Issue Date: December 31, 2019
Revised: March 1, 2022
- Your use of our products and services;
- Offline services, including our Customer Care Center and door-to-door sales and delivery activities (collectively, "offline environments"); and
- Information shared with us by other sources for our own internal purposes.
- Websites, mobile apps, or other products and services that have their own privacy policies;
- Information collected for employment-related or business-to-business related purposes.
INFORMATION WE COLLECT
Personal Information means any information that identifies, relates to, describes, or is capable of being associated with you or your household, whether directly or indirectly. All companies need to collect and share consumers’ Personal Information for everyday business purposes, marketing, and maintenance of the safety, security, and integrity of their websites and other assets, among other reasons.
We collect the information you provide when you:
- Order our products and services or create an account with us;
- Request support or submit an inquiry to our Customer Care Center;
- Sign up to receive information about our Company, our products and our services;
- Respond to surveys or participate in contests or promotions; or
- Post information to message boards or discussion forums accessible through our online environments.
This information may include:
- Identifiers, such as your real name, alias, postal address, e-mail address, phone numbers, or username;
- Financial information, such as your bank account number, credit or debit card number, or other financial information;
- Transactional information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories, equipment maintenance data to provide on-demand services, contract details, written signatures, or recordings of your calls to our Customer Care Center.
TECHNICAL INFORMATION COLLECTED AUTOMATICALLY
We collect the information provided when you transact through our online environments without you actively submitting such information, such as:
- Identifiers, such as your internet protocol (IP) address and geolocation data
- Network activity data, such as browsing history, search history, and information regarding your individual interactions with an internet website, application, or advertisement
This information can make your use of our online environments easier and more meaningful by allowing us to provide better service, customize our online environments based on your consumer preferences, compile statistics, provide you with more relevant advertisements, analyze trends, and otherwise administer and improve our online environments. For more information, refer to our Cookies Policy.
We may also combine the information we collect through one or more of our online environments with information we collect through other online environments. We may also combine information collected through our online environments with information collected through our offline environments, as well as with information provided by our partners. We use this consolidated information to help us improve our online environments, products, and services; to communicate information to you; to enhance our marketing and research activities; and to engage in any other uses described in the "HOW WE USE THE INFORMATION WE COLLECT" section below.
INFORMATION COLLECTED FROM OUR BUSINESS PARTNERS
Our advertising vendors may share information with us regarding our ads on websites or apps where such ads run. This enables us to measure and improve those ads by including information such as whether clicks on ads led to purchases, or a list of criteria to use in targeting ads. We may obtain information from our other partners, such as co-sponsors who we may partner with to run special contests or other co-branded promotions. We may obtain information from other commercially available sources such as data aggregators, marketing firms, and public databases to provide us with additional information about our existing consumers (this is known as “data appending”). This information may include name, demographic information, contact information, interests, and publicly observed data such as from social media and shopping behavior. We may receive information about consumers when we acquire all or part of other companies. We assess this data to determine how it was collected and what consent was given for its use.
HOW WE USE THE INFORMATION WE COLLECT
We use the information we collect to:
- Manage and fulfill orders, deliver products, process payments, manage returns;
- Respond to requests for information and services; and
- Improve our products and services.
We also use the information we collect in anonymized, aggregated form for customer preference analyses, and to:
- Develop new products and services;
- Develop co-branded partner relationships; and
- Determine how to best protect the data of our company and our consumer.
Identifiers – We may use the information you provide to us to:
- Send you advertisements, notices, and other information regarding our products and services, including notifying you about special promotions;
- Respond to your inquiries or support requests;
- Invite you to participate in surveys regarding our products or services;
- Determine your eligibility for, and to register you in, our contests and other promotions, fulfill and deliver prizes, and contact you regarding such contests or other promotions;
- Furnish and maintain our online environments; and
- Secure our networks and online environments
Financial information – If you make a purchase through our online or offline environments and authorize us to use your credit or debit card information, we will use this information to charge you as authorized. In these situations, we may also save your contact and payment information (using commonly accepted security measures) so that you can use them the next time you want to order something from us.
Transactional information – If you register or open an account with us, the information we collect may be used to maintain your account, provide you with access to some features of our online environments, or offer you the benefits and privileges that typically come along with account registration. This may include purchasing products or services, use of exclusive or personalized content or activities (such as message boards), and participation in special events and promotions (contests, sweepstakes, coupons, etc.).
Technical information – We may also use the information we collect to offer you customized content by:
- Recognizing new or past visitors to our online environments;
- Remembering your personal preferences;
- Showing you more relevant and meaningful advertisements;
- Better understanding the interests of our consumers and visitors to our online environments; and
- Conducting research and analyzing the use of our online environments, products, services, and advertisements.
