Primal Palate provides this Privacy Notice to inform you of our policies and procedures regarding the collection, use and disclosure of your Personal Data and other data when you use our Services. For purposes of the European General Data Protection Regulation No. 679/2016 (“GDPR“) and similar data protection laws, Primal Palate processes your Personal Data as a data controller. This Privacy Notice is not a contract and does not create any legal rights or obligations. If you are a California resident, see the section “California Residents: Your California Privacy Rights” for information provided pursuant to the California Consumer Privacy Act.
As used in this Privacy Notice, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis, and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.
- Information Collection and Use
Our primary goals in collecting information are to provide and improve our Services and to enable our users to enjoy, use, and easily navigate our Services. To provide you with a consistent user experience and to recognize you as a user across our Services, we may collect and combine data as described below; for example, data collected when you visit the Site or the App from one browser or device may be combined or linked with data collected when you visit the Site or App from a different browser or device, which may also be combined or linked with product usage data.
Generally, we collect two types of information: Personal Data and Other Information. “Personal Data” is information that can be used to identify or is reasonably linkable to you as an individual, and may include Usage Information (as defined below). “Other Information” is information that is not linkable to you as an identifiable individual, including information that has been de-identified or aggregated with data from other users.
Personal Data we may collect. When you use the Services, we may collect the following Personal Data:
- Your contact information, such as your first and last name, email address, mailing address, and phone number;
- Your billing information, such as your credit card number and billing address;
- Your Primal Palate account information, including your user name, account number, and your encrypted Primal Palate password;
- Product, ownership, and service information about your kitchen appliances and accessories, including those that are manufactured by Primal Palate as well as any that are capable of working with the Primal Palate app (for example, if you use the App to remotely control a kitchen appliance, we will collect information from the appliance manufacturer that we need to make the App work);
- Information you voluntarily provide about yourself, such as allergies, dietary restrictions, food preferences, and groceries that you want to purchase;
- Your preferences, such as product wish lists, food and recipe preferences, kitchen appliance or accessory preferences, order history, and marketing preferences;
- Your user content (including video and images) you provide to use certain features, including recipes you submit, and information you provide so that we can help you manage your grocery inventory (such as photographs or video you provide to facilitate ingredient recognition features);
- Your Usage Information, as described further below; and
- Your mobile device model and ID number, user settings, location (if you enable this feature), and information about your use of the App when applicable.
Your Personal Data is processed only to the extent necessary to pursue the purposes set out in this Privacy Notice. To learn about how long Primal Palate keeps your Personal Data, see Section 3, Data Retention.
Many of our services and features require some Personal Data. If you choose not to provide the necessary Personal Data, you may not be able to use certain services or features. If you choose not to share your Personal Data, features that require personalization will not work for you.
Data From Others. Other parties may provide us with Personal Data. For example, if you create a Primal Palate account using your login from an other party’s service (including a social media network such as Facebook), we will access and collect the information about you that your privacy settings on that service permit so that we can create an account for you.
Use of Personal Data. We use your Personal Data to provide our Services and administer your inquiries. For example, when you create an account through the Services and become a Registered User or when you choose to create your own profile, we may ask you for Personal Data so we can create your account or populate your profile (see “Registered Users” below). We may also use your Personal Data to update our Services or features, troubleshoot, protect our Sites, Apps, and users, or provide support to you.
We also use your Personal Data to improve and develop our products and services, personalize our products, make recommendations to you, and send you relevant offers. We may also use your Personal Data to send you Primal Palate newsletters, marketing or promotional materials, or other information that may be of interest to you. Where required by applicable law, we will obtain your consent to send you these communications. If you decide at any time that you no longer wish to receive them, please follow the unsubscribe instructions provided in any of the communications or update your user preferences information.
Registered Users. Once you become a Registered User, you will be able to create a profile page by submitting certain Personal Data. The profile page may be viewable by other Primal Palate users and will display your profile name as well as your profile picture, if you choose to upload one or agree to allow a Third-party service (like Facebook) to provide one for you. You can choose what other Personal Data you provide as part of your profile. Providing such information is voluntary and should correlate with the degree of interaction you want to have with Primal Palate and its users.
