Primo Water North America Privacy Policy - California Addendum

Issue Date: June 29, 2023
Last Updated: June 26, 2023

Introduction

DS Services of America, Inc., dba Primo Water North America ("Primo," "we," us," or "our") values the privacy of our customers. This Privacy Policy Addendum for California Residents ("California Addendum") applies to residents of the state of California ("you," "your") and describes your rights and choices with respect to the processing of your personal information under the California Consumer Privacy Act, as supplemented and amended by the California Privacy Rights Act, and its implementing regulations (collectively, the "CCPA"). The California Addendum supplements our Privacy Policy and prevails over any conflicting stipulations in the main Privacy Policy.

To access the California Addendum in an alternative format, you may contact us using any of the methods in the "Contact Us" section below.

Scope and Applicability

This California Addendum applies only to personal information collected both online and offline about customers and business partners residing in California. This California Addendum uses certain terms that have the meaning given to them in the CCPA.

This California Addendum does not apply to:

• Job applicants - To learn more about our privacy practices related to personal information you provide us for recruiting purposes, please see our Job Applicant Privacy Policy.
• Primo Associates - Please contact your HR Manager to learn more about our privacy practices regarding the personal information of Primo Associates.
• Publicly available data lawfully made available from the state or federal government, or other information that is exempt under the CCPA.

Information We Collect, Use, and Disclose

Below is a brief description of the categories of personal information we collect, the purposes for which the categories of personal information are collected or used, and categories of third parties with which personal information is sold, shared, or disclosed for a business purpose. Please see our Privacy Policy for further detail about the personal information we collect about you.

If we collect a new category of personal information or process your information for a business purpose not listed below, we will provide you with an updated California Addendum. To learn about your information collection choices, see the"Your Choices and Rights" section below.

1. Categories of Information Collected

Primo collects (and may have collected during the 12-month period prior to the Last Updated date of this California Addendum) the following categories of personal information from customers:

• Identifiers, such as name and email address
• Characteristics of protected classifications, such as age and gender
• Commercial Information, including transaction history
• Financial Information, including credit card number or bank account number
• Internet or network activity, including browsing history on our websites
• Geolocation data
• Audio, electronic, visual, or similar information
• Professional or employment-related information
• Inferences drawn from other pieces of personal information

We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers.

Purpose of Collection and Use of Personal Information

We collect and use (and may have collected and used during the 12-month period prior to the Last Updated date of this California Addendum) personal information for the purposes described in our Privacy Policy and the following business purposes:

• Manage and fulfill orders, deliver products, process payments, and manage returns.
• Respond to requests for information and services.
• Provide quality customer care.
• Improve and develop new products and services, as well as secure our online environments.
• Protect the data of our company and our customers and secure our networks and online environments.
• Provide exclusive personalized advertisements, notices, and other information regarding our products and services, including notifying you about special promotions or surveys, in accordance with applicable law.
• Provide additional shopping features to account holders, such as message boards.
• Collect and use photos and videos (with consent) for marketing purposes.
• Determine your eligibility for, and to register you in, our contests and other promotions, fulfill and deliver prizes, and contact you regarding such contests or other promotions.
• Conduct research and analyze the use and effectiveness of our online environments, products, services, and advertisements to better our Invite you to participate in surveys.
• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services.
• Providing advertising and marketing services.
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.
• Short-term, transient use, such as non-personalized advertising shown as part of your current interaction with us.
• Helping to ensure security and integrity.
• Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them.
• Debugging to identify and repair errors.
• Undertaking internal research for technological development and demonstration.

2. Retention of Personal Information

We will retain your personal information for the time period reasonably necessary to achieve the purposes described in our Privacy Policy and this California Addendum, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.

3. Sources of Personal Information

• You directly
• Data analytics providers
• Internet service providers
• Advertising networks
• Operating systems and platforms
• Social networks
• Your employer, as part of a business-to-business customer relationship
• Data brokers

4. Disclosing and Selling/Sharing Personal Information

Categories of personal information have been disclosed (and may have been disclosed during the 12-month period prior to the Last Updated date of this California Addendum) to the following categories of third parties for business purposes:

In addition to the categories of third parties identified above, during the 12-month period prior to the Last Updated date of this California Addendum, we may have disclosed personal information about you to government entities and third parties in connection with corporate transactions, such as mergers, acquisitions or divestitures.

We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the Last Updated date of this California Addendum) the following categories of personal information about you to online advertising partners:

• Identifiers
• Internet or other electronic network activity information

We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.

Your Choices and Rights

Your Choices

California law enables you to make choices about how your personal information is used. Please note, failure to provide necessary personal information may restrict Primo services.

Your Rights

You have the following rights regarding your personal information:

• Right to Access - You have the right to request access and receive information about personal information we collect about you. This right includes the right to access specific pieces and categories of personal information we collected about you, categories of sources from which personal information was collected, purposes for which personal information was collected, shared, sold, or processed, categories of personal information we shared, sold or disclosed, and the categories of service providers, contractors, or third parties with whom we shared, sold or disclosed personal information. You have a right to receive this information in a structured, machine-readable format.
• Right to Correct - You have the right to request correction of your personal information, where it is inaccurate or incomplete.
• Right to Delete - You have the right to request that we delete your personal information under certain circumstances.
• Right to Opt Out of Sale or Sharing of Personal Information - You have the right, at any time, to direct Primo and its third parties not to sell or share your personal information for purposes of cross-context behavioral advertising.
• Right to Non-Discrimination - You have the right to not receive discriminatory treatment for exercising any of these rights. We will not treat you differently for exercising the rights described above. Please note that a legitimate denial of a request to access, delete, correct, or opt out of sale or sharing of personal information is not discriminatory, nor is charging a fee for excessive or repetitive requests, as permitted by the CCPA.

Exercising Your Rights

1. Identity Verification

To help protect your privacy and maintain security, we verify your identity before responding to access, deletion, or correction requests. To verify your identity to confirm that the personal information requested relates to you, we will ask for certain information, such as name, phone number, and delivery address. In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

We will respond to requests within 45 days of your request. If we need more time to process your request, we will notify you within the 45-day period and will respond to your initial request within 90 days from your original request. Your request and choices may be limited in certain cases; for example, if fulfilling your request is not permitted by law or if a relevant exception to your request applies.

You may have an authorized agent submit a request on your behalf by emailing us at the address provided below. If you wish to use an authorized agent, you must provide the party with written permission signed by you. We may deny a request from an authorized agent if the agent cannot provide your signed permission demonstrating that they have been authorized to act on your behalf.

2. Submitting a rights request

If you are a California resident and wish to exercise the above CCPA rights, please submit your request by:

• E-mailing our Customer Care Center at [email protected];
• Calling our Customer Care Center at 1-800-728-5508; or
• Writing to us at Primo Water:
  Attention Data Privacy Team 200 Eagles Landing Boulevard Lakeland, Florida 33810

You can opt out of the sale or sharing of your personal information by clicking on "Do Not Sell My Personal Information" or by broadcasting the Global Privacy Control signal. Requests sent using the Global Privacy Control will apply to the device and browser from which they are submitted. For more information about Global Privacy Control, please visit https://globalprivacycontrol.org.

Changes to this California Addendum

This California Addendum may be modified at any time and for any reason.

Contact Us

If you have any questions or comments about the California Addendum or the ways in which we use information subject to this policy, please do not hesitate to contact us by:

• E-mailing our Customer Care Center at [email protected];
• Calling our Customer Care Center at 1-800-728-5508; or
• Writing to us at Primo Water:
  Attention Data Privacy Team 200 Eagles Landing Boulevard Lakeland, Florida 33810