Privacy Policy

Effective Date: May 13, 2024

PrimaLoft, Inc. (“PrimaLoft,” “we,” “us” or “our”) recognizes the importance of protecting your privacy. The following privacy policy (“Privacy Policy”) is the way we handle information learned about you from your interactions with us, including visits to our website available at https://primaloft.com/ (the “Site”).

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. When you interact with us, including when you access or use the Site or submit information to or through the Site, you accept the terms of this Privacy Policy and our Terms of Use and consent to our collection, use, disclosure and retention of your information as described in this Privacy Policy.

1. Information Collected

a. Personal Information

PrimaLoft collects personal information from you, which may include the following:

  • Name
  • Email address
  • Geolocation through your IP address.

This information is collected and stored electronically when you download our brand guidelines (if you are one of our brand partners), and subscribe to our newsletter.

b. Information Collected Automatically

In addition, information about your computer hardware and software is automatically collected by PrimaLoft when you use the Site. This information may include:

  • IP address
  • Type of operating system
  • Browser type
  • Language preference
  • Access time and date
  • Device type
  • Referring website addresses
  • Browsing history
  • Geographic location
  • Other technical information such as protocol status and substatus, bytes sent and received, and server information.

We may also collect information regarding traffic patterns, the actions taken on our Site, including the user’s click-stream, and your interaction with our Site and advertisements. This information is used by us for our business purposes, including for the operation and improvement of the Site, for technical troubleshooting, to maintain the quality of the Site, to provide general statistics regarding use of the Site and to determine the effectiveness of our promotional campaigns.

We may also receive similar data from our business partners, including online advertising networks, and from social media platforms, such as Facebook, Instagram and LinkedIn, subject to your registration and privacy settings with such third-party social media platforms.

c. Cookies and Other Information Collection Tools

Cookies

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website or use the service again, the cookie allows that website or online service to recognize your browser or device. Cookies may store unique identifiers, user preferences and other information.

We may use “session cookies” or “persistent cookies.” Session cookies are temporary and expire once you close your browser or once your session ends. Persistent cookies remain on your device for much longer or until you or your browser erase them. Persistent cookies have varying durations that are dependent on their expiration date.

The types of cookies PrimaLoft may use on the Site include:

  • Necessary Cookies. These cookies are necessary for you to browse the Site and use its features, such as accessing secure areas of the Site. Without these cookies, certain aspects of the Site may not be available to you.
  • Preferences Cookies. These cookies collect information about how you have used the Site in the past and allow the Site to remember the choices you have made. These cookies allow us to improve how the Site works for you and tailor the Site to your preferences.
  • Statistics Cookies. These cookies collect information about how you use the Site, such as which pages you most often visit on the Site, the time you spend on the Site, which links you click on, and any issues encountered. These cookies help us understand how visitors interact with the Site. All information collected is aggregated and do not identify you.
  • Marketing Cookies. These cookies track your online activity to help deliver advertisements that are relevant to you and your interests and measure the effectiveness of the advertising campaigns. They also limit how many times you see a certain advertisement. We may share the information collected through these cookies with others, such as advertisers.

We may also use third-party cookies, like Google Analytics, for example, which sets cookies on the Site to help analyze how visitors use the Site. If you would like to opt-out from the use of your information by Google Analytics, you may use Google Analytics’ opt-out browser add-on designed for this purpose.

Cookies help us improve the Site by providing us with information about which parts of the Site are most popular, enabling us to analyze technical and navigational information about the Site, and helping us to detect and prevent fraud. We also use cookies and other data collection tools, such as pixels, to help improve your experience with the Site.

Web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Site. You may manage your cookie preferences on the Site by clicking here.

Web Beacons and Pixels

A pixel is an HTML code snippet embedded in a website or email that collects information about user behaviors and interactions with the website or email.

We may utilize pixels both on certain aspects of the Site and in HTML-formatted email messages to you. Pixels may be used for the purpose of, among other things, measuring the success of our marketing campaigns, compiling statistics about Site usage and tracking the activities of users of the Site and email recipients. For instance, we may use pixels from Meta and Google on the Site to enable us to create targeted advertisements and measure the effectiveness of our advertisements. For additional information on interest-based advertising, please see Section 2 (Interest-Based Advertising).

2. Interest Based Advertising

We may collect information about your online activities on our Site to provide you with advertising about products tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our advertisements are served.

You may see certain advertisements on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based and contextual means. These partners track your online activities over time and across websites, including our Site, by collecting information through automated means, including through the use of third-party cookies, web server logs and web beacons. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Site and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. For example, we utilize certain of our advertising partners’ targeted advertising services to show you our advertisements on other websites based on your prior visits to our Site and other online activity.