Other Information. Other Information will be considered Personal Data if it is combined with other data in such a way that enables you to be identified. However, where Other Information is taken alone or combined only with other non-identifying information, it will not be treated as Personal Data. We may use Other Information for any purpose, unless prohibited by law.
We may combine your Personal Data with Other Information and aggregate it with information collected from other users to attempt to provide you with a better experience, to improve the quality and value of the Services and to analyze and understand how our Services are used. We may also use the combined information without aggregating it to serve you specifically – for instance, to deliver information to you according to your preferences or restrictions.
Usage Information. When you visit or use the Services or use a Primal Palate website, our servers automatically record information that your browser or mobile device sends or transmits (“Usage Information”). This Usage Information may include information such as your computer’s Internet Protocol (IP) address, browser type or the webpage you were visiting before you came to our Site, pages of our Site or the App that you visit (or of the site you visited that had the Primal Palate feature), the time spent on those pages, information you search for, access times and dates, the model and device ID number of your mobile device, user settings, location (if you enable this feature), and statistics and information about your use of the Site and App. We use this information to provide and improve the Services, develop new products, and offer products and services that may be of interest to you. We also use Usage Information to monitor and analyze use of the Services, for technical administration, to secure the Site and App and protect those who visit the Site or App, to improve functionality and user-friendliness, and to better tailor our Services to our visitors’ needs. For example, some of this information is collected so that when you revisit the Services, we will recognize you and can serve advertisements and other information appropriate to your interests. Some of the Usage Information (like your IP address) is treated as Personal Data.
We also use other parties (including Google Analytics) to provide usage analytics for our Services. These other parties will place their own cookies to collect traffic and activity data in order to deliver us relevant metrics and information. The collection of this data by these other parties is subject to their own privacy notices.
- Legal Basis for Processing
Below is an explanation of the different legal grounds we have for processing your Personal Data:
- To satisfy our contractual obligations to you. For example: allowing you to register for an account; providing the Services to you; assisting you with pairing a kitchen appliance or accessory through the Services; and fulfilling your product orders and providing additional services (for example, delivery, after-sale services, and the management of returns).
- With your consent. For example: processing health information, such as information about your allergies, so that we can customize our recommendations for you; processing your entry into a prize promotion/competition; sending you customized marketing communications related to our products and services electronically (including email, notifications from other party’s services, and notifications from mobile applications); and sharing your Personal Data with our selected trusted partners to help us send customized marketing communications with your consent.
- When we have a legitimate business interest to do so. For example: managing the requests for information you send us, including handling complaints; preventing fraud; enforcing our rights before the courts; improving the performance and security of our products and our Services, including the App and the Site; sending you customer care communications concerning products or services you have used or which you showed interest in, and in order to carry out customer satisfaction surveys; unless you opt-out, contacting you for marketing purposes by phone (non-automated) and via paper mail; and carrying out activities useful for the transfers of business and business branches, takeovers, mergers, demergers or other transformations and for the execution of such transactions.
- For legal obligations. We may also use your Personal Data to the extent necessary to comply with our legal obligations.
If you do not want Primal Palate to use your electronic contact details for marketing purposes, you can always follow the instructions to “unsubscribe” in our emails; or in accordance with Section 14 of this Privacy Notice below.
- Data Retention
Primal Palate will process your Personal Data for as long as it is necessary to achieve the purposes described above. If you delete your account we have processes designed to delete or de-identify your Personal Data. If you do not use your account or receive emails from us for an extended period of time, we have processes designed to delete or de-identify your Personal Data.
Keep in mind that we will retain information to comply with the law, prevent fraud and protect Primal Palate, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our agreements, and take other actions permitted by law.
