Privacy Policy

Last Updated: 11/20/23

Protecting your privacy is very important to us. Accordingly, Primary Kids, Inc. (“Primary,” “we,” “us,” and “our”) is providing this Privacy Policy to explain our online and offline practices regarding the collection, use and disclosure of personal information that we collect about you, including when you use our website located at www.primary.com ("Site") and our children’s clothing retail services accessible via our Site.

This Privacy Policy outlines the kinds of personal information we may collect, how we intend to use and share that information, and how you may opt-out of a use or correct or change such personal information. To make the terms in this Privacy Policy easier to read, our Site, and services are collectively called the "Services."

This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. Also, please note that, unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Service. So, please make sure that you have read and understand our Terms of Service.

Notice at Collection

At or before the time of collection, California residents may have a right to receive notice of our practices, including the categories of personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared , and how long such information is retained. California residents can find those details as it relates to personal information that is subject to this Policy by clicking on the above links.

Revisions to this Privacy Policy

Any personal information that is collected via our Services is covered by the Privacy Policy in effect at the time such personal information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them on the Services or by sending you an email or other notification, and we’ll update the "Last Updated Date" above to indicate when those changes will become effective.

Collection and Use of Personal Information

Personal Information Collected or Received from You

The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We collect personal information that you provide to us, personal information we obtain automatically when you use our Services, and personal information from other sources such as third-party services and organizations, as described below.

• Account Information and Customer Interactions.

  When you create an Account, we’ll collect personal information that can be used to identify you, such as your name, password, and email address, and the individuals for whom you may be purchasing products. We will also collect additional personal information if you decide to purchase a product through our Services, such as your name, phone number, and shipping address. When you engage in certain activities via the Services, such as, without limitation, registering for e-mail promotions or notifications, setting up a shopping cart, filling out and submitting an online form, or contacting customer service, you may be asked to provide personal information, such as your name and email address. Depending on which activity you engage in, such personal information may be required or optional. If you agree to receive email or "special offers" from us when you sign up for an Account, or otherwise consent to receiving email from us, we may, from time to time, send you emails regarding our products and services. If you do not want to receive email advertisements, simply tell us when you sign up for your Account. The option to unsubscribe will also be present in every promotional email sent to you. If you encounter difficulties unsubscribing, please contact us at help@primary.com

• Purchases.

  We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but it may receive information associated with your payment card information (e.g., your billing details).

• Surveys.

  We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

• Sweepstakes or Contests.

  We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.

• Job Applications.

  If you apply for a job with us, we will collect any personal information you provide with your application, such as your contact information and CV.

• Personal Information

  Collected Using Cookies and other Web Technologies. Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons (“Technologies”) to collect certain information. "Cookies" are small text files that are placed on your device by a web server when you access our Services. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use Cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some third-party services providers that we engage (including third-party advertisers) may also place their own Cookies on your device. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by such third parties. "Web Beacons" (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Web Beacons are typically embedded invisibly on web pages (or in an e-mail). You may stop or restrict the placement of Technologies on your computer or remove them from your browser by adjusting your web browser preferences.

