Welcome to Primal Nutrition’s website privacy notice (“Notice”).
Primal Nutrition respects your privacy and is committed to protecting your personal information, which we will refer to in this Notice as “Personal Data”. This Notice tells you about how we look after your Personal Data, the privacy rights you have, which may vary depending on where you live, and how the law protects you.
It is important that you read this Notice, and any other privacy notices we may provide when we are collecting or processing Personal Data about you, so that you are fully aware of how and why we are using your personal data.
This Notice applies in addition to other privacy notices we may use and is not intended to override them. For more detail about how Primal Nutrition deals with Personal Data, please contact us using one of the methods provided below.
You can click on the links below to find out more information:
1. INFORMATION ABOUT US
Purpose of this Notice
This Notice describes how Primal Nutrition collects and processes your Personal Data through your use of this website, including any data you may provide to us or that we receive from third parties as described in Section 3 of this Notice.
It is important that you read this Notice together with any other privacy notices we may provide to you when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This Notice supplements other privacy notices and is not intended to override them.
Primal Nutrition, LLC is the controller and responsible for this website.
Data Privacy Team
We have appointed a Data Privacy team who are responsible for overseeing questions in relation to this Notice.
If you have any questions about this Notice, including any requests to exercise your legal rights, please contact the Data Privacy team using the details below.
Full name of legal entity: Primal Nutrition, LLC
Contact: The Data Privacy Team
- For European inquiries: GDPR@kraftheinz.com
- For U.S. inquiries: USprivacy@kraftheinz.com
- For all other privacy-related inquiries: Privacy@kraftheinz.com
- For general inquiries: email@example.com
Postal address: Primal Nutrition, 200 East Randolph St., Chicago, Illinois 60601
Note for European visitors: You have the right to make a complaint at any time to your local regulatory authority whose detail can be found here. However, we would appreciate the chance to deal with your concerns before you approach the authority so please contact us in the first instance.
Helping Us Keep Your Personal Data Up To Date
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
We do not control these third-party websites and are not responsible for their privacy statements or data handling. You should read the privacy terms for all third-party websites you visit to find out how they handle your personal data.
Children and This Website
This website is not aimed at or intended for children under the age of 16.
2. PERSONAL DATA WE COLLECT
‘Personal Data’ is any information about an identifiable living individual but does not include information which you cannot link to a specific person, such as Aggregated Data, as described below. Your Personal Data is therefore information about and linked to you.
We may collect, use, store and transfer different kinds of your personal data, which may include:
(a) Identity Data such as first name, last name, title, marital status, date of birth and gender.
(b) Contact Data such as home address, billing address, email address and telephone numbers.
(c) Financial Data such as bank account and payment card details if you order goods from us.
(d) Transaction Data such as details of purchases you have made from us.
(e) Technical Data such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
(f) Profile Data such as your website username and password, purchases or orders made by you and information about your interests, preferences, feedback and survey responses.
(g) Usage Data such as information about how you use our website, products and services.
(h) Marketing and Communications Data such as your preferences in relation to receiving marketing from us and third parties and for the ways we communicate with you.
We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your Personal Data but is not Personal Data because it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to find out how many users access a specific website feature.
If we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data and will process it as set out in this Notice.
We may collect some items of Special Category Personal Data (which includes information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) but will only do so where we believe it is necessary in connection with issues relating to our products or for some other reason that we will advise to you when we request your consent to collect the data.
Failure to Provide Personal Data Where Requested
Where we need to collect Personal Data by law and you do not provide that data when requested, we may not be able to provide you with the products or services for which that Personal Data is required. Similarly, where we need to collect Personal Data under the terms of a contract we have with you, and you do not provide that data when requested, we may not be able to perform the contract we either have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel the contract you have with us.
3. HOW YOUR PERSONAL DATA IS COLLECTED
We use various methods to collect your personal data, including:
a. Directly from you - where you give us Personal Data such as your Identity, Contact, and Marketing Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
- apply to receive our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- contact us on social media (such as Instagram, Facebook, or Twitter);
- register and participate as an affiliate in our affiliate program; or
- give us some feedback or raise a concern or complaint.
In addition, if you contact us by phone, email or otherwise, we may keep a record of that correspondence.
b. By automated means – when you interact with our website, we may automatically collect Technical Data about your equipment and browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies, which use small pieces of computer code to help us understand how consumers interact with our website and communications. We may also receive Technical Data about you if you visit other websites employing our cookies.