- Information Shared with Others
We only share your Personal Data as described in this Privacy Notice. Through the Services, you are able to share your Personal Data when you share something through our Service, when you give us your consent to do so (like when we notify you that the information you provide will be shared in a particular manner and you provide us with such information), when you share Personal Data with another party service (if you allow such sharing), or when you share Personal Data with your friends with whom you want to connect (according to the preferences you have set in your account).
We may share Other Information, such as de-identified data, with other parties.
Your Personal Data is shared with Primal Palate and with:
Other Users. When you post comments or content (such as reviews or recipes) on any Primal Palate message boards or blogs, or when you use other interactive features (such as when you connect with friends) made available through or in connection with the Services, any data you choose to include will be accessible to other users. We urge you to be very careful when deciding to make any of your Personal Data, or any Other Information, publicly available through the Services. If you choose to use any social network features such as the Facebook “Like” button and other widgets, such as a “share” button or interactive mini-programs that we may offer through the Services, these features may collect your IP address and information about which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by another party or hosted directly on our Website. Your interactions with these features are governed by the privacy statements of the companies and social media networks providing them.
Service Providers. We may share any of your data with companies and individuals we engage to facilitate our Services, to provide services to us or on our behalf, to perform related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of our features) or to assist us in analyzing how our Services are used. We also share information about your use of Primal Palate products that does not personally identify you with service providers that store this information to improve the Services.
Compliance with Laws and Law Enforcement. In certain situations, Primal Palate may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Primal Palate cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Primal Palate, or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
- International Transfers
The Services are offered globally so it is necessary to transfer your information internationally. In particular, your information will be transferred to and processed in the United States where Primal Palate and our servers are located. The data protection and other laws of other countries, such as the United States, may not be as comprehensive as those in your country. The processing activities performed by Primal Palate may be regulated by data protection laws in your own country, in addition to U.S. privacy laws. We rely on legal bases to lawfully transfer Personal Data internationally, including your consent and EU Commission approved model contractual clauses (which require certain privacy and security protections)
- Managing Your Data
We give you options to help you understand what Personal Data we use and to request that we change how we use it. At any time, you may contact us to:
- be informed on the purposes and methods of the processing of your Personal Data;
- ask for access to your Personal Data (commonly known as making a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you;
- ask for updating or rectification of the Personal Data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
- request erasure of your Personal Data. This enables you to ask us to delete or remove your Personal Data where there is no good reason for us continuing to process it. You can also ask us to delete or remove your Personal Data where you have successfully objected to processing or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for reasons which will be communicated to you, if applicable, at the time of your request;
- restrict the processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where you allege that our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
- object to the processing, wholly or partly, of your Personal Data where we are relying on legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
- where we are relying on consent to process your Personal Data, you can revoke the consent to the processing of your Personal Data freely and at any time, and also opt-out of marketing communications by clicking on the unsubscribe option at the bottom of our marketing communications; or
- make your Personal Data available to you or to a different provider in some circumstances. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that Personal Data we process based on our legitimate interests (or those of a third party) may not be portable.
If you wish to manage your data as described above, or raise any questions about the Personal Data we hold about you, please contact us using the contact information below.
There is generally no charge for you to exercise any of the data management options described in this section, but we may charge a reasonable fee if you make excessive or unfounded requests. In some cases, depending on where you live, you have the right to lodge a complaint in front of the competent national data protection or judicial authority if you object to how we use your Personal Data.
- Your California Privacy Rights
If you are a California resident, California’s Shine the Light law permits you to request and receive information about disclosure of certain of your personal information to other parties for their direct marketing purposes. It is our policy not to share such personal information with unaffiliated parties for their own direct marketing purposes without your consent.
California residents also have the right to make the following requests. We will not discriminate against you because you exercise any of these rights.
- Access – You can request that we disclose to you the categories of Personal Data we collected about you, the categories of sources from which we collected the Personal Data, the categories of Personal Data we sold or disclosed, our business or commercial purpose for collecting and selling your Personal Data, the categories of third parties with whom we shared your Personal Data, and the specific pieces of Personal Data we collected about you over the past 12 months.
