or otherwise transact business with a Primal affiliate, you are transacting business with that specific company, not with any other Primal affiliate.  No Primal affiliate is responsible or liable for any other Primal affiliate.

Further, the laws that may govern transactions with one Primal affiliate, including privacy laws, may or may not be the same laws that would govern transactions with another Primal affiliate.  The laws that may govern a specific transaction may also provide fewer rights or less protection than might otherwise be provided by this Privacy Policy.  In such a case, your rights will be limited to those granted by law even if this Privacy Policy might appear to provide greater rights.  Further, not all Primal affiliates may be legally required to comply with a given states or federal privacy law notwithstanding anything in this Privacy Policy.  Each Primal affiliate’s respective commercial Terms & Conditions are also expressly incorporated into this Privacy Policy and you are agreeing to them.  Please read them.  For the avoidance of doubt, nothing in this Privacy Policy (or in any incorporated commercial Terms & Conditions) is intended to nor shall serve to, whether expressly or by implication, disclaim, release or otherwise abridge privacy rights or related remedies which cannot under any circumstances be disclaimed, released or abridged as a matter of the applicable law.

DEFINITIONS

For the purposes of this Privacy Policy:

"Account" means a unique account created for You to access our Service or parts of our Service.

"Business", for the purpose of the CCPA and GDPR, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California or in the European Economic Area or the United Kingdom.

“CCPA” means the California Consumer Privacy Act; California Civil Code § 1798.125.

"Company" (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to PRIMAL PET FOODS, INC.

"Country" refers to the Unted States of America

"Consumer", for the purpose of the CCPA means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

"Cookies" are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

"Data Controller", for the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

“Data Processor”, for the purposes of the GDPR, refers to a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller. 

"Device" means any device that can access the Services such as a computer, a cell phone or a digital tablet.

“GDPR” means the European Union’s General Data Protection Regulation (EU) 2016/679; found at https://gdpr-info.eu/. 

"Do Not Track" (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

"Personal Data" is any information that relates to an identified or identifiable natural person (also a “Data Subject” under GDPR). For the purposes of the CCPA, and the GDPR, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You, a natural person.

"Sale", for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's Personal Data to another business or a third party for monetary or other valuable consideration.

"Services" refers to the products and services made available through the Website.

"Service Provider" means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Services, to provide the Services on behalf of the Company, to perform services related to the Services or to assist the Company in analyzing how the Services are used. For the purpose of the GDPR, Service Providers are considered Data Processors.

“Standard Contractual Clauses (SCCs)”, for the purpose of GDPR, means data protection clauses issued by the European Commission to ensure that personal data transferred outside the European Economic Area (EEA) remains protected under the GDPR.

"Usage Data" refers to data collected automatically, either generated by the use of the Service or from the Services infrastructure itself (for example, the duration of a page visit).

"Website" refers to Primal Pet Food's Direct to Consumer website, accessible from https://primalpetfoods.com/ 

"You" and “Your” (appearing in upper or lower case) means the individual accessing or using the Services, or the company, or other legal entity on behalf of which such individual is accessing or using the Services, as applicable. 

SECTION 2 -- PERSONAL INFORMATION) COLLECTED AND UTILIZED

When you have contact with a Primal affiliate regarding a purchase, services, information, or otherwise, whether by using a website, an app (if any), by email, text or other electronic means, in writing, by phone or in person, or otherwise, that Primal affiliate or a third-party (including Service Providers or contractors) may collect (and/or process) your Personal Data.  By way of example only, Primal affiliates may use separate online store services providers which may themselves collect (and/or process) and use your Personal Data purchase transaction for Primal products or services on a Primal website.  Personal Data may be collected (and/or processed) across all electronic and non-electronic devices and platforms.  Additionally, when you communicate with certain third-parties (including service providers or contractors) such as a Primal affiliate’s online store provider or loyalty program operator, retailers, or social media networks, those third-parties may also collect (and/or process) your Personal Data.  In turn, a Primal affiliate may then access your Personal Data, from that third-party.

Types of Data Collected

Personal Data

While using our Services, We may ask you to provide us with Personal Data that can be used to contact or identify you. Personal Data may include, but is not limited to:

  • Email address

  • First name and last name

  • Phone number

  • Address, State, Province, City, ZIP/Postal code

  • Social Security or Employee ID number

  • Photograph

  • Biometric data

  • Usage Data

Usage Data

Usage Data is collected automatically when using the Services.

