This is how we collect and use your information. Last updated May 20th, 2025.
Introduction This Privacy Policy explains how Primal LTD. (“Primal”, “we”, “our”, “us”) collect, use, and disclose information we collect about you when: (i) you use our website at www.primalfragrance.com and other online locations where this Privacy Policy is posted (together, the "Website"), and our Primal mobile application (the "App") (the Website and App are collectively referred to as the "Site"); (ii) we engage in any off-line communications with you such as telephone, e-mail and personal communications ("Off-Line"). For purposes of this Privacy Policy, "Personal Information" includes any information that can be used to identify or locate you, such as your name, address, IP address, mailing address, contact information, email address or phone number and other personal information, as defined by the laws of your place of residence. Please recognize that your rights related to Personal Information, and how Personal Information is defined, differ somewhat from state to state and country to country. What personal information we collect We collect and process the following categories of Personal Information of individuals Off-Line and through the Site: • contact information (name, physical address, telephone, and email address); • age and gender; • account information (username and password); • payment information, such as credit card and payment card information (type, number, expiration date, security code), bank account number, billing address, and other related information; • purchasing history, such as past product purchases, subscription information for subscribers, order numbers, identification of products and quantities purchased; • information regarding your electronic device(s) and IP address and your use of the Site; • information contained in our Site and Off-Line communications with you, including survey responses, contact preferences and responses to our marketing efforts; • inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. How we collect personal information We may collect Personal Information from you in a number of ways. For example, we may collect Personal Information from you if you choose to create an account or a subscription with us, download or use the Site, complete an online survey or feedback form, visit our Site, rate or review products, sign up to receive communications from us, email us, or order any products or e-gift cards. We also collect information from other sources. Primal automatically receives and records Personal Information on our server logs from your browser as well as through other analysis of the Site. Such information collected may include but is not limited to your browser type, your operating system, your language preference, any referring web page you were visiting before you came to our Site, the date and time of each visitor request, and information you search for on our Site. We can also track the path of page visits on the Site and monitor aggregate usage and web traffic routing on the Site. We may collect Personal Information using cookies, web beacons or similar technologies, or through third parties using similar technologies. A "cookie" is a piece of data stored on your computer. When you visit the Site, your web browser may store cookies on your computer, which will better enable you to navigate the Site upon return. You can change your web browser settings at any time to stop accepting cookies or to prompt you before accepting a cookie from the sites you visit. You may use the Site even if you choose to reject or delete the cookies; however, some functions of the Site may not be available to you if you do so. Cookies also may be used by some of the other websites for which a link is placed on the Site. If you are in the United Kingdom, the European Union or another country where we need your consent in order to drop non-essential cookies on your device, we will not do this without obtaining your consent. To learn more, see our Cookie Policy. We may access Personal Information about you from third-party sources and platforms like Facebook, other social media and marketing platforms, marketing or ad firms. The Personal Information we collect may include your username and connection services, age range, gender, interests, advertisement interaction and viewing data and unique identifiers like a mobile identification number. With your consent if required by applicable law, Primal may use Google Analytics and other web analytics services, such as Mixpanel, to collect information relating to your use of the Site. These analytics services mainly use cookies to report on your interactions on the Site and help us analyze how users use the Site. Children and privacy If you are under 13, DO NOT USE THIS SITE. We do not knowingly collect Personal Information from children under age 13. If you are under age 13, you are not permitted to use the Site. If you are 13 - 17 years of age, you may visit, browse and use the information on the Site but you may not register an account or submit any Personal Information. If you are 13 - 17 years old, by browsing the Site you confirm that you have the permission of a parent or guardian to do so. If you are a parent or guardian and believe that we may have inadvertently collected Personal Information from your child, please notify us immediately by sending an email to dan@primalfragrance.com. How we use personal information We use the Personal Information we collect to communicate with you, advertise and of course, improve our Site. We may use any of the information we collect from you to serve you, respond to you, provide customer service and improve the Site and our products and services, including to: • process and fulfill your orders, and process payments; • alert you to new features, products, events, or services (if you have opted into receiving marketing communications, as described below); • process and respond to your customer service and