Effective as of 02 March 2023
Who we are
Our full details are:
- Name of legal entities:
Prime Hydration UK Limited
Prime Hydration, LLC
- Email address of the Compliance Officer: firstname.lastname@example.org
If you have a complaint relating to such information, please contact the Compliance Officer using the contact details above. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, prefer to deal with your concerns before you approach the ICO so please contact us in the first instance.
Our Privacy Principles:
The following outlines our privacy principles:
- Before or at the time of collecting personal information, we will identify the purposes for which information is being collected.
- We will collect and use personal information to fulfil the purposes specified by us and for other compatible purposes.
- We will only retain personal information as long as necessary for the fulfilment of those purposes.
- We will collect personal information by lawful and fair means and transparently.
- Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up to date.
- We will use reasonable efforts to protect personal information by appropriate security safeguards against loss or theft, as well as unauthorised access, disclosure, copying, use or modification.
We will make readily available to customers information about our policies and practices relating to the management of personal information.
1. Personal information we collect
We may obtain information from you directly. For example you may give us information when you buy products from us in our store at www.drinkprime.uk or when you contact us either directly or by filling in forms on our Site. The information collected will include the following:
- contact details (e.g. email address, postal address or telephone number)
- transactional details (e.g. products ordered, quantity, dates of order, payments you make, method of payment, any returns, shipping details).
- information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, posting material, or requesting further services. We may also ask you for information if you report a problem with our Site
- records and copies of your correspondence (including email addresses and phone calls), if you contact us
- your responses to surveys that we might ask you to complete for research
- your search queries on the Site
If you do not provide personal information that we request, it may mean that we are unable to provide you with the products or customer services you have requested.
You also may provide information to be published or displayed on public areas of the Site, or transmitted to other users of the Site or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorised persons.
We also collect personal information automatically when you use the website and when you navigate through the website. As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site
- Information about your computer and internet connection, including your IP address, operating system, and browser type and settings
We also may use these technologies to collect information about your online activities over time and across third party Sites or other online services (behavioural tracking). The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage
- Store information about your preferences, allowing us to customise our Site according to your individual requirements
- Speed up your searches.
- Recognize you when you return to our Site
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. Pages of our Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or and for other related Site statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).
If you give us personal data about other people (for example members of your family) then you confirm that they are aware of the information in this Policy about how we will use their personal data.
Our Site is not intended for children under  years of age. No one under age 16 may provide any information to or on the Site. We do not knowingly collect personal information from children under 16. If you are under 16, please do not use or provide any information on this Site. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at email@example.com.
2. How we use your personal information, and the legal basis for doing so
This section includes details of the purposes for which we use personal information and also the different legal grounds upon which we process that personal information. We use personal information to provide you with products you have bought and improve our services and for other purposes that are in our legitimate interests, as well as for compliance purposes. Further information is set out below.
We can only process your personal data on a basis permitted by law. The legal basis will usually be one of the following:
- to allow us to take actions that are necessary in order to provide you with our retail services (to perform our contract with you); for example, to despatch to you the products you have bought, through our fulfilment and delivery partners;
- necessary to allow us to comply with our legal obligations; for example, to respond to a court order;
- necessary for our or your legitimate interests; for example, to help us develop and improve our products and services (further details about this are set out below);
- where we have your consent to do so. We only ask for your consent in relation to specific uses of personal information where we need to and, if we need it, we will collect it separately and make it clear that we are asking for consent; or
- in the case of special categories of personal data, that it is in the substantial public interest.
Note that we may process your personal information on more than one lawful basis depending on the specific purpose for which we are using your information. You are welcome to contact us for further information on the legal grounds that we rely on in relation to any specific processing of your personal information.
Legitimate interests for use
We use personal information for a number of legitimate interests, including to provide and improve our products and services, administer our relationship with you and our business, for marketing and in order to exercise our rights and responsibilities. More detailed information about these legitimate interests is set out below.
