PRIVACY POLICY

This Privacy Policy describes how PRIMALON LTD ("Primalon," "we," "us," "our") collects, uses, and discloses personal information when you visit, interact with, or make a purchase from primalon.co (the "Site"), communicate with us, or otherwise use our services (collectively, the "Services").

Contact us:

Email: support@primalon.co
Mailing address: 17595 Harvard Avenue, Suite C - 10211, Irvine, CA 92614, United States
Subject line for privacy requests: "Privacy Request"

Wellness product disclaimer

Our red light therapy products are intended for general wellness use only. They are not intended to diagnose, treat, cure, or prevent any disease. We are not a healthcare provider, and we are not a HIPAA-covered entity. Information you share with our customer support team about health conditions, symptoms, or medical history is treated as customer support information - not as protected health information under HIPAA.

Please consult your physician before using our products if you have any medical condition, are pregnant, have a pacemaker or other implanted device, take photosensitizing medication, or have any concerns about light therapy.

1) Key points

We collect information to process orders, provide customer support, and improve the Site.
We use analytics and advertising tools, including Google Analytics, Google Ads, Meta (Facebook/Instagram) Pixel, and TikTok Pixel, to understand performance and show relevant ads.
We use Klaviyo for email and SMS marketing - only when you opt in. You can opt out at any time.
We may share information with service providers (Shopify, payment processors, shipping carriers, analytics/ad partners).
Some U.S. state privacy laws define certain advertising-related disclosures as a "sale" or "share." You have the right to opt out (see Section 9).
We do not use health-related information you share with us to target advertising.
We do not knowingly collect personal information from children under 13.

2) Personal information we collect

We collect personal information in three main ways: (A) information you provide, (B) information collected automatically, and (C) information from third parties.

A) Information you provide to us

Contact information: name, email, phone number
Order information: billing address, shipping address, purchase history, products purchased, order notes
Account information: login credentials if you create an account
Support communications: messages you send to us, and any photos or videos you choose to share for support, returns, or warranty requests
Marketing preferences: your email/SMS opt-in status and preferences
Survey, quiz, or review responses: including any wellness goals or use-case preferences you share when answering our questions

B) Information collected automatically

Device information: IP address, device type, browser type, operating system, device identifiers
Usage information: pages viewed, clicks, time on Site, referring URLs, shopping behavior (cart actions, checkout steps)
Approximate location: derived from IP address
Cookie and tracking data: cookies, pixels, and similar technologies (see Section 8)

C) Information from third parties

Shopify (our ecommerce platform)
Payment processors (confirmation of payment status - we do not receive full card numbers)
Shipping carriers (delivery status, tracking events)
Advertising and analytics partners (performance data for ads and Site usage)
Trustpilot (reviews and related metadata if you leave a review)
Affiliate partners (referral attribution)

3) How we use personal information

A) To provide and operate the Services

Process transactions, fulfill orders, ship products, and provide tracking
Provide customer service (returns, refunds, warranty support, troubleshooting, product questions)
Send service-related communications (order confirmations, shipping updates, policy updates)

B) To improve and protect our business

Maintain Site functionality and security
Prevent fraud, abuse, and chargeback abuse
Debug errors and improve performance
Conduct analytics and understand how visitors use the Site

C) Marketing and advertising

Send marketing emails and SMS messages only when you opt in (via Klaviyo)
Measure marketing effectiveness and show relevant ads using tools such as Google Ads, Meta Pixel, and TikTok Pixel
Build advertising audiences based on general site behavior (pages viewed, products added to cart, purchases) - not on health information
Measure conversions (e.g., whether an ad led to a purchase)

D) What we do NOT do

We do not use health-related information you share with our support team to target advertising or build advertising audiences.
We do not sell health information to anyone.
We do not make solely automated decisions that produce legal or similarly significant effects about you.

4) How we disclose (share) personal information

We share personal information only as needed for legitimate business purposes:

Service providers and vendors

Ecommerce platform: Shopify
Payment processing: Shop Pay, PayPal, Stripe, and card networks
Shipping and logistics: carriers and 3PLs
Customer support and chat tools
Email and SMS marketing: Klaviyo
Analytics and advertising: Google Analytics, Google Ads, Meta, TikTok
Reviews platform: Trustpilot, Judge.me
Affiliate program partners (for referral attribution and commission payment)

These providers process information on our behalf under contracts consistent with this Policy.