  Our uses of these Technologies fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
  • Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
  • Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
  • Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites. Some of the advertising Technologies we use include:
    • Facebook Connect. For more information about Facebook’s use of your personal information, please visit Facebook’s Privacy Policy. To learn more about how to opt-out of Facebook’s use of your information, please click here while logged in to your Facebook account.
  • Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:
    • Google Analytics. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
  • Social Media Platforms. Our Services may contain social media buttons such as Facebook, Instagram, Pinterest, and Twitter (that might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address, which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.
  • Personal Information Related to Use of the Services. Our servers automatically record certain information about how a person uses our Services (we refer to this information as "Log Data"), including both Account holders and non-Account holders (either, a "User"). Log Data may include information such as a User’s Internet Protocol ("IP") address, browser type, operating system, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address to fight spam, malware and identity theft. We also use the IP address to generate aggregate, non-identifying information about how our Services are used.
  • Personal Information Sent by Your Mobile Device. We collect certain personal information that your mobile device sends when you use our Services, like a device identifier, user settings and the operating system of your device, as well as information about your use of our Services.
  • Location Information. In some cases, we collect and store information about where you are located, such as by converting your IP address into a rough geolocation. We may use location information to improve and personalize our Services for you.
  • Via Email or Phone. We will also receive personal information about you if you send us an email or call our customer support number, and we’ll use that personal information in order to respond to your email communication or address your customer support inquiry.
  • Purchase History. If you create an Account, in addition to collecting and storing Log Data, we may also store certain information that you provided in connection with completing your purchase via the Services for each visit and for a period of time prior to that purchase (e.g., your purchase history and certain billing information). We reserve the right to keep such information as long as is appropriate to be compliant with our retention policy or applicable law.

  How We Use Your Personal Information.

  Additionally, we acquire, hold, use and process personal information for a variety of business purposes, including:

  • To Provide Products, Services, or Information Requested.

    We may use personal information to fulfill requests for products, Services, or information, including information about potential or future Services, including to:

    • Generally manage Accounts;
    • Respond to questions, comments, and other requests;
    • Provide access to certain areas, functionalities, and features of our Services;
    • Contact you to answer requests for customer support or technical support.

  • Administrative Purposes.

    We may use personal information for administrative purposes, including to:

    • Measure interest in our Services; Develop new products and Services;
    • Ensure internal quality control;
    • Verify individual identity;
    • Communicate about individual Accounts and activities on our Services and systems, and, in our discretion, changes to any Primary Kids, Inc. policy;
    • Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;
    • Process payment for products or services purchased;
    • Process applications and transactions;
    • Prevent potentially prohibited or illegal activities;
    • Enforce our Terms.

  • Marketing Our Products and Services.

    We may use personal information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials as permitted by applicable law. Such uses include:

    • To tailor content, advertisements, and offers;
    • To notify you about offers, products, and services that may be of interest to you;
    • To provide Services to you and our sponsors;
    • For other purposes disclosed at the time that Individuals provide personal information;
    • or Otherwise with your consent.

    You may contact us at any time to opt-out of the use of the personal information you’ve provided for marketing purposes, as further described in “Your Choices” below.

  • Research and Development.

    We may use personal information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, we may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
  • Direct Mail, Text, Phone, and Email. Individuals who provide us with personal information, or whose personal information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, text messages, or phone calls from us with information on our or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in “Your Choices” below.
  • Share Content with Friends. Our Services may offer various tools and functionalities. For example, we may allow you to provide personal information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend, such as an email inviting your friend to use our Services.
  • Services via Mobile Devices. From time to time, we may provide Services that are specifically designed to be compatible and used on mobile devices. We will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of our Services may require that users log in with an Account. In such cases, information about use of mobile versions of the Services may be associated with Accounts. In addition, we may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit personal information to us to enable Individuals to access Accounts and to enable us to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. We may use personal or non-identifiable information transmitted to us to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices we provide. Also, we may occasionally send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
  • De-Identified and/or Aggregated Information Use. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. De-identified and/or aggregated information is not personal information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within our and with Third Parties for our or their purposes in a de-identified and/or aggregated form that is designed to prevent anyone from identifying you. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by or required to comply with applicable laws.
  • Other Uses. We may use personal information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide personal information or with your consent.

Personal Information that We Share with Third Parties

We will not share any personal information that we have collected from you except as described below:

• Personal Information Shared with Our Service Providers.

  We may engage third party service providers to work with us to administer and provide the Services including (i) provision of information and services you have requested; (ii) payment processing; (iii) customer service activities; and (iv) in connection with the provision of the Site.

• Personal Information Shared for Interest-Based Advertising.