- to provide technical and customer support and training and to improve our products, our website and our services to you
- to administer our relationship with you, our business and our third-party providers such as Shopify (e.g. to provide financial information or to provide you with information about your order)
- to personalise your experience with our services. If you leave our site with your shopping cart full, we may contact you later to suggest you complete the purchase. We may also retain your browsing and usage information to make your searches within our services more relevant and use those insights to target advertising to you online on our websites and apps. Your choices in relation to marketing are explained below.
- to deliver and suggest tailored content such as news about new products. We analyse the way you use our website to make suggestions to you for products or services that we believe you will also be interested in, and so that we can make our services more user-friendly
- to contact you in relation to, and conduct, surveys or polls you choose to take part in and to analyse the data collected for market research purposes
- to provide you with newsletters and other marketing as permitted by law
- to meet our internal and external audit requirements, including our information security obligations
- to enforce our terms and conditions
- to protect our rights, privacy, safety, networks, systems and property, or those of other persons
- for the prevention, detection or investigation of a crime or other breach of law or requirement, loss prevention or fraud
- to comply with requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, including where they are outside your country of residence
- in order to exercise our rights, and to defend ourselves from claims and to comply with laws and regulations that apply to us or third parties with whom we work in order to participate in, or be the subject of, any sale, merger, acquisition, restructure, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or shares.
Where we rely on legitimate interests as a lawful ground for processing your personal information, we balance those interests against your interests, fundamental rights and freedoms. For more information on how this balancing exercise has been carried out, please contact our Compliance Officer.
Special categories of data
We do not knowingly collect special categories of data (also known as sensitive personal data). Examples of these are data concerning health, ethnic or racial origin or religious beliefs. If we were to do so, we would do so on the basis that it was necessary for reasons of substantial public interest, to establish, exercise or defend any legal claims, or in some cases, with explicit consent. In any case, we would carry out the processing in accordance with applicable laws.
Automated Decision Making and Profiling
We do not analyse personal data in relation to our services in a way which involves profiling, which is processing your personal data using software that is able to evaluate your personal aspects and automatically predict risks, interests or outcomes.
We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
3. Messages to you (including marketing)
We may send you messages (by telephone, post, SMS text and email and other digital means) to help you track your orders and keep you informed about our terms and conditions and features of our website.
4. Disclosure of personal information
We will treat all your personal information as private and confidential (even when you are no longer a customer). We will not reveal your name, address or any details of your relationship with us to anyone, other than in the following cases:
- [Congo Brands, LLC] and affiliates in the United States for administrative, accounting and operational purposes.
- Our third party service providers. These may include for example:
- Shopify Inc., who host our store. They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall;
- those we engage to host and maintain the website and IT systems;
- analytics and search engine service providers that assist us in the improvement and optimisation of this website;
- those who assist us with or partner with us in marketing campaigns (eg Klaviyo);
- SMS/telephone provider.
- Third parties where we have a duty to or are permitted to disclose your personal information by law (e.g., government agencies, law enforcement, courts and other public authorities);
- Third parties where reasonably required to protect our rights, customers, systems and services (e.g. legal counsel and information security professionals).
Before we disclose personal information to a third party, we take steps to ensure that the third party will protect personal information in accordance with applicable privacy laws and in a manner consistent with this Policy. Where required by law third parties sign a data processing agreement with us. They are required to restrict their use of this personal information to the purpose for which the information was provided.
Sometimes the third party will be outside the UK, in which case see section 6 below for more information.
If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. [It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS).] Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.
All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard and American Express.
PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
Prime does not hold or have access to the payment information you provide to Shopify or its payment service providers, such as your credit card or bank account details, although we do have access to the method of payment and card issuer.
5. External links and social media sites
Communication, engagement and actions taken through external social media platforms are subject to the terms and conditions as well as the privacy policies of those social media platforms.
This website may use social sharing buttons which help share web content directly from our web pages to the social media platform in question. Where you use such social sharing buttons you do so at your own discretion. You should note that the social media platform may track and save your request to share a web page respectively through your social media platform account. Please note these social media platforms have their own privacy policies, and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these social media platforms.
6. Where we store personal information
If you live in the EU or the UK, the personal information relating to you that we collect may be transferred to, and stored at, locations outside the UK and the European Economic Area ("EEA"). It may also be processed by staff operating outside the UK and EEA who work for us or for one of our service providers. In particular personal data may be accessed by staff at our Prime company (and its parent company, Congo Brands) in the USA.