Some of our applications and mobile-optimized online environments may have location-based features. To deliver these features, we may access and use location data provided by your mobile device. For example, we may offer shopping features that allow you to get information about local merchants. Location information will be collected solely to deliver the requested feature and will not be further retained or stored by us.
With regard to our mobile apps’ communications, the default settings on application download enable us to send you notifications about your account, product deliveries, and product offerings. These settings may be modified through the notification settings feature of your mobile device.
SHARING YOUR PERSONAL INFORMATION
WE DO NOT SELL YOUR PERSONAL INFORMATION to third parties. We may share some or all of your personal information as required or permitted by law and to the following persons or entities:
Legal Requests and Preventing Harm – We will disclose information as reasonably necessary to comply with a law, regulation, or legal request; to protect the safety, rights, or property of the public, any person, or Primo; or to detect, prevent, or otherwise address fraud, security, or technical issues.
OTHER IMPORTANT INFORMATION ABOUT OUR RELATIONSHIP WITH THIRD PARTIES
RIGHTS AND CHOICES YOU HAVE ABOUT YOUR PERSONAL INFORMATION
You have the following rights with respect to your Personal Information:
- Right to Notice. Before or at the time we collect Personal Information from you, you have the right to receive notice of the Personal Information to be collected and the purposes for which we use it. This Notice is intended to satisfy this requirement.
- You also have the right to request that we disclose to you the categories of personal information we have collected about you in the preceding 12 months, along with the categories of sources from which the personal information was collected, the purpose for collecting the personal information, and the categories of third parties with whom we shared the personal information
- Right of Access. You have the right to request that we disclose or provide you with access to the specific pieces of Personal Information we have collected about you in the preceding 12 months.
- Right to Deletion. You have the right to request that we delete the Personal Information we collect from you. However, in certain situations we are not required to delete your Personal Information, such as when the information is necessary in order to complete the transaction for which the Personal Information was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure our websites or other online services, or to otherwise use your Personal Information internally in a lawful manner that is compatible with the context in which you provided the information.
- Right Not to Be Subject to Discrimination. You have the right to be free from discrimination or retaliation for exercising any of your rights as described above. We may, however, charge a different price or rate, or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to Primo by your Personal Information. Further, we may offer you financial incentives in return for your Personal Information.
You can exercise any of your rights by using the information in the “Contact Us” section below.
PRIMO does not sell YOUR personal information.
VERIFICATION OF YOUR IDENTITY
We value the security and confidentiality of your Personal Information. Therefore, if you exercise your right to notice, right of access, or right to deletion, we must first verify your identity to make sure that you are the person about whom we have collected Personal Information. We verify every request carefully.
HOW WE SECURE YOUR INFORMATION
We have instituted physical, technical, and procedural safeguards to store and maintain information we collect in a secure environment. You may also be required to use a password to access certain pages on our online environments where certain types of your information can be changed or deleted. It is therefore important for you to protect against unauthorized access to your password and to your device. You take full responsibility for maintaining the complexity and confidentiality of your password. While we have implemented safeguards, you should be aware that Internet security technology rapidly changes. We cannot guarantee that the safeguards we employ today can protect your information from the threats of tomorrow. You should also be aware that despite our efforts, factors beyond our control may result in disclosure of information. Accordingly, we are not able to guarantee that your information will be secure under all circumstances. We retain Personal Information collected through the online and offline services as long as necessary to provide the services, products, and information you request or as permitted by applicable law.
MESSAGE BOARDS AND DISCUSSION FORUMS
Some of our online environments may allow you to share comments or other information. Any information that you may disclose through message boards, discussion forums, blogs, or on other public areas on our online environments becomes public information.
OUR POLICY ON CHILDREN’S INFORMATION
We do not knowingly collect or use any information from children (we define "children" as minors younger than 16 (sixteen) years of age) on our online or offline environments. We do not knowingly allow children to order our products or services, communicate with us, or use any of our online environments. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below, and we will work with you to address this issue.
Our online and offline environments are designed for and targeted to audiences in the United States (“U.S.”) and are governed by and operated in accordance with the laws of the U.S. While users from countries other than the U.S. may access our online and offline environments, we make no representation that such environments are operated in accordance with the laws or regulations of, or governed by, other nations.
Please be aware that by accessing our online and offline environments, or providing us with information, you understand and agree that:
Information collected from you may be transferred to and stored on servers located outside your jurisdiction;
- Clicking on the "Contact Us" link on the online environment you are visiting;
E-mailing our Customer Care Center at firstname.lastname@example.org;
Calling our Customer Care Center at 1-800-728-5508; or
Writing to us at Primo Water North America, Attention Data Privacy Team, 200 Eagles Landing Boulevard, Lakeland, Florida 33810.