Please see our Cookie Notice for further details.
c. From third parties and publicly available sources. We may receive Personal Data about you from various third parties and publicly available sources as set out below:
- Technical Data from analytics providers such as Google;
- contact, financial and transaction data from providers of technical, payment and delivery services;
- identity and contact data from data brokers or aggregators such as Nielsen and Starcom, and social media companies such as Facebook and Twitter, which have operations inside the European Union; and
- identity and contact data from publicly availably sources such as, for European residents, Companies House and the Electoral Register based inside the EU.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting the Data Privacy Team.
We may use your Personal Data for or in connection with the following purposes:
a. Where necessary to establish and perform your contract with us, such as where you buy products directly from us;
b. Where necessary to comply with a legal obligation:
- in connection with any potential or actual corporate transaction or transfer of employment arising in relation to a business transfer or change of service provider in which case Personal Data may only be processed to the extent permitted by applicable law (such as the Acquired Rights Directive in Europe);
- compliance with applicable procedures, laws or regulations including in relation to retaining records of business activities and payment of taxes;
- disclosures to law enforcement agencies or in connection with legal claims, health & safety compliance, regulatory, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation)
c. Where necessary for Primal Nutrition's legitimate interests in connection with the purposes listed below, and where our interests are not overridden by your data protection rights:
- the proper conduct and development of Primal Nutrition’s businesses and operations;
- research including consumer and market preferences to assist with the operation and development of Primal Nutrition’s business;
- assisting with the development of existing and creation of new Primal Nutrition products and services;
- the manufacture of Primal Nutrition Products and supply of those products to Primal Nutrition customers;
- promotional and marketing activities (including running competitions and prize draws) in relation to Primal Nutrition’s business and products;
- other disclosures required in the connection with promoting or marketing of Primal Nutrition, its products or services;
- financial and other forecasting and modelling;
- operation, maintenance and development of Primal Nutrition’s information systems, networks and the equipment associated with or connecting to those systems and networks;
- development of Primal Nutrition’s business through mergers, acquisitions, disposal and other corporate actions;
- dealing with actual and potential shareholders, investors and other stakeholders in Primal Nutrition’s business or the business of its parent company, Kraft Heinz Foods Company;
- maintenance and protection of Primal Nutrition’s physical and intellectual property and assets;
- protecting corporate and personal security (which may include use of CCTV and other visual or audio monitoring);
- recording, responding to, dealing with and resolving matters arising in respect of Primal Nutrition products or staff;
- recording, responding to, dealing with and resolving actual or potential complaints from customers and consumers;
- investigations to ensure compliance with or identify/confirm any potential breaches of any applicable procedures, laws or regulations;
- establishing, exercising or defending legal rights;
- working with suppliers to whom Primal Nutrition has outsourced business or other services;
- in connection with business acquisition, disposal or reorganisations other than where information is exchanged in connection with a legal obligation as set out above; and
- processing necessary for the purposes of other legitimate interests pursued by Primal Nutrition.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You can ask us to stop sending you marketing messages at any time by clicking on the “unsubscribe” link within the message or by contacting the Data Privacy Team.
Note for European residents: You can obtain further information on the legitimate interests balancing exercises which we have carried out by contacting the Data Privacy Team at GDPR@kraftheinz.com.
5. SHARING YOUR DATA WITH THIRD PARTIES
We may share your data with third parties, including other companies within Primal Nutrition and with third-party service providers who provide services to us as further explained below.
Where we provide Personal Data to contractors and suppliers who provide services to us, including assistance with the processing activities set out in this notice, we will enter into a data processing agreement (which complies with applicable law, including provisions required by GDPR) with those contractors and suppliers.
In order to fulfill our legal and other obligations and in connection with our rights including protection of our legitimate interest, we reserve the right to disclose Personal Data (or Special Category Data as appropriate) to law enforcement agencies, regulatory bodies, government agencies and other third parties as required by law or for administrative purposes (for example, the Internal Revenue Service in the United States or HM Revenue and Customs in the UK) and to the extent that local law allows and/or requires this.