Countries where personal information relating to you may be stored and/or processed, or where recipients of personal information relating to you may be located, may have data protection laws which differ to the data protection laws in your country of residence. By submitting your personal data, you accept that personal data relating to you may be transferred, stored or processed in this way. We take measures to ensure that any international transfer of information is managed carefully and in accordance with data protection law to protect your rights and interests and in accordance with this Policy.
These measures include:
- Transfers of your personal information to countries which are recognised as providing an adequate level of legal protection for personal data;
- We have obtained the consent of data subjects to the international transfer of their personal data;
- Transfers to organisations where we are satisfied about their data privacy and security standards and protected by contractual commitments such as signing the Standard Contractual Clauses or International Data Transfer Agreements and, where available, further assurances such as certification schemes.
7. Changes of Business Ownership and Control
8. Security and data retention
The security of personal data received from or about you is a high priority. We take such steps as are reasonable securely to store personal data regarding you so that it is protected from unauthorised use or access, misuse, loss, modification or unauthorised disclosure. We only use third party service providers (such as Shopify) whom we are satisfied look after personal data securely and in accordance with privacy laws. This includes both physical and electronic security measures. Examples include:
- storing information on secured networks consistent with industry standards, which are only accessible by those employees who have special access rights to such systems;
- using industry-standard encryption technologies when transferring or receiving personal data, such as SSL technology;
- the use of two factor authentication on accounts with access to data;
- adherence to PCI standards by our payment service providers;
- restrictions are placed on the electronic transfer of files;
- our IT networks undergo regular necessary vulnerability testing to identify and remedy potential opportunities for unauthorised data access; and
- robust management of boundary firewalls, access controls, malware protection and patch release processes towards protecting customer data.
Retaining your information
We will only retain your personal information for a period of time that is calculated depending on the type of personal information, and the purposes for which we hold that information.
We will only retain information that enables us to:
- provide customer services in relation to orders that have been placed;
- maintain business records for analysis and/or audit purposes;
- comply with record retention requirements under the law;
- defend or bring any existing or potential legal claims;
- maintain records of anyone who does not want to receive marketing from us;
- deal with any future complaints regarding the services we have delivered or the products we have supplied;
- assist with fraud monitoring; or
- assess the effectiveness of marketing that we may have sent you.
Our policy is to ensure information is only held for the correct period. We then delete or de-identify your data. The retention period is generally linked to the amount of time available to bring a legal claim, which in many cases is six or seven years following a transaction. We will retain your personal data after this time if we are required to do so to comply with the law, if there are outstanding claims or complaints that will reasonably require your personal data to be retained, or for regulatory or technical reasons. If we do, we will continue to make sure your privacy is protected.
9. Your rights
You have certain rights regarding your personal data. These include the rights to:
- request a copy of the personal information we hold about you;
- request that we supply you (or a nominated third party) with an electronic copy of the personal information that you have provided us with;
- inform us of a correction to your personal information;
- exercise your right to restrict our use of your personal information;
- exercise your right to erase your personal information; or
- object to particular ways in which we are using your personal information (such as automated decision making, or profiling (for example to help us decide what products and services would suit you best); or
- understand the basis of international transfers of your information by us.
Where we rely on our legitimate interests to obtain and use your personal information then you have the right to object if you believe your fundamental rights and freedoms outweigh our legitimate interests. Where processing is carried out based upon your consent, you have the right to withdraw that consent.
Your ability to exercise these rights will depend on a number of factors and in some instances, we will not be able to comply with your request e.g. because we have legitimate grounds for not doing so or where the right does not apply to the particular information we hold on you.
You should note that if you exercise certain of these rights we may be unable to continue to provide some or all of our products or services to you (for example where the personal data is required by us to comply with a statutory requirement, or is necessary in order for us to perform our contract with you).
We ask that you contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.
Please contact the Compliance Officer if you wish to exercise any of your rights.
If you have a concern about the way we are collecting or using personal data relating to you, we request that you raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/.
10. Changes to this Policy