Provided that a company participates in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising, you may opt out of interest-based advertising generally through the Network Advertising Initiative website or by visiting http://www.aboutads.info/choices/ (web-based advertising) or http://www.aboutads.info/appchoices (for mobile advertising). To learn more, please visit the websites operated by the Network Advertising Initiative and Digital Advertising Alliance at www.networkadvertising.org/choices. Opting-out does not mean that you will stop receiving advertisements from us. It means that you still stop receiving advertisements from us that have been targeted to you based on your visits and browsing activity across websites over time.

3. How Information is Used

We may use the information we collect for any of the following purposes:

  • To provide the Site to you;
  • To fulfil your requests, such as to download our brand guidelines;
  • To give each user a more consistent and personalized experience when interacting with us;
  • Personalize our advertising and marketing communications, and to deliver promotions and offers to you that we think may be of interest to you both on the Site and on other websites;
  • To learn about your interest in our products;
  • If you sign up for our email list, to send you emails about products or offers that we think might be of interest to you;
  • For security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site;
  • To respond to your inquiries and communicate with you;
  • For our other business purposes, such as research, data analytics, audits, developing new products, enhancing our Site, improving our products and services, identifying Site usage trends, and determining the effectiveness of our promotional campaigns;
  • As we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Policy and our Terms of Use; (v) to protect our operations; (vi) to protect our rights, privacy, safety or property, and/or that of you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

4. Sharing of Information

We may disclose your information:

  • With Third Party Service Providers Performing Services on Our Behalf. We share your personal information with our service providers to perform the functions for which we engage them. For example, we may use third parties to host the Site or assist us in providing functionality on the Site, provide data analytics and research on the Site and send out emails about the Site and our products.
  • Through Tracking Technologies. We may share information collected through tracking technologies set on the Site with our website analytics and digital advertising service providers.
  • For Legal Purposes. We also may share information that we collect from users as needed to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose personal information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share personal information as required to pursue available remedies or limit damages we may sustain.
  • Changes of Control. We reserve the right to transfer or assign the information that we have collected from users in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

PrimaLoft does not share your personal information with third parties for those third parties’ direct marketing purposes.

5. Links to External Websites and Online Services

Our Site may contain links to third-party websites and online services. Any access to and use of such third-party websites or online services is not governed by this Privacy Policy but is instead governed by the privacy policies of those third-party websites or online services, and we are not responsible for the information practices of such third-party websites or online services.

6. Social Media

Some aspects of the Site may allow you to interface with social media, such as Facebook, Instagram and LinkedIn. We will attempt to identify these aspects of the Site to you, for example, by identifying them with the applicable third-party logos or trade names. By using these interfaces, you will allow us to access information about you from those other online services, including information and other content that you submit to those online services. If you interface with the Site through your social media account, we may contact you or enable you to share your experience and content via your social media account, which information may be publicly viewed by other users of those services. For a description on how such social media services and other third-party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.

7. Consent to Receive Communications

You may choose to stop receiving our marketing emails by following the unsubscribe instructions included in such emails or contacting us at primaloftbrand@primaloft.com.

8. Security Used & Retention of Personal Information

PrimaLoft uses reasonable security measures designed to prevent unauthorized intrusion to the Site and the alteration, acquisition or misuse of personal information. However, please note that no data transmission over the Internet or data storage system can be guaranteed to be 100% secure.

We will retain your personal information for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.

9. Do Not Track

Our Site does not currently take any action when it receives a Do Not Track request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not

interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.

10. Children

We do not knowingly collect or maintain personal information from any person under the age of 16. No parts of our Site are directed to or designed to attract anyone under the age of 16.

11. Nevada Residents

Under Nevada law, PrimaLoft does not sell your personal information. However, if you are a Nevada resident, you may submit a request that we not sell any personal information we have collected about you by contacting us as set forth below.

12. California Residents

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CPRA”) provides California residents with specific rights regarding their personal information. The below describes such rights and how you may exercise such rights, and our information practices, including the categories of personal information we collect, use, retain, disclose, sell or share, and how and why we collect, disclose, sell or share such information.

Consumer Rights
Right to Know

You have the right to request that we disclose what personal information we collect, use, disclose, sell or share. Specifically, you may request that we disclose to you the following:

1. The categories of personal information we have collected about you.

2. The categories of sources from which the personal information is collected.

3. The business or commercial purpose for collecting, selling or sharing personal information.

4. The categories of third parties with whom we disclose personal information.

5. The specific pieces of personal information we have collected about you.

You may also request that we disclose to you:

1. The categories of personal information that we have sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each third party to whom the personal information was sold or shared.

2. The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

Right to Request Deletion

You have the right to request that we delete any personal information about you which we have collected from you. If it is necessary for us to maintain your personal information for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.

