PRIVACY POLICY FOR PRIMAL PET GROUP

Effective January 10, 2023

PRIMAL PET GROUP, INC., A DELAWARE CORPORATION, WWW.PRIMALPETGROUP.COM
PRIMAL PET FOODS, INC., A CALIFORNIA CORPORATION, WWW.PRIMALPETFOODS.COM
PRAIRIE DOG PET PRODUCTS, LLC, A DELAWARE LIMITED LIABILITY COMPANY, WWW.PRAIRIEDOGPETPRODUCTS.COM
HIMALAYAN DOG CHEW, INC., A WASHINGTON CORPORATION, WWW.HIMALAYAN.PET
HOLISTIC HOUND, INC., A DELAWARE CORPORATION, WWW.HOLISTICHOUND.COM

SECTION 1 — SCOPE OF THIS POLICY

When posted, this Privacy Policy governs Primal Pet Group, Inc. and its affiliates’ respective collection and use of personal information on each’s website and from other identified sources. Primal Pet Group, Inc. is a Delaware corporation, www.primalpetgroup.com. Primal Pet Group, Inc.’s affiliates include Primal Pet Foods, Inc. (including its dba “Primal Pets”), which is a California corporation, www.primalpetfoods.com, Prairie Dog Pet Products, LLC, a Delaware limited liability company, www.prairiedogpetproducts.com, Himalayan Dog Chew, Inc., a Washington corporation, www.himalayan.pet, and Holistic Hound, Inc., a Delaware corporation, www.holistichound.com. In this Privacy Policy, each of Primal Pet Group, Inc. and its affiliates are referred to as “Primal” or a “Primal affiliate,” as may be applicable in the context. In this Privacy Policy, neither “Primal” nor “Primal affiliate” has a collective meaning.

Please note that each Primal affiliate is a separate company and a separate legal entity from each and all of the companies that are other Primal affiliates. When you access or use a Primal affiliate’s website or otherwise transact business with a Primal affiliate, you are transacting business with that specific company, not with any other Primal affiliate. No Primal affiliate is responsible or liable for any other Primal affiliate.

Further, the laws that may govern transactions with one Primal affiliate, including sales, consumer and privacy laws, may or may not be the same laws that would govern transactions with another Primal affiliate. The laws that may govern a specific transaction may also in some cases provide less protection than might otherwise be provided by this Privacy Policy. In such a case, your rights will be limited to those granted by law even if this Privacy Policy might appear to provide greater rights. No Primal website is currently intended for use by individuals or entities subject to the European Union General Data Protection Law.

For the avoidance of doubt, nothing in this Privacy Policy is intended to nor shall serve to, whether expressly or by implication, disclaim, release or otherwise abridge privacy rights or related remedies which cannot under any circumstances be disclaimed, released or abridged as a matter of the applicable law.

SECTION 2 — WHAT CATEGORIES OF PERSONAL INFORMATION (INCLUDING “SENSITIVE” PERSONAL INFORMATION) DOES PRIMAL COLLECT AND WHAT CATEGORIES OF INFORMATION SOURCES ARE UTILIZED?

When you have contact with a Primal affiliate regarding a purchase, services, information, or otherwise, whether by using a website, an app (if any), by email, text or other electronic means, by phone or in person, or otherwise, that Primal affiliate or a third-party (including third-party service providers) may collect your personal information, including “sensitive” personal information. Personal information, including “sensitive” personal information, may be collected across all electronic and non-electronic devices and platforms. Additionally, when you communicate with certain third-parties (including third-party service providers) such as a Primal affiliate’s online store or loyalty program operator, or retailers, those third-parties may also collect your personal information, including “sensitive” personal information. When you share personal information, including “sensitive” personal information, directly with such a third-party, a Primal affiliate may then access your personal information, including “sensitive” personal information, from that third-party.

The categories of personal information and “sensitive” personal information which a Primal affiliate or third-party (including third-party service providers) may collect include, without limitation:

Identifiers, Contact, Commercial and Financial Information: Such information may include your name, address, phone number, email address, delivery address, signature, physical characteristics or description, credit or debit card information, bank or payment and payment account and other financial information, security data, social media data, and the like.

Additional Personal Information: Such information may include photographs of and anecdotal and inferential information about you and your pet(s), including personal and demographic information which may reflect your sex, race, ethnicity, personal preferences, behavior and philosophical information, pet diet information and preferences, product use information, and the like.

Device and Technical Information: Such information may include computer or other device internet activity, internet protocol (IP) addresses, and operating system, web browser, cookie, beacon, and similar technical data, URLs, referring URLs, browsing history (including dates), search terms used, the history and manner of your use of Primal affiliate and third-party (including third-party service providers’) websites, data regarding your interactions with a Primal affiliate or a third-party (including third-party service providers), emails, texts, marketing information, geolocation data, and the like.

