2. What Personal Information Do We Collect and How Do We Collect It?
- Information You Voluntarily Give Us
- Information Collected Automatically
- Information We Create or Generate
- Information Obtained from Third Parties
3. How Do We Use the Personal Information We Collect?
- Provide Goods and Services
- Personalization
- Improve Our Services and Products, and Do Analysis
- Market Our Products to You
- Sweepstakes, Contests and Other Promotions
- General Operations and Administration
- Aggregate or De-Identify Personal Information
4. To Whom do We Disclose the Personal Information We Collect?
5. What Rights and Choices Do You Have Regarding Your Personal Information?
6. Third-Party Websites and Services
7. How Do We Protect Your Personal Information?
8. How Long do We Retain Your Personal Information?
9. Collection of Personal Information of Children
10. Changes
11. Contact Us
1.Scope of this Policy
Please read this privacy notice and policy (this “Policy”) carefully to understand our policies and practices regarding your personal information and how we will treat it. This Policy applies to individuals who interact with Primo Brands Corporation and Our services as consumers or members of the public (“you”). This Policy explains how your “personal information” (which some jurisdictions may refer to as “personal data”) is collected, used, and disclosed by Primo Brands Corporation, our affiliates, our subsidiaries (including, without limitation, BlueTriton Brands, Inc. and Primo Water Corporation) and certain parties acting on our behalf (collectively “Primo”, “We”, “Us”). It also tells you how you can access and update your personal information, exercise certain rights, and make certain choices about how your personal information is used.
This Policy covers both our online and offline data collection activities, including personal information that We collect through our various channels such as Our websites, telephone contacts and Customer Support, and apps (Our “Services“), as well as third-party social media networks, consumer affairs, certain third-party data sources, points of sale, and events where this policy is provided to you. Please note that We might combine personal information from different sources (website, offline event), including by combining personal information that were originally collected by different Primo entities or Primo partners. We also may combine data from third parties with data We already have.
In some instances, if you do not provide personal information to Us, We may not be able to provide you with certain goods and/or services. We will generally indicate to you when this is the case, for example, by stating so on Our registration forms or not enabling the process to continue without that information.
2. What Personal Information Do We Collect?
Personal information is generally considered any information that can identify you or that relates specifically to you. The personal information that We collect about you depends on how you interact with Us and Our Services, what requests you make from Us, and the context of our relationship.Information You Give Us
When you interact with Us or the Services, you may provide certain personal information to Us, including:- Identifiers, including certain data defined as personal information under the California Customer Records statute or as a protected classifications under California or federal law. This data includes:
- Identification and Contact Data. Data that specifically identifies you or allows us to contact you, such as your first name, middle name or initial, last name, nickname or alias, government-issued ID, postal address, e-mail address, social media network details, or phone number.
- Account Login Data. Data that is required to give you access to your specific account profile. Examples include your login ID/email address, screen name, password, and/or security question and answer.
- Payment and Financial Data. Data that We need in order to fulfil an order, or that you use to make a purchase, such as your debit or credit card details (cardholder name, card number, expiration date, etc.) or other forms of payment (if such are made available). We may also collect information in connection with your credit application, if any.
- Demographic Data & Interests. Data that describes or identifies your demographic or behavioral characteristics, including your date of birth, age or age range, gender, geographic location (e.g., ZIP code), favorite products, hobbies and interests, and household or lifestyle data.
- Audio, Electronic, Visual and Similar Information. Content that you create and share with Us on third-party social media networks or one of Our Services. Examples include photos, videos, personal stories, or other similar media or content. We may also record and collect information from you during conversations with Customer Service.
- Commercial Information. Information relating to your use of the Services, including products or services purchased, obtained or considered and other purchasing or consuming history or tendencies.
- Sensitive Personal Information. Certain personal information that you provide might also be considered sensitive personal information under certain laws, including governmental IDs, social security number, account log-in information, health information, financial account information, and certain demographic information. For example, if you enable certain accessibility functions, that may involve collection of information relating to the particular accessibility need that you have.
Information Collected Automatically
When you interact with Us or the Services, certain information is automatically collected by the systems We use, including:- Data from Your Computer/Mobile Device/Browser. Data about the computer or device that you use to access Our Services, such as the Internet protocol (IP) address, and device and browser type, as well as other online identifiers. If you access Our Services via a mobile device such as a smartphone, the collected data will also include, where permitted, your phone’s unique device ID, advertising ID, and other similar mobile device data.
- Internet or Other Similar Network Activity. As you navigate through and interact with Our Services or emails, We use automatic data collection technologies to collect certain data about your device(s) and your actions. This includes data such as which links you click on, which pages or content you view and for how long, and other similar data and statistics about your interactions, such as content response times, download errors, and length of visits to certain pages, as well as operating system type and web browser type and version. This data is captured using automated technologies such as cookies and web beacons and is also collected through the use of third-party tracking for analytics and advertising purposes (see “Do Not Track/Opt-Out of Targeted Advertising” ).
- Audio, Electronic, Visual and Similar Information. We may visually record your interactions with Our Services, including your mouse clicks, movement, scrolling, and navigation through Our Services, including through the creation of heat maps.
- Geolocation Data. Our systems record IP addresses, which often provides your general location.We do not collectprecise geolocation data, but if you location services enabled on your device, third-party technologies may process that information and use it in relation to Our Services. We do not have access to that precise geolocation data, nor the ability to control its collection or its association with you; if you do not want your precise geolocation data collected or used, you may opt-out or disable location services on your device or with respect to the particular technologies.