  Through our Services, we may allow third-party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected personal information (such as demographic information and past purchase history) we have collected with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit websites within their networks. This practice is commonly referred to as “interest-based advertising,” “personalized advertising,” or “targeted advertising.” We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share personal information with third-party advertising partners, you may opt-out of such sharing at no cost by following the instructions in the section titled “Your Choices” below.

• Information Shared with Other Users.

  The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.

• Personal Information Disclosed in Connection with Business Transactions.

• If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction. Personal Information Disclosed for Our Protection and the Protection of Others.

  We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.

Your Choices

We may offer you choices regarding the collection, use and sharing of your personal information and, in such cases, we’ll respect the choices you make. Please note that if you decide not to provide us with the personal information that we request, you may not be able to access all of the features of the Services.

Opt-Out.

• Email Communications. We may periodically send you free newsletters and e-mails that directly promote our Services. You will have the option to "opt-out" of receiving such promotional communications from us when you create an Account or by following the unsubscribe instructions provided in the e-mail you receive. We do need to send you certain communications regarding the Services and you will not be able to opt-out of those communications – e.g., communications regarding updates to our Terms of Service or this Privacy Policy or information about billing. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Primary Kids, Inc. and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

• Text Messages and Phone Communications. You may opt out of receiving text messages from us by following the instructions in the text message or by otherwise contacting us. You may opt out of receiving phone calls by contacting us as set forth below and or indicating that you would like to opt out via phone.

• Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly. The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from organizations that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or www.youronlinechoices.eu/ and www.aboutads.info/choices/.

  Please note you must separately opt out in each browser and on each device.

“Do Not Track.”

Additionally, Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Your Privacy Rights.

In accordance with applicable law, you may have the right to:

• Confirm Whether We Are Processing Your Personal Information (the right to know);
• Request Access to and Portability of Personal Information about you, including: (i) obtaining access to or a copy of your personal information; and (ii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine-readable format (the “right of data portability”);
• Request Correction of your personal information where it is inaccurate or incomplete;
• Request Deletion of your personal information;
• Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws);
• Request Restriction of or Object to our Processing of your personal information; and
• Withdraw your Consent to our processing of your personal information.

You may exercise any of these rights here. We will process such requests in accordance with applicable laws.

To protect your privacy, we will take commercially reasonable steps to verify your identity before fulfilling requests submitted under applicable privacy laws.. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to confirm the email address we have associated with you.

Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.

Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right, and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.

• EEA Data Protection Authorities (DPAs)
• Swiss Federal Data Protection and Information Commissioner (FDPIC)
• UK Information Commissioner’s Office (ICO)

Retention of Personal Information

We retain the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

Links to Third-Party Services

Our Services may contain links to websites and services that are owned or operated by third parties (each, a "Third-party Service"). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information, we recommend that you carefully review the privacy policies of all Third-party Services that you access.

International Transfer of Personal Information

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

Our Policy Toward Children

Our Services are not directed to individuals under 18(each a “child” or collectively “children”) and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may alert us at help@primary.com. If we learn that we have collected any child’s personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s Account.

Supplemental Notice for California Residents

This Supplemental Notice for California Residents supplements our Privacy Policy and only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (as amended from time to time) (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Primary has collected about them and whether Primary disclosed that personal information for a business purpose (e.g., to a service provider), whether Primary “sold” that personal information, and whether Primary “shared” that personal information for “cross-context behavioral advertising” in the preceding 12 months. California residents can find this information below:

The categories of sources from which we collect personal information and our business and commercial purposes for using and disclosing personal information are set forth in “Collection and Use of Personal Information” and “Personal Information that We Share with Third Parties” above, respectively. We will retain personal information in accordance with the time periods set forth in “Retention of Personal Information.”

• “Sales” of Personal Information and “Sharing” of Personal Information for “Cross-Context Behavioral Advertising” under the CCPA.