Legal and safety

We may disclose information:

to comply with law, legal process, subpoenas, or government requests
to protect the rights, property, or safety of Primalon, our customers, or others
to enforce our terms and policies

Business transfers

If we are involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction. We will notify users via the Site of any change in ownership or use of personal information.

5) Payments

Payments are processed by secure third-party payment processors (such as Shop Pay, PayPal, and card networks). We do not store full payment card details. Your payment provider's privacy policy governs their processing of payment information.

6) Reviews and user-generated content

If you leave a review or share content (including photos or videos), it may be displayed publicly. Trustpilot and similar services may collect and display information according to their own policies.

Please avoid including specific medical conditions, diagnoses, prescription details, or other sensitive health information in public reviews. Reviews are publicly visible and indexed by search engines. If you want to share a detailed health-related experience, please contact support privately at support@primalon.co instead.

7) Affiliate program tracking

If you arrive at the Site via an affiliate link, we may use cookies or similar tracking to:

attribute your visit or purchase to an affiliate
prevent fraud
calculate commissions

This tracking may involve assigning an identifier to your browser or device. You can limit this by adjusting cookie preferences and browser settings (see Section 8).

8) Cookies, pixels, analytics, and advertising

What these technologies are

"Cookies" are small data files stored on your device. We also use "pixels," "tags," and similar technologies that help us recognize your device and measure marketing effectiveness.

Why we use them

Strictly necessary: Site functionality (cart, checkout, security)
Functional: preferences (language, region)
Analytics: understanding Site usage (Google Analytics)
Advertising: measuring and improving advertising (Google Ads, Meta Pixel, TikTok Pixel)
Marketing/communications: Klaviyo email and SMS engagement

Managing cookies

You can control cookies through:

Our cookie preference banner on the Site
Your browser settings (block or delete cookies)
Your device settings (where available)

Disabling some cookies may affect Site functionality (such as keeping items in your cart).

Industry opt-out tools

You can also opt out of interest-based advertising from many companies through:

Digital Advertising Alliance: https://youradchoices.com
Network Advertising Initiative: https://optout.networkadvertising.org
Meta: https://www.facebook.com/adpreferences
Google: https://adssettings.google.com
TikTok: https://www.tiktok.com/legal/page/global/privacy-policy

9) U.S. state privacy rights

Depending on where you live, you may have rights under U.S. state privacy laws - including California (CCPA/CPRA), Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Delaware, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, and Rhode Island. These rights may include:

Access / Know: the right to know what personal information we collect about you
Delete: the right to request deletion of certain personal information
Correct: the right to correct inaccurate information
Opt out: the right to opt out of "sale," "share," and targeted advertising
Limit use of sensitive personal information (where applicable)
Non-discrimination for exercising your privacy rights
Appeal: the right to appeal a denial of your request (in certain states)

"Sale" / "Share" and targeted advertising

We do not sell personal information for money. However, some privacy laws define "sale" or "share" broadly to include disclosures for cross-context behavioral advertising (targeted advertising), such as sharing identifiers with advertising partners via pixels or cookies.

How to opt out

You can opt out of "sale/share" and targeted advertising by:

Using the "Do Not Sell or Share My Personal Information" link in our Site footer or cookie banner
Emailing us at support@primalon.co with subject line "Privacy Request – Opt Out"
Enabling the Global Privacy Control (GPC) signal in a supported browser

Global Privacy Control (GPC)

Where required, we treat the GPC signal as a request to opt out of "sale/share" and targeted advertising for that browser/device. GPC applies per browser/device and may not persist if you clear cookies or use a different device.

Response timeframes

We will acknowledge most privacy requests within 10 business days.
We will respond substantively within 45 days (with one possible 45-day extension for complex requests, with notice).

Authorized agents

You may use an authorized agent to submit requests on your behalf. We may require:

written authorization from you, and
verification of your identity directly with us.

Right to appeal

If we deny your privacy request, you may appeal by emailing support@primalon.co with subject line "Privacy Request – Appeal" within 60 days. We will respond to appeals within 60 days.