Information We Create or Generate
We may use certain personal information we collect to create or generate other information, including:- Inferences. We may draw inferences from the data We collect from and about you to create a profile reflecting your preferences, characteristics, and behavior. We use this data for personalization and other general business purposes, such as internal or market research, developing models for prospective customers, analytics, and security.
Information Obtained from Third Parties
We get personal information about you from other sources, including our affiliates and business partners. We may obtain data from companies who compile information about shoppers and their preferences, and we may also get information from parties who we use for financial transaction, verification and fraud prevention. Social media platforms may also give Us data about you. We may get data about your interactions with our ads on third-party sites. The information that we obtain from third parties may be in any of the above categories.3. How Do We Use the Personal Information We Collect?
Provide Goods and Services
We use certain personal information, including Identification, Account, Payment and Financial, Commercial Information, Data From Your Device, Internet Activity and Sensitive Personal Information to provide our goods and services to you, including recording, processing, fulfilling, delivering and shipping your orders; payment processing; and customer service. We also use your personal information to inform you about the status of your orders, correct addresses and conduct identity verification and other fraud detection activities. Specific uses of this information include providing the products that you order, providing access to your account, tracking orders and resolving issues, responding to your requests and inquiries, and sending you updates regarding products or services (including changes to this Notice and our other terms).Personalization
We may use certain personal information, including Identification, Account, Payment and Financial, Demographic Data, Commercial Information, Data From Your Device, Electronic and Similar Information, Internet Activity, Geolocation Data and Inferences to (i) analyze your preferences and habits, (ii) anticipate your needs based on our analysis of your profile, (iii) improve and personalize your experience with Our Services, (iv) ensure that content from Our Services is optimized for you and for your computer or device, (v) provide you with targeted advertising and content, (vi) enable accessibility functionality, and (vii) allow you to participate in interactive features, when you choose to do so. For example, We remember your login ID/email address or screen name so that you can quickly login the next time you visit Our Services or so that you can easily retrieve the items you previously placed in your shopping cart. We may also show you specific Primo content or promotions that are tailored to your interests.Improve Our Services and Products, and Do Analysis
We constantly strive to improve our offerings, and in order to do so, We analyze interactions with Our Services and our marketing, reactions to our products, order history, customer comments and Customer Support interactions, and user behavior. The information we use to do this may include any or all of the categories of information that we collect. The models we use to analyze this information include the range of tools available to us from spreadsheets and databases to algorithmic models, and technologies like artificial intelligence and machine learning.Market Our Products to You
We may use your personal information to provide you with advertising and marketing information about Our products and Services, as well as certain other brands and products of others that we market or sell. The information that we use for those purposes may include Identification, Account, Payment and Financial, Demographic Data, Commercial Information, Data From Your Device, Electronic and Similar Information, Internet Activity, Geolocation Data and Inferences. Our advertising may include targeted online advertising (see “Do Not Track/Opt-Out of Targeted Advertising“. You can always opt out of receiving advertising and marketing materials through your account, by following the instructions for the specific message you receive, or through “Your Privacy Choices” below:Rewards Programs, Sweepstakes, Contests and Other Promotions
We have certain rewards programs and may also periodically offer promotions, including coupons, sweepstakes or contests. In order to participate in these activities, we may collect and use certain personal information based on the nature of the specific promotional activity, and there may be additional terms, rules, requirements and notices associated with those promotions.General Operations and Administration
In accordance with applicable laws, We use your personal information for other general business purposes, such as maintaining your account, conducting audits, financial calculations and tax reporting, administering our business and operations, evaluating performance, evaluating and maintaining our systems, security and fraud prevention and monitoring. When and as appropriate, We may also use personal information to exercise Our legal rights or perform our obligations under applicable laws. The information we use to do this may include any or all of the categories of information that we collect.Aggregate or De-Identify Personal Information
We may also use certain information that we have de-identified or aggregated (as defined under applicable law) with other information so that it can no longer identify, or be associated with, you. Under applicable law, this information is no longer personal information, and we can use and disclose the information for any purposes, unless prohibited by applicable law. The information we use to do this may include any or all of the categories of information that we collect.4. To Whom do We Disclose the Personal Information We Collect?
Our Affiliates
We may provide your personal information to our affiliates and subsidiaries (including BlueTriton Brands, Inc. and Primo Water Corporation) who process that information for the delivery of our Services or for our business purposes as described in this Policy.Our Service Providers
We disclose your personal information to service providers who We engage to help Us run our business (e.g., order management and fulfilment, payment processing, fraud detection and identity verification, Customer Support, information technology and computing support, customer relations management systems (CRM), rewards and benefits offerings, customer and consumer research, operations, managing marketing and promotions, customer and consumer research, and similar activities). Without limiting the above, for purposes of fraud prevention, we may share your personal information with Forter, Inc. (“Forter“), our third-party provider of fraud screening services; please see Forter’s privacy policy.Other Third Parties
We may also disclose personal information to certain other parties, including:- Credit reporting agencies/debt collectors (credit reporting agencies and debt collectors are external companies that We use to help Us to verify your creditworthiness (in particular for orders with invoice) or to collect outstanding invoices).
- Advertising and marketing partners and agencies, including digital advertising networks, publishers, and technology providers.
- Joint promotion partners, if any, as disclosed in the applicable joint promotion terms.
- Other parties in connection with a corporate transaction, including a merger, acquisition, restructuring, or bankruptcy. Personal information may be disclosed in the context of due diligence relating to the transaction and/or to the successors to Our business or the applicable parts of it.
- To law enforcement, governmental authorities or third parties when and as required by law; in response to legal proceedings; in response to a required from law enforcement; to protect Our rights, security, safety, or property, or those of other parties or the public; to enforce the terms of any agreement, including the terms of our Services.