  California residents have the right to opt out of the “sale” of their personal information and/ “sharing” personal information for “cross-context behavioral advertising”. Under the CCPA, “sale” is defined broadly and includes the transfer of personal information by a business to a third party for valuable consideration (even if there is no exchange of money). It is unclear whether or not a Primary’s use of retargeting pixels on its website is a “sale” of personal information.

  To the extent Primary’s processing of personal information is considered “selling” or “sharing,” Primary “sells” and/or “shares” your personal information to provide you with “cross-context behavioral advertising” about Primary’s products and services.

  To the extent Primary’s processing of personal information is considered “selling” or “sharing”, the categories of personal information we have “sold” and/or “shared” for “cross-context behavioral advertising” and the categories of third parties we have “sold” personal information to and/or “shared” with in the preceding twelve months are listed below:

  Category of Personal Information Sold and/or Shared by Primary	Category of Third Parties Personal Information is Sold to and/or Shared with
  Identifiers. An online identifier, Internet Protocol address.	Advertising partners
  Commercial information Records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Advertising partners
  Internet or other electronic network activity Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.	Advertising partners
  Inferences drawn from other personal information to create a profile about a consumer Profile reflecting a consumer's preferences and behavior.	Advertising partners

Additional Disclosures for California Residents

Notice of Right to Opt-out of “Sale” of Personal Information and/or “Sharing” for “Cross-Context Behavioral Advertising”. California residents have the right to opt out of the “sale” of personal information and the “sharing” of personal information for “cross-context behavioral advertising.” To the extent Primary’s processing of personal information is considered “selling” or “sharing”, California residents may opt out at the “Do Not Sell/Share My Personal Information” link offered on our Site and following the instructions on that page, or by contacting us as set forth below.

Disclosure Regarding Individuals Under the Age of 16. Primary does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. Primary does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”

Disclosure Regarding Opt Out Preference Signals. California residents may opt out of “sales” of personal information and “sharing” of personal information for “cross-context behavioral advertising” that are carried out on Primary.com by broadcasting the opt-out preference signal known as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, visit the Global Privacy Control website. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use to visit Primary.com.

Disclosure Regarding Sensitive Personal Information. Primary only uses and discloses sensitive personal information for the following purposes:

• To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information.
• To resist malicious, deceptive, fraudulent, or illegal actions directed at Primary and to prosecute those responsible for those actions.
• To ensure the physical safety of natural persons.
• To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by Primary, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by Primary.
• For purposes that do not infer characteristics about individuals.

Notice of Financial Incentive. This Notice of Financial Incentives is to inform you about any programs, benefits, and other financial incentive offerings, including price or service differences (collectively, “Incentive Offerings”), that we may provide in connection with the collection of your personal information so that you may make an informed decision on whether to participate in our Incentive Offerings. Such Incentive Offerings may be deemed “financial incentives” under the CCPA.

The material aspects of any Incentive Offering, along with the personal information collected in connection with an Incentive Offering, will be described at the time you are presented with the Incentive Offering.

Examples of our Incentive Offerings may include:

• One-Time Promotion: We may offer you a discount on your first order if you provide us your email address and agree to receive marketing emails in exchange for a one-time discount.
• Refer-a-Friend Program: We may offer a discount on your future purchase when you provide your personal information along with your friends’ or colleagues’ personal information and they make a purchase using our Services. The referred party may also receive a reward in the form of a discounts on the first order and a free service for making a purchase through your referral.

You can opt-in to an Incentive Offering by following the instructions that accompany the presentation of the Incentive Offering. If you subsequently wish to withdraw from the Incentive Offering, you may request such withdrawal by contacting us as set forth in “Contact Us” below. Each Incentive Offering may be based upon our reasonable and good-faith determination of the estimated value of such offer to our business, taking into consideration the value of the offer itself and the anticipated revenue generation that may be realized.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Supplemental Notice for Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

Questions?

Please contact us at help@primary.com or 1-844-435-5675 if you have any questions about our Privacy Policy.