support requests or feedback; • contact you about your account or profile; for example, we send all registered users a welcome email to confirm registration; • administer and improve the Site and our products and services, perform security functions, analyze data, perform surveys, and create marketing plans; • implement credit fraud protection and risk reduction measures; • make other marketing offers from our affiliates and marketing partners that we think may be of interest of you, subject to your having opted into receiving electronic marketing communications; • enforce our Terms of Service; • comply with laws and regulations, collect debts and protect our rights, protect Primal against fraud, misuse of our Site or services, comply with tax reporting requirements; and • for any other reason for which you provided the Personal Information. We may de-identify and anonymize Personal Information to create statistical data or system usage data, by removing all personal identifiers and/or aggregating your data with other’s data so that it is not identifiable as to any particular person. Such de-identified data may be retained and used by Primal to improve its products and services, provided to third parties, and used for any other proper purposes, subject to any limitations of applicable laws. Sharing personal information with third parties Depending on how you use our Site, the nature of your Off-Line communications, and our business and commercial needs, we may share your Personal Information in the following situations: • to our service providers, sponsors, suppliers, vendors and others who help Primal provide the Site and our services to you, including but not limited to advertising and ad measurement services, including but not limited to companies such as Iterable. This may include providing Personal Information to third parties for their processing in performing functions on our behalf, particularly the functions listed above in the "HOW WE USE PERSONAL INFORMATION" section. These third party providers will be contractually and/or legally required to protect Personal Information from additional processing (including for marketing purposes) and transfer in accordance with applicable laws; • to our affiliates; • to merchants, licensors, activity and event partners and sponsors, and other third parties for their own marketing purposes, such as to provide information to you about their new developments, special events, programs, services, activities, products, attractions, stores, promotions and sweepstakes activities, and other important information. We share your email or other Personal Information with our business partners, such as perfume brand companies, for their marketing purposes only if you have specifically opted-in to receiving communication from that brand or company; • to third parties to provide analytics or to confirm or update Personal Information provided by you; • to third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of Primal's business or operations (including without limitation in connection with bankruptcy or any similar proceedings); • to our professional advisers, such as auditors and legal counsel; or • as otherwise authorized by you. We also may share your Personal Information in response to a subpoena, legal order or official request; when we believe you have acted in violation of the Terms of Service; to investigate, prevent or take action regarding suspected illegal activities, fraud or potential threats; to exercise legal rights or defend against claims; or as otherwise permitted or required by law. We also may use, share or sell non-personally identifiable information, such as aggregated and de-identified data, with third parties. Such data will not be in a form that is identifiable or re-identifiable as to any individual person. If you elect to participate in any promotions, sweepstakes, surveys, questionnaires, or other events during your visit to the Site, the rules or terms and conditions for those events may indicate that your Personal Information will be shared with third parties with your consent. Please review the applicable rules or terms and conditions for any promotions, sweepstakes, surveys, questionnaires or events. Do not track We may, from time to time, collect information about your online activities, over time and across different websites. When you use our Site, third parties may also collect information about your online activities, over time and across different internet websites, online or cloud computing services, online applications, or mobile applications. Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Sites do not currently change the way they operate based upon detection of a “Do Not Track” or similar signal. Retention of personal information Primal processes and retains Personal Information to fulfill the purposes identified above, and for so long as is necessary to achieve the purpose for which the information was collected. Your rights relating to your personal information Specific Jurisdictions. Depending on where you live, you may have certain rights concerning your Personal Information. For more information on those rights, please see the specific sections below relating to residents of California, the UK, Europe, and Canada. General. If you otherwise wish to exercise certain rights over your Personal Information, please send an email to dan@primalfragrance.com and we will review your request as appropriate under applicable law. Opting into and out of communications. You don't have to hear from us or from our marketing partners, like perfume brands, if you don't want to. We share your Personal Information with our marketing partners only if you opted-in to receiving communications from them. You may opt out of receiving future opt-in communications by contacting us as at dan@primalfragrance.com, or by clicking the "unsubscribe" link at the bottom of any emails you receive from us and follow the instructions provided. Your California