Effective as of 02 March 2023
Welcome to PRIME'S Privacy Policy.
PRIME respects your privacy and is committed to protecting your personal information. This Privacy Policy is to provide you with the information required under the UK GDPR and the EU GDPR (General Data Protection Regulation) and informs you about how we use and look after your personal information (also referred to as personal data), including any information you may provide through this website and our store (our “Site”) or when you request information from PRIME or otherwise communicate with us, and when your personal information is provided to us relating to our business. This Policy also informs you about your privacy rights and how the law protects you. If you are not in the UK or the European Economic Area (EEA) you should view our Privacy Policy at https://drinkprime.uk/policies/privacy-policy.
PRIME Hydration UK Limited and PRIME Hydration, LLC are each independent controllers and responsible for your personal information (referred to as "PRIME", "we", "us" or "our" in this Privacy Policy). PRIME Hydration UK Limited is the controller of your personal data which it holds or uses, and PRIME Hydration LLC is the controller of your personal data which it holds and uses if you are in the UK or the EEA.
Our Compliance Officer is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (including any opt-out mentioned in this Privacy Policy), please contact the Compliance Officer using the details set out below.
Our full details are:
PRIME Hydration UK Limited
PRIME Hydration, LLC
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.
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The following outlines our privacy principles:
We will make readily available to customers information about our policies and practices relating to the management of personal information.
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:
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:
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:
The technologies we use for this automatic data collection may include:
Third Party Use of Cookies and other Tracking Technologies: Some content or applications, including advertisements, on the Site is served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different Sites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
For more information on our use of these technologies, see our Cookie Policy which explains how you can opt out of certain non-essential cookies.
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 [16] 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 contact@drinkprime.com.
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:
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.
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.
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.
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.
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.
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.
We may also send you marketing messages, to inform you about products and services (including those of others) that may be of interest to you. You can ask us to stop or start sending you marketing messages at any time by contacting us (see Contact Us at the beginning of this Privacy Policy) or by following the unsubscribe instructions in our marketing messages.
We may obtain consent to collect and use certain types of personal data when we are required to do so by law (for example, sometimes when we process sensitive personal data or when we place cookies or similar technologies on devices or browsers). If we ask for your consent to process your personal data, you may withdraw your consent at any time by following the unsubscribe instructions in our communications with you or by contacting us using the details set out in the Contact Us section at the beginning of this Privacy Policy or, if in relation to cookies or similar, as described in the Cookie Policy.
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:
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.
For more insight, you may also want to read Shopify’s Terms of Service (https://www.shopify.com/legal/terms) or Privacy Statement (https://www.shopify.com/legal/privacy). Once you leave our store’s website or are redirected to a third party website or application you are no longer governed by this Privacy Policy or our website terms of service.
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.
This website and our services 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 information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.
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.
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.
As described in this Privacy Policy, we may also share personal information relating to you with third parties who are located overseas, for business purposes and operational, support and continuity purposes, for example, when we use IT service providers or data storage services.
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:
You have the right to ask us for more information about our safeguards. Please contact the Compliance Officer (see the Contact Us section at the beginning of this Privacy Policy).
We may, from time to time, expand, reduce or sell our business, and this may involve the transfer of certain divisions or the whole business to other parties, such as through a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of PRIME’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Personal information relating to you will, where it is relevant to any division so transferred, be transferred along with that division to prospective buyers and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use personal information relating to you for the purposes.
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:
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:
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.
You have certain rights regarding your personal data. These include the rights to:
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/.
We review and amend our Privacy Policy from time to time. Any changes we make to this Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Policy. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the website.