Public Source Information: Such information may include that which is available from public sources, including governmental sources, internet service providers, social media networks, data brokers, and the like.

Other Information You Provide a Primal Affiliate In Person or By Email, Texts, Written or Telephonic Communications: Such information may include any that you provide voluntarily to a Primal affiliate or a third-party (including third-party service providers).

SECTION 3 — WHAT IS PRIMAL’S PURPOSE IN COLLECTING YOUR PERSONAL INFORMATION (INCLUDING “SENSITIVE” PERSONAL INFORMATION), AND WHAT DOES PRIMAL DO WITH IT?

A Primal affiliate’s purpose in collecting your personal information, including “sensitive” personal information, is to use it to accomplish your purchase, service, informational, posting and other transactions, if any, including any deliveries, returns, credits or refunds, and where necessary to legally enforce Primal’s related rights.

A Primal affiliate may also use your personal information, including “sensitive” personal information, for things, if any, like product and warranty administration, marketing to you (including email, text and internet advertising and marketing) and marketing generally, including cross-context behavioral advertising and marketing, to administer loyalty program(s), for security purposes, for business operations (like fulfillment, accounting, inventory, product improvement, research, account management, and similar purposes) and analytics (like to determine and tabulate what is selling, to whom, where, and related business information), and for website analytics (like to assess website use and to improve website performance and experience).

A Primal affiliate retains your personal information for so long as may be required to accomplish such purposes and/or as may be required by law.

SECTION 4 — WHAT CATEGORIES OF PERSONS OR ENTITIES DOES PRIMAL SHARE (DISCLOSE) YOUR PERSONAL INFORMATION (INCLUDING “SENSITIVE” PERSONAL INFORMATION) WITH?; THIRD-PARTIES, INCLUDING THIRD-PARTY SERVICE PROVIDERS

In utilizing your personal information, including “sensitive” personal information, as described above, a Primal affiliate may share it with (i.e., disclose it to) third-parties (including third-party service providers), if any, such as other Primal affiliates, financial institutions and intermediaries including involved credit or debit card issuers and banks, private and public delivery services (including, potentially, the United States Postal Service), business support providers (including third-party service providers) of things like Domain Name Service and data storage and security services, online store services, loyalty program services, payment services, debt collection services, email marketing services, governmental entities including law enforcement agencies, and social media networks, without limitation.

Some third-parties, whether third-party service providers or not, may also share or sell your personal information subject to their own privacy policies. Primal is not responsible for third-parties’ privacy (including data sharing and selling) policies or practices. Also, remember that third-parties, whether third-party service providers or not, may be located in or have facilities that are located in a different jurisdiction than either you or a Primal affiliate. So, if you elect to proceed with a transaction, which may involve a third-party, then your personal information may become subject to the laws of the jurisdiction(s) in which that party or its facilities are located or which govern their activities.

If a Primal affiliate or third-party (including third-party service providers) is acquired or merged with another company, your personal information, including “sensitive” personal information, may be transferred to the new company so that it may continue to sell products and services, if any, to you.

Also remember that if you leave a Primal affiliate’s website or are redirected to a third-party website or application, you may no longer be governed by this Privacy Policy.

Primal affiliates do not sell your personal information. Primal affiliates do not share personal information, including “sensitive” personal information, for purposes other than those described in this Privacy Policy. Primal affiliates do not, as of the publication date of this Privacy Policy, have actual knowledge of the collection, sale or sharing of personal information, including “sensitive” personal information, belonging to minors. Primal affiliates do not knowingly service persons under 18 years of age.

SECTION 5 — DISCLOSURES REQUIRED OR ALLOWED BY LAW

Primal affiliates may disclose your personal information, including sensitive personal information, as required or allowed by law.

SECTION 6 — CONSENT & WITHDRAWAL OF CONSENT & USE LIMITATIONS; CONSUMERS’ RIGHTS TO REQUEST PERSONAL INFORMATION (INCLUDING “SENSITIVE” PERSONAL INFORMATION) OR TO CHANGE, DELETE OR LIMIT THE DISCLOSURE OF PERSONAL INFORMATION; HOW TO CONTACT PRIMAL TO DO SO

When you provide a Primal affiliate or a third-party (including third-party service providers) with personal information, including “sensitive” personal information, Primal infers that you consent to its collection and use for the purpose at issue and that you are directing Primal or a third-party (including third-party service providers) to do so. If a Primal affiliate or a third-party asks for your personal information, including “sensitive” personal information, for a secondary reason, like direct marketing to you, the Primal affiliate will either ask you directly for your express consent or provide you with an opportunity to decline to participate. For example, you may unsubscribe from Primal affiliate emails or texts at any time by clicking on a link provided in such emails or by responding as requested in such texts.