Right to Opt-Out of Sale or Sharing of Personal Information

You have the right to direct a business that sells or shares personal information about you to third parties not to sell or share your personal information. We do not sell your personal information for monetary consideration. However, we do use cookies for targeted advertising purposes. The collection of data through certain cookies for our targeting advertising purposes may be considered a “sale” and is considered “sharing” under the CPRA. To opt-out of having your information sold and shared with third-party website analytics and digital advertising service providers for this purpose, visit our “Do Not Sell or Share My Personal Information” web page.

Right to Correct Inaccurate Personal Information

You have the right to request a business that maintains inaccurate personal information about you to correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to direct a business that collects sensitive personal information about you to limit its use of your sensitive personal information (1) to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; (2) for certain business purposes; and (3) as authorized by the implementing regulations of the CPRA . PrimaLoft does not collect any sensitive personal information.

No Discrimination

You have the right not to be discriminated against because you exercised any of your aforementioned rights.

How to Submit a Request

To exercise the rights described above, you must submit a verifiable request to us. You can do so by calling us at 513-313-1860 or by visiting https://primaloft.com/news-contact-us/.

To submit a verifiable request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the personal information that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors.

You may designate an authorized agent to make a request on your behalf by providing the agent with signed written permission to do so.

If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.

How we collect, use, disclose, sell and share personal information of consumers

PrimaLoft has collected the following categories of personal information and used, disclosed, sold or shared such information in the twelve (12) months prior to the effective date of this Privacy Policy:

  • Identifiers, such as name, unique personal identifier, online identifier, Internet Protocol address, email address or other similar identifiers.
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name.
  • Internet or other electronic network activity information, including, but not limited to, information regarding a consumer’s interaction with the Site or advertisement.
  • Geolocation data.

Each of the above categories are disclosed for a business or commercial purpose as described above in Section 3. (How Information is Used) to the third parties listed in Section 4. (Sharing of Information).

The following categories of personal information were sold or shared in the twelve (12) months prior to the effective date of this Privacy Policy:

  • Identifiers, such as unique personal identifier, online identifier, Internet Protocol address or other similar identifiers.
  • Internet or other electronic network activity information, including, but not limited to information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
  • Geolocation data.

Such information is sold to or shared with our third-party website analytics and digital advertising service providers.

We share or sell such information:

  • To provide the Site to you and to improve the Site;
  • To give each user a more consistent and personalized experience when interacting with us;
  • To personalize our advertising and marketing communications, and to deliver promotions and offers to you that we think may interest you;
  • For security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site;
  • For our business purposes, such as research, data analytics, audits, enhancing our Site, improving our products and services, identifying Site usage trends, and determining the effectiveness of our promotional campaigns;
  • As we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Policy and our Terms of Use; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

As stated previously, PrimaLoft does not collect sensitive personal information.

PrimaLoft collects the personal information described above from or through the following categories of sources:

  • You, directly and indirectly, including when you access the Site, download our brand guidelines (if you are one of our brand partners) or subscribe to our newsletter; and
  • Service providers, including those that provide analytics services to help us understand the activity on the Site.

PrimaLoft will retain the personal information described above for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.

Personal Information of Minors

PrimaLoft does not have actual knowledge that it sells or shares personal information about minors under the age of 16.

13. EU/UK/Switzerland Residents

With respect to “personal data” as defined by Regulation (EU) 2016/679 (“GDPR”), any national law of an EU member state adopted pursuant to the GDPR, the United Kingdom Data Protection Act of 2018, and the Switzerland Federal Act on Data Protection (collectively, “European Data Protection Laws”), we serve as the “controller” and are located at:

PrimaLoft, Inc.
19 British American Blvd E
Latham, NY 12110
United States

We collect personal data when you access and use the Site, when you download our brand guidelines (if you are one of our brand partners) and subscribe to our newsletter. We collect the following types of information and process and disclose such information in the following ways:

 