privacy rights. This section applies to California residents only. California Consumer Privacy Act (CCPA) All terms and phrases used under this sub-heading have the same meaning as those terms are defined under the California Consumer Privacy Act of 2018, as amended, and related regulations, as adopted from time to time (collectively, “CCPA”). Notice of Financial Incentive Material Terms of Incentive From time to time, we may provide a discount on your purchase of our products in exchange for you providing your Personal Information, including but not limited to signing up for a subscription. We may use the information you provide to send you messages, market future services or Sites, and for other internal statistical purposes. How The Incentive Is Reasonably Related To The Personal Information Provided Our financial incentive program is based upon our reasonable but sole determination of the estimated value of the Personal Information you provide, which takes into consideration, without limitation, estimates regarding the anticipated revenue generated from such information, the anticipated expenses which might be incurred in the collection, storage, and use of such information in the operation of our business, and other relevant factors related to the estimated value of such information to our business, as permitted under applicable law. Opt-In By providing your Personal Information when signing-up for a discount, you are affirmatively opting-in to our incentive program. If you wish to opt-out of the program, do not submit the Personal Information. Right to Withdraw If you wish to withdraw from receiving a discount or sample, you may submit such a request by sending an e-mail to dan@primalfragrance.com before completing your order. Notice of Collection To learn more about the categories of Personal Information we have collected about you in the twelve months preceding the last date this Privacy Policy was updated, including the sources of collection and how we use and share that information, please see What Personal Information We Collect, How We Collect Personal Information, How We Use Personal Information, and Sharing Personal Information With Third Parties above Notice of Disclosure for a Business Purpose To learn more about the categories of Personal Information we have disclosed for a business purpose to third parties in the twelve months preceding the last date this Privacy Policy was updated, including the categories of third parties who received such information, please see What Personal Information We Collect and Sharing Personal Information With Third Parties above. Notice of Sale and Sharing We “sell” and “share” your Personal Information through the use of certain third-party tools on our Site, including those relating to tracking technologies. To learn more about those technologies, see our Cookie Policy. Specifically, we make certain of your Personal Information with advertising, analytics, and marketing partners that may be considered a “sale” or “sharing” of your Personal Information under applicable law. We do not knowingly sell or share the Personal Information of any individual under the age of 16. Consumer Rights To submit a request for any of the rights listed below, please send an e-mail to dan@primalfragrance.com. Please note, depending on the type of request submitted, we may undertake reasonable efforts to verify your identity, including but not limited to matching the information you submit in your request with the information we have on file about you, and where appropriate requesting that you sign a declaration under penalty of perjury. Right to Know. You have a right to submit a request for the disclosure of the following information: (1) the categories of Personal Information we have collected from or about you in the twelve months preceding the date of your request; (2) the categories of sources from which we have collected that information, and the business or commercial purpose for which we collected that information; (3) the categories of third parties with whom we have shared or sold your information, and the business or commercial purpose for such sharing / selling; and (4) specific pieces of your Personal Information, subject to appropriate exceptions recognized under law. Right to Delete. You have a right to request that we delete the Personal Information we have collected about you, subject to certain exceptions available under the law such as, but not limited to, if the information is necessary to complete a transaction with you, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, comply with the law, or to use internally for purposes aligned with your expectations. Right to Opt-Out of the Sale or Sharing of Personal Information. Primal does not sell your Personal Information in the traditional sense. We do, however, share your Personal Information, such as your IP address, with third-party advertising and marketing partners who may use your Personal Information for a commercial purpose. Because this type of sharing may be considered a “sale” of Personal Information under the CCPA, we provide you the right to opt-out of that sale or sharing activity. To exercise this right, you may send an e-mail to dan@primalfragrance.com or visit Do Not Sell or Share My Personal Information. at the bottom of our Site. Finally, you may exercise your right to opt-out of the sale or sharing of your Personal Information by using the Global Privacy Control (GPC) on the browsers and extensions that support such a signal. If you choose to use the GPC signal, you will need to turn it on for each supported browser extension you use. Right to Correct. You have a right to request that we correct your Personal Information, subject to exceptions recognized under applicable law. Right to Non-Discrimination. We will not discriminate against you in any way if you choose to exercise your rights under this section and the CCPA. Account deletion Customers can request account deletion in the following ways: