Privacy Policy
Last Updated: 02/26/2020
Welcome to Primrose, which is the trading name of Cercis Ltd. (“Primrose,” “we,” “us” or “our”). We take your privacy seriously. Because we do gather certain types of information from visitors to our sites, we have developed a Privacy Policy to help you understand the terms and conditions surrounding the collection and use of that information. This Privacy Policy discloses the types of information we gather, how it is used and shared, and how you can gain access to and edit any personal information that we've collected about you at any time. When we collect personal information from visitors, we will make every reasonable effort to avoid excessive or irrelevant collection of data. By using our sites and services (collectively, the “Services”), you acknowledge that you have read and understood the terms and conditions of this Privacy Policy. If you do not agree to the terms and conditions of this Privacy Policy, please do not use the Services.
IMPORTANT NOTICE: PLEASE NOTE THE ARBITRATION PROVISION SET FORTH BELOW, WHICH REQUIRES, EXCEPT WHERE AND TO THE EXTENT PROHIBITED BY LAW, YOU TO ARBITRATE ANY CLAIMS YOU MAY HAVE AGAINST PRIMROSE ON AN INDIVIDUAL BASIS. ARBITRATION ON AN INDIVIDUAL BASIS MEANS THAT YOU WILL NOT HAVE, AND YOU WAIVE, THE RIGHT FOR A JUDGE OR JURY TO DECIDE YOUR CLAIMS, AND THAT YOU MAY NOT PROCEED IN A CLASS OR CONSOLIDATED CAPACITY.
INFORMATION COLLECTED
“Personal information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. We may have collected the following categories of information from and about you in the preceding 12 months:
| Category of Personal Information | Source(s) | Purpose(s) | Disclosure to Third Parties |
| Identifiers |
Directly from you Indirectly from you (e.g., from observing your actions on our Services) From third party service providers, such as data analytics providers |
To fulfill or meet the reason you provided the information, e.g., to respond to an inquiry, process your order, or provide special offers For marketing purposes |
Disclosure for business purposes to: payment processors Disclosure for administrative purposes to: third party service providers, order fulfillment service providers, third party customer service providers Disclosure for security purposes to: card authorization and fraud screening services Disclosure for marketing purposes or to administer promotions: affiliates, strategic partners, agents, third party marketers |
| Personal Information categories contained in customer records | Directly from you | To fulfill or meet the reason you provided the information, e.g., to respond to an inquiry or process your order |
Disclosure for business purposes to: internet service providers, payment processors Disclosure for marketing purposes to: affiliates, joint marketing partners Disclosure for administrative purposes to: third party service providers, such as order fulfillment service providers, third party customer service providers Disclosure for security purposes to: card authorization and fraud screening services |
| Protected classification characteristics | Directly from you | To fulfill or meet the reason you provided the information, e.g., to provide targeted advertising | N/A |
| Commercial information | Directly from you | To fulfill or meet the reason you provided the information, e.g., to respond to an inquiry or process your order |
Disclosure for business purposes to: payment processors Disclosure for marketing purposes to: affiliates, joint marketing partners Disclosure for administrative purposes to: third party service providers, such as order fulfillment service providers, third party customer service providers Disclosure for security purposes to: card authorization and fraud screening services |
| Internet or other similar network activity |
Indirectly from you (e.g., from observing your actions on our Services) From third party service providers, such as data analytics providers |
To fulfill or meet the reason you provided the information, e.g., to provide targeted advertising, to deliver our webpages to you upon request To improve our services, e.g., to tailor our Services to the interests of our users, measure traffic within our Services For marketing purposes |
Disclosure for business purposes to: internet service providers Disclosure for security purposes to: fraud screening services Disclosure for marketing purposes to: affiliates, strategic partners, agents, third party marketers |
| Geolocation data |
Directly from you Indirectly from you (e.g., from observing your actions on our Services) |
To fulfill or meet the reason you provided the information, e.g., to respond to an inquiry, process your order, or provide targeted advertising | Disclosure for business purposes to: internet service providers |
| Inferences drawn from other personal information |
Indirectly from you (e.g., from observing your actions on our Services) From third party service providers, such as data analytics providers |
To fulfill or meet the reason you provided the information, e.g., to provide targeted advertising |
Disclosure for marketing purposes to: affiliates, joint marketing partners |
The following are additional explanations about our data collection that may be helpful to you.
USE & RETENTION OF INFORMATION COLLECTED
We use the information we collect from you for the following purposes:
We retain your information only for as long as necessary for the purpose for which it was collected.
DISCLOSURE OF PERSONAL INFORMATION
We collect and maintain the personal information of our consumers for our use. We do not disclose consumer information to third parties, other than as described below or with your consent.
Except as described in this Privacy Policy or at the time we request the information, we do not otherwise use, share or otherwise disclose your personal information to any third parties.
USE OF COOKIES
Cookies are small files placed on your hard drive that assist us in providing you with a customized browsing experience. We use cookies to provide you with the convenience of not having to reenter information multiple times during your visits to our sites. Cookies can also be utilized to help us provide you with information targeted to your interests, based upon your prior browsing on our sites. Different cookies are used to perform different functions, which we explain below:
The “help” section of the toolbar on most browsers will inform you on how to prevent your browser from accepting new cookies, how to have the browser notify you upon the receipt of a new cookie, or how to disable the use of cookies completely. As our sites have been designed to take advantage of the use of cookies, should you configure your browser to decline their use, certain features of our sites may not function correctly.
