This policy was last modified on January 11th, 2023.

This privacy policy (this “Privacy Policy”) describes how we collect, use, and share data that we obtain through your use of the Internet sites, applications, email and newsletter communications, and online services (the “Site”) operated by, controlled by, or affiliated with Primary Goods Media LLC (d/b/a Primary Goods) and certain subsidiaries, affiliates, and entities that it controls, including Primary Goods Media LLC. (d/b/a Primary Goods) (collectively, “PG,” “we,” “us,” or “our”). If you are a resident of California or the European Union, please contact us directly at team@primarygoods.com for additional disclosures and information relating to your rights – some of which may be required by law.

1. COLLECTION OF DATA

We collect data from you in several different ways on the Site, including personal data and data about your use of the Site which does not identify you personally. Personal data means information, or combination of information, that can reasonably be used to identify you personally (such as your name, phone number, address, and email address).

We collect personal data that you voluntarily provide to us.

We collect personal data that you voluntarily provide to us (such as when you submit an inquiry), including name, email address, and any other data you choose to provide.

We automatically collect data about your use of the Site.

When you access and use the Site, our technology and tools may automatically collect and record certain data about your use of and interaction with the Site that does not identify you personally (such as your IP address, browser type, the make and model of device used to view the Site, unique device identifiers, the referring webpage, pages visited, search terms, advertising identification numbers, and log files).

We also use various tracking technologies (such as cookies and pixel tags) to collect data about your use of and access to the Site. Cookies are small data files stored on your hard drive or in device memory by websites you visit, applications you use, or advertisements you view and help us improve the Site and your experience on the Site. Pixel tags are electronic images that generate a generic notice of a visit to the Site and are used in conjunction with cookies to anonymously track activity on the Site by a particular browser.

We use the following types of cookies for the following purposes on the Site:

1. Strictly Necessary Cookies

   1. These cookies are necessary for the Site to function. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences or filling in forms. As described in Section 10, you may remove or reject cookies by adjusting settings on your browser. If you do not allow these cookies then the functionality of the Site may be affected. These cookies do not store any personal data.

2. Performance Cookies

   1. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of the Site. They help us to know which webpages are the most and least popular and see how visitors move around the Site. These cookies collect aggregated data that does not identify you personally. If you do not allow these cookies we will not know when you visited the Site and will not be able to monitor the Site’s performance.

3. Functional Cookies

   1. These cookies enable the Site to provide enhanced functionality and personalization by remembering certain preferences that you may select. They may be set by us or by third parties that provide services to us. If you do not allow these cookies then some or all of these services may not function properly.

4. Targeting Cookies

   1. These cookies may be set by our advertising partners to track your browsing habits in order to build a profile of your interests and show relevant advertisements to you on other websites. These cookies store data about your use of the Site, such as your browser type and device. If you do not allow these cookies, you will experience less targeted advertising.

5. Social Media Cookies

   1. These cookies may be set by social media services that enable you to share our content with your friends and networks. They are capable of tracking your browser across other websites and building up a profile of your interests. This may impact the content and messages you see on other websites. If you do not allow these cookies you may not be able to use or see these sharing tools.

2. USE OF COLLECTED DATA

We use the data we collect to assist in the administration and operation of the Site and to provide you an efficient, meaningful, and customized experience.
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We may use data to:

• Fulfill our obligations with respect to the reason you voluntarily provided the data (such as responding to an inquiry or provide you with information, products, or services that you request from us or that may be of interest to you);
• Allow you to participate in certain features of the Site;
• Improve the Site or our products, events, and services and for other business or commercial purposes;
• Optimize your experience on the Site (such as troubleshooting technical programs or storing your preferences)
• Provide co-branded services and features (such as contests, sweepstakes, or other promotions);
• Notify you about changes to the Site (including this Privacy Policy);
• Carry out any other purpose described to you at the time the data was collected; and
• Carry out any other purpose with your consent or as permitted by law.