Note for European residents: Primal Nutrition is located in the United States and it processes your Personal Data in the United States. We may share your Personal Data with Primal Nutrition’s affiliates and parent companies, partners, suppliers, law enforcement agencies and to other organizations that are also located in the United States or in other countries outside the EU for the purposes of establishing and performing your contract with us, fulfilling legal obligations, and where necessary to fulfill our legitimate interests described above, where our interests are not overridden by your data protection rights. The laws of some jurisdictions outside the EEA may not be as protective as Data Protection Laws in the EEA. Primal Nutrition will ensure that, for such jurisdictions, appropriate measures are in place for compliance with Data Protection Law in relation to the processing of Personal Data in those jurisdictions.
6. DATA RETENTION
We have legal duties to keep various records and records need to be held for different periods of time, depending on their contents.
We will therefore keep Personal Data for as long as we reasonably consider we may need to in connection with those obligations.
Where we do not have keep Personal Data for a period specified by law we will not keep Personal Data for longer than applicable law allows us to.
For further information about our approach to data retention, please contact the Data Privacy Team.
7. YOUR LEGAL RIGHTS IF YOU LIVE IN EUROPE
If you are a resident of Europe, under the General Data Protection Regulation and other applicable data protection laws, you are entitled to ask Primal Nutrition for a copy of your Personal Data and to ask for it to be corrected, edited or have its processing restricted. In certain situations, you may also be entitled to ask Primal Nutrition to delete your Personal Data or transfer some of your Personal Data to other organizations.
You may also have rights to object to some processing of your Personal Data although Primal Nutrition may continue that processing if it is required in connection with legal obligations.
Your Personal Data rights may be limited or subject to exceptions in some situations; for example, where Primal Nutrition demonstrates that it has a legal requirement to process your data, such as where tax authorities require us to retain it or where it is needed for proper performance of a contract.
Where Primal Nutrition has asked for your consent to process Personal Data and that consent is withdrawn we will not process that Personal Data further but may not be able to continue providing the goods or services for which the Personal Data was sought.
Where Primal Nutrition has a legal right or obligation to retain Personal Data or wishes to do so in connection with its legitimate interests, it may do so even if you have withdrawn consent for Primal Nutrition to hold your Personal Data.
Where Primal Nutrition requires Personal Data to comply with legal or contractual obligations, the provision of such data is mandatory. If such data is not provided Primal Nutrition will not be able to manage the employment or engagement relationship, or to meet legal obligations placed on us. In all other cases, provision of requested Personal Data is optional.
8. IF YOU HAVE CONCERNS ABOUT YOUR PERSONAL DATA
For any concerns or questions about how Primal Nutrition processes your Personal Data or have any questions in relation to your rights in respect of your personal data, please contact the Data Privacy Team.
In the first instance you should raise all data concerns with the Data Privacy Team but you also have the right to complain directly to data protection authorities at any time. The relevant data protection authority will be the supervisory authority in the same country as your employing entity.
Please see here for details of national data protection authorities in the European Union.
9. CHANGES TO THIS NOTICE
We may change this Notice at our discretion and in the event we do so we will make the revised Notice available via our websites.
Effective Date: January 1, 2020
California Privacy Notice
Effective Date: January 1, 2020
Your privacy is important to us. This California Privacy Notice supplements our Website Privacy Notice and describes the types of information we collect from and about California residents when you visit any of our websites where this policy is posted (or the mobile optimized version of the website) (each a “Site”). This Privacy Notice also explains how we may use and disclose such information, as well as your ability to control certain uses of it. Please review our Website Privacy Notice for additional information about how we use your personal data. Any terms defined in the California Consumer Privacy Act of 2018 (“CCPA”) have the same meeting when used in this California Privacy Notice.
Information We Collect
Information You Provide
We collect certain personal information from you when you choose to share it with us. This personal information includes:
|Category of Personal Information||Examples|
|Identifiers||Real name, postal address, IP address, email address, account name, social media account name|
|Characteristics of protected classifications under California or federal law||Age, gender, race, ethnic background|
|Commercial information||Records of products or services purchased, obtained, or considered; purchase histories|
|Internet or other electronic network activity information||Page views, Site browsing history, information about your interaction with our Site|
|Professional or employment-related information||Profession, job title, industry of employment, honorific|
|Education information||Level of degree obtained|
We do not collect the following categories of personal information using the Site:
- biometric information, such as fingerprints or faceprints;
- geolocation data; or
- sensory data, such as audio, electronic, visual, thermal, or olfactory information.