THIRD-PARTY ADVERTISING
We may use advertisers, third party ad networks and other advertising companies to serve advertisements on the Services. These third parties use cookies and other similar technologies to collect or receive information from our sites and elsewhere on the Internet and use that information to provide you with targeted ads. The Network Advertising Initiative offers a means to opt-out of a number of advertising cookies. Please visit www.networkadvertising.org to learn more. Note that opting-out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted-out will no longer deliver ads tailored to your preferences and usage patterns.
COLLECTION AND USE OF INFORMATION FROM CHILDREN
Our Services are not intended for children. We do not knowingly collect personal information from children, and none of our Services are designed to attract children. In the event that we learn that a person under the age of 13 has provided personal information to us, we will delete such personal information as soon as possible.
EXTERNAL LINKS
Our Services contain links to other sites. We are not responsible for the privacy practices or the content of such third party sites. To better protect your privacy, we recommend that you review the Privacy Policy of any third party site you visit.
SECURITY
We will take reasonable physical, electronic and managerial measures to safeguard and secure any personal information you provide to us. Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. If we learn of a security system breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services. We may post a notice via our Services if a security breach occurs. We may also send an e-mail to you at the e-mail address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
MARKETING OPT-OUT PROCEDURES
You may always opt-out of receiving future marketing communications from us. Users may opt-out of receiving such communications through the unsubscribe link provided in each communication. When you unsubscribe from certain marketing communications, you may be given the opportunity to unsubscribe from other marketing communications on an individual level.
Additionally, we may send you information regarding our Services, such as information about changes to our policies and other notices and disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature, rather than promotional.
YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits visitors to the Services who are California residents to request certain information, once a year, regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an e-mail at info@primrose.co.uk and put “Shine the Light Request” in the subject line of your e-mail.
If you are a California resident, from January 1, 2020 you may have the following additional rights:
If you would like to exercise one or more of the above rights, please contact us using the contact information provided below. You may also designate an authorized agent registered with the California Secretary of State to make a request on your behalf. The authorized agent must be registered by the California Secretary of State and must have written permission to submit requests on your behalf. Whenever feasible for verification, we will match the identifying information provided by you to the personal information already maintained by us. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information.
HOW WE RESPOND TO DO NOT TRACK SIGNALS
The “Do Not Track” (DNT) privacy preference is an option that may be made in your web browser allowing you to opt out of tracking by websites and online services. At this time, standard DNT technology is not yet finalized and not all browsers support DNT. We therefore do not recognize DNT signals and do not respond to them.
ASSIGNMENT
In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the personal information collected via the Services.
DISPUTE RESOLUTION AND AGREEMENT TO ARBITRATE
Except where and to the extent prohibited by law, by using the Services, you and Primrose agree that, if there is any controversy, claim, action, or dispute arising out of or related to your use of the Services or the breach, enforcement, interpretation, or validity of this Privacy Policy or any part of it (“Dispute”), both parties shall first try in good faith to settle such Dispute by providing written notice to the other party describing the facts and circumstances of the Dispute and allowing the receiving party thirty (30) days in which to respond to or settle the Dispute. Notice shall be sent to:
Both you and Primrose agree that this dispute resolution procedure is a condition precedent that must be satisfied before initiating any litigation or filing any claim against the other party. IF ANY DISPUTE CANNOT BE RESOLVED BY THE ABOVE DISPUTE RESOLUTION PROCEDURE, YOU AGREE THAT THE SOLE AND EXCLUSIVE JURISDICTION FOR SUCH DISPUTE WILL BE DECIDED BY BINDING ARBITRATION ON AN INDIVIDUAL BASIS. ARBITRATION ON AN INDIVIDUAL BASIS MEANS THAT YOU WILL NOT HAVE, AND YOU WAIVE, THE RIGHT FOR A JUDGE OR JURY TO DECIDE YOUR CLAIMS, AND THAT YOU MAY NOT PROCEED IN A CLASS OR CONSOLIDATED CAPACITY. Other rights that you and we would otherwise have in court will not be available or will be more limited in arbitration, including discovery and appeal rights. All such disputes shall be exclusively submitted to JAMS (www.jamsadr.com) for binding arbitration under its rules then in effect, before one arbitrator to be mutually agreed upon by both parties, in Iowa.
The arbitrator, and not any federal, state, or local court or agency, shall have exclusive authority to resolve any dispute arising under or relating to the interpretation, applicability, enforceability, or formation of this Privacy Policy, including any claim that all or any part of this Privacy Policy is void or voidable.
CHOICE OF LAW
This Privacy Policy has been made in and shall be construed in accordance with the laws of Iowa, without giving effect to any conflict of law principles. Any disputes or claims not subject to the arbitration provision discussed above shall be resolved by a court located in Iowa and you agree and submit to the exercise of personal jurisdiction of such courts for the purpose of litigating any such claim or action.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to change this Privacy Policy from time to time. When we do, we will also revise the “Last Updated” date above. If we make material changes to the Privacy Policy, we will notify you by placing a prominent notice on our Services and/or by sending you an e-mail at the e-mail address we have on file for you. We encourage you to periodically review this Privacy Policy to keep up to date on how we are handling your personal information.
CONTACTING US
If you have questions concerning this Privacy Policy or our privacy practices, please contact us:
Primrose