Usage Data may include information such as our Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that You visit, the time and date of Your visit.

IDENTIFIERS, CONTACT, COMMERCIAL AND FINANCIAL INFORMATION:  Such information may include signature, physical characteristics or description, credit or debit card information, bank or payment account and other financial information, account security information, social media data, and the like.  Regarding businesses, a Primal affiliate may also collect (and/or process) business-related information such as contractual information, business financial information, business operations, product and service, inventory and planning information, employee and other representative information, and the like.

ADDITIONAL PERSONAL INFORMATION:  Such information may include photographs and video of and anecdotal and inferential information about you and your pet(s), including personal and demographic information which may reflect your sex, race, ethnicity, personal preferences, behavior and philosophical information, pet diet information and preferences, product use information, and the like.

ADDITIONAL DEVICE AND TECHNICAL INFORMATION:  Such information may include the history and manner of your use of Primal affiliate and third-party (including service providers’ or contractors’) websites, data regarding your interactions with a Primal affiliate or a third-party (including service providers or contractors), emails, texts, geolocation data, and the like.

PUBLIC SOURCE INFORMATION:  Such information may include that which is
available from public sources, including governmental sources, commercial financial and other information sources, credit assessment services, internet service providers, data analytics providers, advertising networks, social media networks, data brokers, and the like.

OTHER INFORMATION YOU PROVIDE A PRIMAL AFFILIATE IN PERSON, BY EMAIL, TEXTS, WRITTEN OR TELEPHONIC COMMUNICATIONS:  Such information may include any that you provide voluntarily to a Primal affiliate or a third-party (including service providers or contractors).

SECTION 3 -- USE OF YOUR PERSONAL DATA 

A Primal affiliate’s purpose in collecting (and/or processing) your Personal Data, is to use it to accomplish your purchase, service, informational, posting, business, and other transactions, if any, including any products and services provided or purchased, deliveries, returns, credits or refunds, and where necessary to legally enforce Primal’s related rights.  

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Services, including to monitor the usage of our Services.

  • To manage Your Account: to manage Your registration as a user of the Services. The Personal Data You provide can give You access to different functionalities of the Services that are available to You as a registered user.

  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Services.

  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

  • To manage Your requests: To attend and manage Your requests to Us.

  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

A Primal affiliate may also use your Personal Data, for things, if any, like product and warranty administration, advertising and marketing to you (including email, text and internet advertising and marketing and targeted and re-targeted advertising and marketing), potentially across services, platforms and media, to administer loyalty program(s), for security purposes, for business operations (like fulfillment, accounting, inventory, product improvement, research, account management, and similar purposes) and analytics (like to determine and tabulate what is selling, to whom, where, and related business information), and for website analytics (like to assess website use and to improve website performance and experience and correct errors).  A Primal affiliate retains your personal information for so long as may be required to accomplish such purposes and/or as may be required or allowed by law.  Retention may depend on such things as the purpose of the collection (and/or processing), the nature and sensitivity of the personal information, the risk to the consumer if the information is lost or misused, and your consent, without limitation.

SECTION 4 -- DISCLOSURE OF YOUR PERSONAL INFORMATION 

In utilizing your Personal Data, as described above, a Primal affiliate may disclose it to third-parties (including service providers and contractors), if any, such as other Primal affiliates, financial institutions and intermediaries including involved credit or debit card issuers and banks, business support providers (including service providers and contractors) of things like Domain Name Services and data storage and security services, online stores and store services, order fulfillment services, private and public delivery services (including, potentially, the United States Postal Service), loyalty program services, payment services, debt collection services, email and other marketing services, suppliers, manufacturing, servicing, marketing and other business services providers, governmental entities including regulatory and law enforcement agencies, and social media networks, without limitation. 

We may share Your Personal Data in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Services, for payment processing, to contact You.

  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Share of Personal Information

We may share Your personal information identified in the above categories with the following categories of third parties:

  • Service Providers

  • Payment processors

  • Our affiliates

  • Our business partners

  • Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You.

Some third-parties, whether service providers or contractors or not, may also disclose, share or sell your personal information subject to their own privacy policies.  Primal is not responsible or liable for third-parties’ privacy (including data collection (and/or processing), disclosure, sharing and selling) policies or practices.  Similarly, and as addressed in Section 8 below, some third-parties (including service providers and contractors) may use cookies, beacons, applications and similar technical tools in connection with Primal affiliates’ websites, which may also collect (and/or process) Personal Data.  Again, Primal is not responsible or liable for such third-parties’ privacy (including data collection (and/or processing), disclosure, sharing and selling) policies or practices.  Also remember that if you leave a Primal affiliate’s website or application (if any) or are redirected to a third-party website or application, you may no longer be governed by this Privacy Policy.  Finally, third-parties, whether service providers or contractors or others, may be located in or have facilities that are located in a different jurisdiction than either you or a Primal affiliate.  So, if you elect to proceed with a transaction, which may involve a third-party, then your personal information may become subject to the laws of the jurisdiction(s) in which that party or its facilities are located or which govern their activities.

If a Primal affiliate or third-party (including service providers or contractors) is acquired or merged with another company, your Personal Data may be transferred to the new company so that it may continue to provide products, services and information, if any, to you. 

Primal affiliates do not sell Personal Data.  Primal affiliates do not share Personal Data to engage in cross-context behavioral advertising.  Primal affiliates do not use or disclose Personal Data for purposes other than those described in this Privacy Policy or as may otherwise be allowed by applicable law.  Primal affiliates do not, as of the publication date of this Privacy Policy, have actual knowledge of the collection (and/or processing), disclosure, sharing or sale of Personal Data belonging to minors.  Primal affiliates do not knowingly service persons under 18 years of age.

RETENTION OF YOUR PERSONAL DATA

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Services, or We are legally obligated to retain this data for longer time periods.

TRANSFER OF YOUR PERSONAL DATA

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

DISCLOSURE OF YOUR PERSONAL DATA

Business Transactions: If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

SECTION 5 -- DISCLOSURES REQUIRED OR ALLOWED BY LAW

Primal affiliates may disclose your Personal Data as required or allowed by law. Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

    • Comply with a legal obligation

    • Protect and defend the rights or property of the Company

    • Prevent or investigate possible wrongdoing in connection with the Services

    • Protect the personal safety of Users of the Services or the public

    • Protect against legal liability

HOW TO CONTACT PRIMAL TO DO SO

When you provide a Primal affiliate or a third-party (including service providers or contractors) with Personal Data Primal infers that you consent to its collection and use for the purpose at issue and that you are directing Primal or a third-party (including service providers or contractors) to do so.  If a Primal affiliate or a third-party asks for your Personal Data, for a secondary reason, the Primal affiliate will either ask you directly for your express consent or provide you with an opportunity to decline to participate.  For example, you may unsubscribe from Primal affiliate emails or texts at any time by clicking on a link provided in such emails or by responding as requested in such texts.

CALIFORNIA ADDENDUM:  Under California law, only to the extent that it may be applicable, consumers (or their authorized agents) have several rights related to their Personal Data.  These include:

  • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

  • The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:

    • The categories of personal information We collected about You

    • The categories of sources for the personal information We collected about You

    • Our business or commercial purpose for collecting or selling that personal information

    • The categories of third parties with whom We share that personal information

    • The specific pieces of personal information We collected about You

    • If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:

      • The categories of personal information categories sold

      • The categories of personal information categories disclosed

  • The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request please Contact Us at https://primalpetfoods.com/pages/contact-us

  • The right to change, correct and delete Personal Data

  • The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:

    • Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.

    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

    • Debug products to identify and repair errors that impair existing intended functionality.

    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.

    • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.

    • Comply with a legal obligation.

    • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

Certain restrictions may apply to any such requests.  Any such requests must be
verifiable as being made by the actual individual (or household) in question (or by an authorized agent).  Any verified request for action regarding your Personal Data shall also be provided to
applicable third-parties (including service providers and contractors), if any, for compliance. 

Under CCPA, personal information does not include:

  • Publicly available information from government records

  • Deidentified or aggregated consumer information

  • Information excluded from the CCPA's scope, such as:

  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data

  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Also under California law, only to the extent that it may be applicable, you must also agree in advance (“opt-in”) to a Primal affiliate’s collection, use and disclosure of personal information,  obtained specifically for any financial incentive given to you in exchange and you also have the right to withdraw your consent to a Primal affiliate’s use of your Personal Data, specifically given in exchange for any financial incentives at any time.  In certain circumstances, a Primal affiliate may offer financial incentives such as coupons, rebates, discounts or the like when you participate in programs like loyalty programs or when you create an online account, or otherwise.  The involved Primal affiliate will explain the involved program, its material terms, how to opt-in or withdraw, and what Personal Data may be required to participate.  While any related financial incentives may not be offered specifically in exchange for your Personal Data, you may need to provide such information to engage in the program.  In either event, if you do, Primal affiliates assume that you are opting-in to the arrangement as you are voluntarily providing such information.  The value of any Personal Data, you provide specifically in exchange for a financial incentive may vary but will typically be based on, among other possible metrics, the cost of providing the financial incentive by the involved Primal affiliate.  Primal affiliates do not discriminate based on your privacy choices and, again, you can withdraw your consent to Primal affiliates' use of your Personal Data, specifically related to any financial incentive program at any time.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

  • To operate our Services and provide You with our Services.

  • To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Services.

  • To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Services, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • As described to You when collecting Your personal information or as otherwise set forth in the CCPA.

  • For internal administrative and auditing purposes.

  • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy

The Right Not to Be Discriminated Against.

You have the right not to be discriminated against for exercising any of Your privacy  rights, including by:

  • Denying goods or services to You

  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

  • Providing a different level or quality of goods or services to You

  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

  • By visiting this page on our website: https://primalpetfoods.com/pages/contact-us

  • By sending us an email: [email protected]

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

  • Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative

  • Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if we cannot:

  • Verify Your identity or authority to make the request

  • And confirm that the personal information relates to You

  • We will disclose and deliver the required information free of charge within 180 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

DO NOT SELL MY PERSONAL INFORMATION

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Services that sells personal information as defined by the CCPA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Services:

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Services:

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

  • "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices

  • "Limit Ad Tracking" on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Services do not respond to Do Not Track signals. However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Children's Privacy

Our Services do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account. Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

DELAWARE ADDENDUM:  Under Delaware law, only to the extent that it may be
applicable, website users have the right to review and request that a Primal affiliate change or delete certain personal information collected.

GDPR ADDENDUM; If you are located in the European Economic Area (EEA) or the United Kingdom (UK), the following additional rights and disclosures apply to you under the General Data Protection Regulation (GDPR):

1. Legal Basis for Processing Personal Data

We only process your Personal Data where we have a legal basis to do so, including:

  • Consent – where you have given us explicit permission;

  • Contractual necessity – where data processing is necessary for the performance of a contract;

  • Legal obligation – where we are required to comply with a legal obligation;

  • Legitimate interests – where we have a legitimate interest that is not overridden by your rights and interests.

2. Your Rights Under GDPR

You have the following rights regarding your Personal Data:

  • Right of access – You can request access to the Personal Data we hold about you.

  • Right to rectification – You may request that we correct inaccurate or incomplete Personal Data.

  • Right to erasure (“right to be forgotten”) – You may request deletion of your Personal Data in certain circumstances.

  • Right to restrict processing – You may request that we limit how we use your Personal data.

  • Right to data portability – You can request a copy of your Personal Data in a structured, commonly used, and machine-readable format.

  • Right to object – You may object to our processing of your Personal Data for direct marketing or based on legitimate interests.

  • Right to withdraw consent – Where we rely on your consent, you may withdraw it at any time.

To exercise any of your rights, please contact us at:

Email: [email protected]

3. International Transfers
We may transfer your Personal Data outside the EEA or UK. Where we do so, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission or adequacy decisions.

4. Data Retention
We retain Personal Data only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable laws and regulations.

5. Supervisory Authority
If you believe your rights have been violated, you have the right to lodge a complaint with your local data protection authority (DPA).

TEXAS ADDENDUM:  Under Texas law, only to the extent that it may be applicable, consumers (or their authenticated agents) have several rights related to their Personal Data.  These include the right to request (subject to prescribed authentication procedures), the right-to-know and access, the right to correct, the right to delete, the right to exercise opt-out and use limitations, and the right against discrimination based on privacy choices, similar to the rights enumerated in the California Addendum to this Privacy Policy (sub-paragraphs (i)-(vi) of this Section, above).  Also under Texas law, only to the extent that it may be applicable, consumers have the right, and are required to, affirmatively opt-in to certain sales or processing of Personal Data.  Also under Texas law, only to the extent that it may be applicable, consumers have the right to appeal any decisions made by a Primal affiliate regarding a consumer personal information request.  As to any Primal affiliate, such appeals may be made through the same channels and means as are used to make initial consumer requests, as described below in this Section.