Tracking Options and California Do Not Track Disclosures
Certain parts of our Site require cookies, as described in further detail in our cookie notice. You are free to set your Internet browser settings to stop accepting new cookies, to receive notice when you receive a new cookie, to disable existing cookies, and to omit images (which will disable pixel tags). On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising. By doing so, you may not be able to use certain features on the Site or take full advantage of all of our offerings. Please refer to your Web browser’s or operating system’s website or “Help” section for more information on how to disable your browser or operating system from receiving cookies or controlling your tracking preferences.
Our system may not respond to Do Not Track requests or headers from some or all browsers. You can learn more about and opt out from receiving third party advertiser cookies by visiting the Digital Advertising Alliance’s opt-out page here. We adhere to the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising.
How We Use and Share Your Information
We use your personal information as described in the Website Privacy Notice.
We do not sell or otherwise disclose personal information about our website visitors except as described here. We do not share your personal information with unaffiliated third parties for their own marketing purposes without your consent. Please see “Your Rights and Choices” below for information on how to opt out of the sale of your data.
We may share personal information we collect from and about you with our third-party service providers for the following business purposes:
- To assist us in responding to your comments or questions, or contacting you if needed while processing a product or service you requested through our websites;
- To improve our websites, products, and services; develop new products or services; and conduct analysis to enhance current products and services;
- To review the usage and operations of our websites and improve our content, products; and services;
- To send you promotional offers, newsletters, materials, and other communications and information about Primal Nutrition, its portfolio of brands, affiliates, and its partners;
- To provide you with content that is customized to your interests, targeted offers, and advertising on the Sites, on third party sites and media platforms, including in social media, or via email, depending on your preferences;
- To contact you as necessary when you enter a contest, sweepstakes, or game in order to conduct the promotion (for example, to contact you if you’re a winner);
- To conduct joint promotions with third-party partners, where such personal information is necessary to conduct the promotion;
- To address problems with the websites or our business;
- To manage our telecommunications networks;
- To protect the security or integrity of the websites and our business;
- As otherwise described to you at the point of data collection; and
- To process credit/debit card information where needed to process payments and prevent fraud.
Additionally, if you use the websites to connect with third-party services you authorize us to use information from and about you, on your behalf, to interact with these third-party services based on your requests.
Your Rights and Choices
You have the right to request that we provide certain information to you about how we collected and used your personal information during the previous 12 months. Specifically, you have the right to request:
- The categories of personal information we collected about you;
- The categories of sources of personal information we collected about you;
- The business or commercial purpose(s) for which we collected or sold your personal information; and
- The categories of third parties with which we share your personal information and, where such disclosures were for a business purpose, the personal information categories that each category of third-party recipients received and, where such disclosures were sales, the personal information categories purchased by each category of recipient;
- The specific pieces of personal information we collected about you.
You also have the right to request that we delete personal information we collected from you, subject to certain exceptions.
How to Exercise Your Rights
If you would like to exercise the rights set out above, please submit a verifiable consumer request to us via:
A verifiable consumer request must provide us adequate information to allow us to (1) reasonably verify that you are the individual whose personal information we collected (or an authorized representative) and (2) to understand your request so that we can process and respond to it. Please note that only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may submit a verifiable consumer request for your personal information. You may submit verifiable consumer requests on behalf of your minor children.
Once we have received and verified your request, we will send a confirmation of our receipt of your request and, within 45 days, either a copy of the requested information or confirmation of deletion, as applicable. If, for any reason, we are unable to fulfill your request, we will notify you and provide an explanation.
Do Not Sell My Personal Information
Updates To This California Privacy Notice
We may change or update portions of this California Privacy Notice at any time. When we do, we will post the change(s) on the Site. Your continued use of the Site following the posting of changes to these terms means you accept these changes. Please check back from time to time so you are aware of any changes or updates to the notice. If we make any material changes, we will provide appropriate notice to you. We will indicate the notice’s effective date at the top of the notice.
How To Contact Us
If you have any questions about this California Privacy Notice, you can contact us at:
Primal Nutrition, LLC
200 E. Randolph St.
Chicago, IL 60601
Attention: Data Privacy Team
Call us at 1-855-634-1984 9 a.m. - 5 p.m. Eastern Time, Monday through Friday, excluding holidays.
E-mail us at USprivacy@kraftheinz.com. We would be happy to answer your questions or hear your concerns.