DELAWARE ADDENDUM: Under Delaware law, only to the extent that it may be applicable, website users have the right to review and request that a Primal affiliate change or delete certain personal information collected.

CALIFORNIA ADDENDUM: Under California law, only to the extent that it may be applicable, consumers (or their authorized agents) have several rights related to their personal information, including “sensitive” personal information. These include:

(i) the right to opt-out of a Primal affiliate’s sale (if any) or sharing of certain personal information;

(ii) the right to limit a Primal affiliate’s use of certain “sensitive” personal information;

(iii) the right to know what personal information, including “sensitive” personal information, by category, by source and by item, a Primal affiliate may collect and who it is sold to (if anyone) or shared with;

(iv) the right to know what purposes a Primal affiliate may use personal information, including “sensitive” personal information, for; and

(v) the right to change, correct, delete and receive copies of personal information, including “sensitive” personal information.

Certain restrictions may apply to any such requests. Any such requests must be verifiable as being made by the actual individual (or household) in question (or by an authorized agent). Any verified request for action regarding your personal information, including “sensitive” personal information, shall also be shared with applicable third-parties (including third-party service providers), if any.

Also under California law, only to the extent that it may be applicable, you must also agree in advance (“opt-in”) to a Primal affiliate’s collection, use and disclosure of personal information, including “sensitive” personal information, obtained specifically for any financial incentive given to you in exchange and you also have the right to withdraw your consent to a Primal affiliate’s use of your personal information, including “sensitive” personal information, specifically given in exchange for any financial incentives at any time.

Also under California law, only to the extent that it may be applicable, consumers have the right not to be discriminated against based on the exercise of any of their privacy rights or choices.

To provide or withdraw consent to any service or action (i.e., to “opt-in” or “opt-out”), to stop or limit the sale (if any), sharing or use of personal information, including “sensitive” personal information, to ascertain what categories of personal information, including “sensitive” personal information, a Primal affiliate may have, what purposes it is used for, and what categories or persons or entities with whom a Primal affiliate may have sold (if at all) or shared such information with, to obtain items of personal information, or to request that a Primal affiliate change, correct or delete personal information, including “sensitive” personal information, please email your request to the Primal Privacy Compliance Officer through this link hello@primalpetgroup.com or contact the relevant Primal affiliate by telephone at (866) 566-4652. The involved Primal affiliate will respond within 10 days and strive to resolve all requests within 45 days.

To protect you and all customers, and as indicated above, a Primal affiliate will have to verify your identity (and any agent’s identity and authority) before disclosing, changing, ceasing or limiting the disclosure of or deleting any personal information, including “sensitive” personal information. Generally, this may be done using information the involved Primal affiliate already has, from public information and/or by asking you for verifying information including unique identifiers and two-factor identifying information. A Primal affiliate may also require written and signed consumer authorization or a legal power of attorney in the event of an agent request.

SECTION 7 — SECURITY

Primal takes commercially reasonable precautions to help protect personal information, including “sensitive” personal information, from inappropriate destruction, loss, access, disclosure or misuse. Please note that Primal does not believe that any method of transmission over the internet or of electronic storage is 100% secure and so cautions you so that you may make more informed privacy choices.

SECTION 8 — COOKIES

Primal affiliates or third-parties (including third-party service providers) may use cookies in connection with Primal affiliates’ websites. The cookies that Primal affiliates use or understand are used in connection with their websites are, generally, used for purposes such as user and session identification, session data storage (e.g., referrer, landing page), token identification, login, password security, payment security, website site security, number of visits, cart information, purchase transactions, website, session and purchase analytics, embedded video view tracking, ad tracking across time and platforms, and geolocation. Primal affiliates disclose cookie use in connection with their websites to help you choose if you want to block cookies or use similar “do not track” type settings, or not. Again, Primal is not responsible for third-party privacy policies or practices.

SECTION 9 — AGE OF CONSENT

By using this website, you represent that you are at least 18 years old.

SECTION 10 — CHANGES TO THIS PRIVACY POLICY

Primal affiliates reserve the right to modify this Privacy Policy at any time, so please review it frequently. Changes will be posted on Primal affiliate websites and will take effect immediately upon their posting. Changes to the policy effective date typically mean that the policy terms have changed.

SECTION 11 — QUESTIONS AND CONTACT INFORMATION

If you have any questions about this Privacy Policy, please contact the Privacy Compliance Officer at hello@primalpetgroup.com or by telephone at (866) 566-4652.