10) CCPA/CPRA-style disclosures (last 12 months)

A) Categories of personal information we collect

Identifiers: name, email, phone, IP address, device identifiers
Commercial information: products purchased, order history
Internet/network activity: browsing behavior on our Site
Geolocation data: approximate location derived from IP
Customer support information: communications and files you choose to provide
Inferences: interests/preferences based on browsing and purchase activity

B) Sources

You (forms, account, support, reviews)
Your device/browser (cookies, pixels)
Service providers (Shopify, carriers, payment processors)
Advertising/analytics partners (Google, Meta, TikTok)
Trustpilot

C) Business purposes

Order fulfillment and customer service
Site operations, security, fraud prevention
Analytics and product improvement
Advertising performance measurement
Legal compliance and recordkeeping

E) "Sale" / "Share"

We may "share" identifiers and internet/network activity with advertising partners for targeted advertising and measurement (as those terms are defined by certain state laws). You can opt out (see Section 9). We do not "sell" personal information for money.

11) Sensitive personal information and health-related information

Some U.S. state laws define health-related information as "sensitive personal information."

We do not intentionally collect health information to infer characteristics about you or to build health profiles. However, because our products are used for recovery and wellness purposes, customers sometimes voluntarily share information about pain, injuries, sleep, stress, or wellness goals when contacting customer support, leaving reviews, or responding to surveys.

We use this information only to:

respond to the specific support request
improve product instructions, FAQs, and educational content (in aggregated, de-identified form)
process returns or warranty requests

We do not:

sell or share health-related information with advertising partners
use it to target ads or build advertising audiences
combine it with advertising identifiers

Please do not include detailed medical history, diagnoses, prescription information, or other sensitive health details in public reviews or social media tags.

12) Data retention

We retain personal information only as long as necessary for the purposes described:

Order records: approximately 7 years (for tax, accounting, and warranty purposes)
Marketing subscriber data (email/SMS): until you unsubscribe, plus approximately 30 days for suppression-list compliance
Customer support communications: approximately 2–3 years after resolution
Web analytics data: approximately 14–26 months (matching default analytics retention)
Account data: for the life of the account, plus a reasonable wind-down period after closure
Cookies and tracking data: varies by cookie (session cookies expire when you close your browser; persistent cookies typically expire within 13 months)

We may retain information longer where required by law, to resolve disputes, prevent fraud, or enforce agreements.

13) Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit, restricted access controls, and use of reputable processors (Shopify, Klaviyo, Stripe, PayPal). No system is 100% secure, but we work to protect your data and limit access to authorized personnel and trusted vendors.

14) Children's privacy

Our Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided personal information, please contact us at support@primalon.co so we can delete it.

15) International visitors

Primalon currently ships within the United States. If you access the Site from outside the United States, your information will be processed in the United States, where privacy laws may differ from those in your country. By using the Site, you understand that your information will be processed in the U.S.

16) Notice of Financial Incentive (California residents)

If we offer a discount, free shipping, free gift, or other benefit in exchange for joining our email or SMS list, this may be considered a "financial incentive" under California law.

What we collect: name, email, and/or phone number
What you get: the offered discount or benefit
How the value is calculated: based on the value of the discount/benefit and the estimated value of the contact information to our marketing program
How to opt in/out: by joining or unsubscribing from email or SMS at any time

You may withdraw at any time by unsubscribing - there is no penalty for doing so.

17) Exercising your rights / contacting us

To submit a privacy request, email support@primalon.co with subject line "Privacy Request" and include:

your full name
the email address used on our Site
your state of residence
the request type (access, delete, correct, opt out, appeal)

We may need to verify your identity before processing the request. We may deny requests where permitted by law (for example, where we must keep records for legal or tax compliance).

18) Changes to this Policy

We may update this Privacy Policy from time to time. We will post the updated policy on this page and update the "Last updated" date. For material changes, we will provide additional notice (such as via email or a Site banner) where required by law.

PRIMALON LTD [INSERT MAILING ADDRESS] support@primalon.co

19)

If you have any questions or concerns regarding your privacy while using PRIMALON LTD's services, or if you wish to exercise any of your privacy rights, please do not hesitate to contact us:

- Email: support@primalon.co

- Phone: +12182776683

- Postal Address: 17595 Harvard Avenue, Suite C - 10211, Irvine, CA 92614, United States

Our team is dedicated to addressing your concerns and providing the necessary assistance regarding your privacy and data protection.