To provide or withdraw consent to any service or action (i.e., to “opt-in” or “opt-out”), to stop or limit the sale (if any), sharing (if any), other disclosure or use of Personal Data (if any), to ascertain what categories of PersonalData a Primal affiliate may have, what purposes it is used for, and what categories or persons or entities with whom a Primal affiliate may have sold, shared or otherwise disclosed such information (if at all), to obtain items of personal information, to request that a Primal affiliate change, correct or delete Personal Data , or to appeal (under Texas law) a Primal affiliate personal information request response, please email your request (or appeal) to the Primal Privacy Compliance Officer through this link [email protected] or contact the relevant Primal affiliate by telephone at (866) 566-4652.  The involved Primal affiliate will respond within 10 days and strive to resolve all requests within 45 days.  To protect you and all customers, and as indicated above, a Primal affiliate will have to verify (or authenticate) your identity (and any agent’s identity and authority) before disclosing, changing, ceasing or limiting the use or disclosure of or changing or deleting any Personal Data.  Generally, this may be done using information the involved Primal affiliate already has, from public information, and/or by asking you for verifying information including unique identifiers and two-factor identifying information.  A Primal affiliate may also require written and signed consumer authorization or a legal power of attorney in the event of an agent request.

SECTION 7 -- SECURITY

Security of Your Personal Data

Primal takes commercially reasonable precautions to help protect Personal Data, from inappropriate destruction, loss, access, disclosure or misuse.  The security of Your Personal Data is important to Us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Services in accordance with their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Services.

  • Google

  • Elevar

  • Klaviyo

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

Payments

We may provide paid products and/or services within the Services. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

  • Shopify Payments

  • Apple Pay

  • Google Pay

  • PayPal

SECTION 8 – “COOKIES” & SIMILAR FEATURES

Primal affiliates or third-parties (including service providers and contractors) may use cookies, beacons, applications and similar technical tools in connection with (embedded in) Primal affiliates’ websites.  The cookies, beacons, applications and similar tools that Primal affiliates use or understand are used in connection with their websites are, generally, used for purposes such as user and session identification, session data storage (e.g., referrer, landing page), token identification, login, password security, payment and payment security, website site security, page visits, number of visits, product visits, cart and check-out information, purchase transactions, subscriptions, advertising and marketing including email advertising and marketing, website, session and purchase analytics, embedded and other video view tracking, ad tracking across time and platforms, and geolocation.  Some third-parties (including service providers and contractors) that use cookies or similar technical tools on Primal affiliate websites may engage in cross-context behavioral advertising.  Primal affiliates disclose cookie, beacon, app and like tools’ use in connection with their websites to help you choose if you want to block such tools, or not.  Primal affiliates currently do not recognize “do not track,” “universal opt-out” or similar software settings.  Again, Primal is not responsible or liable for third-party privacy (including data collection (and/or processing), disclosure, sharing and selling) policies or practices.

SECTION 9 -- AGE OF CONSENT

By using this website, you represent that you are at least 18 years old. We do not knowingly collect personal information from minors under the age of 18 through our Services, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

SECTION 10 – EXCLUSIVE ARBITRATION OF DISPUTES

Any and all disputes between you and an applicable Primal affiliate arising out of or related to this Privacy Policy or any related matters shall be resolved, exclusively and irrevocably, by binding arbitration under the then current rules of the American Arbitration Association.  The arbitration shall be conducted, irrevocably and exclusively, at either Fairfield, California, Abilene, Texas or Bellingham, Washington, based upon the location of the applicable Primal affiliate.  There shall only be individual arbitrations, no class or representative arbitrations.  In agreeing to arbitration, you are waiving your rights to sue in court and, possibly, to a trial by jury.

SECTION 11 -- CHANGES TO THIS PRIVACY POLICY

Primal affiliates reserve the right to modify this Privacy Policy at any time, so please review it frequently.  Changes will be posted on Primal affiliate websites and will take effect immediately upon their posting.  Changes to the policy effective date typically mean that the policy terms have changed.

SECTION 12 -- QUESTIONS AND CONTACT INFORMATION

If you have any questions about this Privacy Policy, please contact the Privacy Compliance Officer at [email protected] or by telephone at (866) 566-4652.