- Deletion – You can request that we delete your Personal Data that we maintain about you as described in Section 7 above, subject to certain exceptions.
- Opt-out – You can request to opt-out of the sale of your Personal Data by clicking the Do Not Sell My Personal Information link that may be available in the footer of our website, or by contacting us. For purposes of this Privacy Notice, “sell” means the transfer of your Personal Data to a third party for monetary or other valuable consideration, subject to certain exceptions set forth in applicable California law.
California residents can make an access or deletion request by contacting us.
We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps may vary depending on the sensitivity of the Personal Data and whether you have an account with us. If you designate an authorized agent to make a request on your behalf please ensure the authorized agent is identified as your authorized agent.
We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain Personal Data as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. Except as otherwise provided by the California Consumer Privacy Act, note that for purposes of this section, Personal Data does not include information about job applicants, employees and other of our personnel or information about employees and other representatives of third-party entities we may interact with.
We may collect California residents’ Personal Data, like contact information, in connection with a financial incentive, such as a discount, special pricing or other promotional offer. Our offers and incentives generally reflect the value of the relationships that we have with the individuals who participate in these programs. Participation in these programs is voluntary and you may withdraw at any time by electing not to participate or contacting us using the information in the “Contact Us” section of this Privacy Notice.
We also want California residents to know the following regarding our data collection, use, and disclosure of Personal Data in the past twelve months:
- We collect and use the following categories of Personal Data for the business and commercial purposes described in this Privacy Notice: Identifiers; contact and payment information; characteristics of protected classifications under California or federal law; commercial information; internet or other electronic network activity information; geolocation data; audio, electronic or visual information; and inferences.
- We collect and use these categories of Personal Data for the business and commercial purposes described in Section 1 of this Privacy Notice.
- We collect these categories of Personal Data from the sources described in Section 1 of this Privacy Notice.
- We disclose each of these categories of Personal Data for our business and commercial purposes as described in this Privacy Notice to the categories of parties described in Section 4 of this Privacy Notice.
- Interest-Based Advertising/Your Choices
As described above, we and other parties we do business with (including advertisers on the Site), may place or recognize unique cookies or other technologies on your browser or device when you visit the Site or use the App. In addition to the uses above, these technologies enable the collection of information about online activities over time and across different websites and apps, which can be used to customize advertisements to you as you browse the Internet. In accordance with the Digital Advertising Alliance (DAA) Self-Regulatory Principles for Online Behavioral Advertising, you can opt-out of having information regarding your online behavior collected and used for advertising purposes. To learn more about interest-based advertising, or to opt out for your web browser, please visit optout.aboutads.info or optout.networkadvertising.org; to opt out for mobile apps, please visit aboutads.info/appchoices.
Primal Palate is concerned with safeguarding your information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access; however, despite these efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us.
- Links to Other Sites
Our Services may contain links to other websites, apps, and platforms. If you click on an ad or another third party link, you will be directed to that third party’s website, app, or platform. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Data from you. Other sites follow different rules regarding the use or disclosure of the Personal Data you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit. This Privacy Notice does not address, and we are not responsible for, the privacy, information or other practices of any other parties.
- Our Policy Toward Children
Our Service is not directed to children and we do not knowingly collect personally identifiable information from children under 16. If we become aware that we have collected Personal Data from a child under 16 (or any other age specified by applicable law), we will take steps to delete such information from our files as soon as possible.
- Amendments and Updates
We may occasionally update this Privacy Notice. Please review the Effective Date at the top of this page to see when this Privacy Notice was last revised. If we make any material changes we will notify you as required by law, which may include by email (sent to the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Your use of the Services following these changes means that you accept the revised Privacy Notice.
- Contact Us
If you have any questions about this Privacy Notice, please contact us via email at info@Primal Palate.com, or please write to us at the following address:
Chief Data Officer
1300 Freeport Road Pittsburgh, PA 15238