Categories of Personal Data Collected Purposes of Processing Legal Basis for Processing Categories of Recipients
Name, email address, IP address, type of operating system, browser type, language preference, access time and date, device type, referring website addresses, browsing history, geographic location, other technical information such as protocol status and substatus, bytes sent and received, and server information • To provide the Site to you;
• To fulfil your requests, such as to download our brand guidelines;
• To give each user a more consistent and personalized experience when interacting with us;
• Personalize our advertising and marketing communications, and to deliver promotions and offers to you that we think may be of interest to you;
• If you sign up for our email list, to send you emails about products or offers that we think might be of interest to you;
• For security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site;
• To respond to your inquiries and communicate with you;
• For our other business purposes, such as research, data analytics, audits, developing new products, enhancing our Site, improving our products and services, identifying Site usage trends, and determining the effectiveness of our promotional campaigns;
• As we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Policy and our Terms of Use; (v) to protect our operations; (vi) to protect our rights, privacy, safety or property, and/or that of you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.		 • Performance of Contract. We may use your information to perform our contractual services or prior to entering into an agreement with you. If you use the Site or if you become one of our brand partners, we may use your information to provide to you the features and functionality of the Site and our products.
• Legitimate Interest. We may use information for our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms. For instance, we may use your personal data to contact you and respond to your requests and inquiries, to administer our business including by creating statistical analyses, to identify prevent and detect fraud or to pursue or defend ourselves against legal claims.
• Consent. We may use your information with your consent. In these instances, we will ask you to grant us consent to use your information. You are free to grant or deny permission. If you deny permission, we will not be able to process your information to conduct the activity to which the consent relates. For example, we will not be able to send you marketing materials that you request. You are also free to withdraw your consent at any time. A withdrawal of consent will not affect processing that has been completed during the time in which the consent was valid. If you have granted us consent to use your information, we will use it only for the purposes specified when we request your consent. This includes use for our marketing campaigns. If you sign up for our newsletter, you allow us to use your email address for marketing related to our products. We will use your personal data to send you emails containing newsletters. You may unsubscribe from such emails at any time by following the unsubscribe instructions in such messages.
• Fulfillment of Legal Obligations. We may use your information to comply with our legal obligations. To comply with regulations, laws or any authority requests, we may disclose your information to authorities or other officials or otherwise process your information pursuant to legal obligations we are subject to (e.g., retain certain information according to tax or commercial laws, respond to your requests to exercise your rights under European Data Protection Laws).		 • With Third Party Service Providers Performing Services on Our Behalf. We share your personal information with our service providers to perform the functions for which we engage them. For example, we may use third parties to host the Site or assist us in providing functionality on the Site, provide data analytics and research on the Site and send out emails about the Site and our products.
• Through Tracking Technologies. We may share information collected through tracking technologies set on the Site with our website analytics and digital advertising service providers.
• For Legal Purposes. We also may share information that we collect from users as needed to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose personal information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share personal information as required to pursue available remedies or limit damages we may sustain.
• Changes of Control. We reserve the right to transfer or assign the information that we have collected from users in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
Name, social media handle • To learn about your interest in our products;
• To communicate with you.
E-mail address • If you sign up for our email list, to send you emails about products or offers that we think might be of interest to you;
•To reply to your comments on social media platforms.

 

Given the international nature of our business, personal data may be sent abroad and processed by companies located inside the European Union and third countries, solely for the aforementioned purposes. By using the Site, you consent to the transfer of your personal data to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country. In these cases, we transfer your personal data through the use of appropriate safeguards as required by European Data Protection Laws.

We will retain your information for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.

Under European Data Protection Laws, you have the following privacy rights, which you may exercise by contacting us at primaloftbrand@primaloft.com:

      • Right of Access. You have the right to obtain confirmation as to whether your personal data is being processed, as well as access to the personal data along with certain information, including the purposes of the processing, the categories of personal data concerned and the recipients or categories of recipients to whom the personal data have been or will be disclosed.
      • Right to Rectification. You have the right to rectify your inaccurate personal data and to complete any incomplete personal data, including by means of providing a supplementary statement.
      • Right to Erasure or Right to be Forgotten. You have the right to erase your personal data under certain circumstances.
      • Right to Restrict Processing. You have the right to restrict our processing of your personal data under certain circumstances.
      • Right to Object. You have right to object, on grounds relating to your particular situation, at any time to our processing of your personal data, which is based on public interest or our legitimate interests, including the profiling of data. In this case, we will stop processing your data, except for where we have compelling legal grounds for the processing which override your interests, rights and freedoms, or for the exercise or defense of possible legal claims. You also have a right to object to the processing of your personal data for direct marketing purposes.
      • Right to Data Portability. Under certain circumstances, you have the right to receive your personal data that you provided to us in a structured, commonly used and machine-readable format, and have the right to transmit such data to another controller without hindrance from us.
      • Right to Withdraw Consent. If you have provided us with your consent for the processing of your personal data, you may withdraw your consent at any time to stop any further processing.
      • Right to Lodge a Complaint. You have a right to lodge a complaint with a supervisory authority if you believe that our processing of your personal data violates the European Data Protection Laws.

14. Questions / Contact Us
If you have any questions regarding this Privacy Policy, please contact us at primaloftbrand@primaloft.com.

15. Notification of Changes
Any changes to our Privacy Policy will be posted to this page so users are always aware of the information we collect and how we use it. Accordingly, please refer back to this Privacy Policy frequently as it may change.

 

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