Additionally, we may use data for marketing purposes to:

• Provide you with additional information regarding products, events, promotions, and services from Primary Goods and third-party advertisers via email or through advertising on various social media platforms or websites (both desktop and mobile) that you may visit;
• Deliver relevant advertisements from Primary Goods and third-party advertisers; and
• Develop, improve, and target our advertising and promotional messaging to you and others via retargeting, online behavioral advertising, and use of social media platform tools for advertising (such as creation of Facebook Lookalike Audiences).

You can learn more about Facebook ads HERE and other types of online advertising HERE.

3. THIRD-PARTY WEBSITES

Through your use of the Site, you may access, directly or indirectly, other websites or services, including from our service providers, business partners, and other third parties, in each case, that are not owned or controlled by us. Data collection and use by those third parties is subject to the privacy policies of those third parties. It is up to you to review the terms of use and privacy policies of those third parties.

Please note that when you apply for a job with us through our job application portal, the privacy policy of our job applicant processing partner may also apply to the submission of your application information.

4. SHARING OF COLLECTED DATA

We may share the data we collect as follows:

• With our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;
• With our service providers that perform services for us (such as e-mail and mobile marketing, analytics, and web hosting);
• With our sponsors, promotional partners, or event partners in connection with certain contests, sweepstakes, promotions, or ticketed events;
• With our third-party vendors and partners that sell items, offer promotions, or provide services to you through our services (either alone or jointly with us), as well as third-party advertisers, agencies, networks, ad measurement providers, and other marketing and advertising providers and partners;
• To comply with a court order or other legal obligation, to enforce the Site terms of use, and to protect the rights, property, or safety of our users and other third parties;
• With government or law enforcement officials or private parties (including our legal or other professional advisors) as we determine, in our sole and absolute discretion, is necessary or appropriate to respond to claims or to comply with legal processes, laws, regulations, or ordinances, or to prevent or stop illegal, unethical, or actionable activity;
• In connection with, or during negotiations of, any merger, acquisition by another company, or sale of all or substantially all of our business or assets; and
• With your consent or at your direction.

5. TRANSFER OF COLLECTED DATA

The Site is operated in the United States. If you are located in another jurisdiction, please be aware that the data we collect will be transferred to, stored, and processed in the United States. By using the Site and/or providing us with any data, you consent to this transfer, processing, and storage of your data in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen such as the European Union. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice. We will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards and ensure that your data is treated securely and in accordance with this Privacy Policy.

6. DATA SECURITY

We use commercially reasonable technical and organizational measures to help secure and safeguard your data in our possession. However, no data transmission over the Internet is completely secure and no security mechanism is impenetrable. Therefore, although we take steps to protect your data, we cannot guarantee the security of the data that we collect from you or the security of our servers or the Site. By accessing the Site, any transmission of data is at your own risk and you agree to assume all risk in connection with data sent to us or collected by us.

7. DATA RETENTION

We retain data only as long as necessary in light of the purpose(s) for which it was originally collected. Please note that we may retain your data for longer periods of time as necessary to comply with our legal obligations or respond to governmental authorities.

8. CHILDREN & PARENTS

We respect children’s privacy. We do not target or knowingly or intentionally collect personal data from children under the age of 18. By using the Site, you have represented and warranted that you are either at least 18 years of age or using the Site with the supervision of a parent or guardian. If you are under the age of 18, you may not use the Site. If you become aware that your child has provided us with personal data without your consent, please contact us immediately.

9. DO NOT TRACK (“DNT”) POLICY

Some websites have “do not track” features that allow you to tell a website not to track you. We do not currently respond to those signals or any similar mechanisms transmitted by web browsers. To learn more about DNT and tracking signals, please visit All About DNT.

10. YOUR DATA PREFERENCES

Please contact us immediately should any of the following circumstances arise:

• You no longer want us to use your collected data as described above;
• You no longer wish to receive communications from Primary Goods;
• You wish to receive instructions on how to remove, or block, certain cookies, pixel tags, or other similar tracking technologies;
• You wish to receive instructions on how you adjust your advertising preferences.

11. CONTACT US

If you have any questions about this Privacy Policy, please email us at team@primarygoods.com or write to us:
Office of the General Counsel – ℅ Primary Goods Media LLC
2810 North Church St. (#19454), Wilmington, DE 19802