Privacy Policy

Primo (“we”, “us”, “our”) consistently aims to keep privacy protection of all our users at the forefront of our business for both our Site and Services. The below outlines how the data and information you provide are used.

1. Contact Information

If you ever wish to clarify or have any queries regarding our Privacy Policy, then we encourage you to contact us.

2. Obtaining Of Information

A) Collecting of Information When you’re making use of our Site or Services, there is some information we collect from you,

• Once you create your own account or make any changes to it.
• When placing an order (for payment and order delivery purposes).
• If you grant us consent to contact you, whether by email, phone, message or our chat functions. We will contact you to inform you on our marketing campaigns, Primo initiatives or to invite your participation for surveys.
• If you contact us directly by phone, email, message or our chat functions.
• When you browse and make use of our Site or Services.

We also obtain information from third party sites. If you decide to link any of your Social Media or third-party accounts to us, then a record will be kept of your Social Media handle as well as any other information made available via your settings. B) Types Of Information Collected Whenever you’re placing an order on our Site or making use of one or more of our Services, some personal information is collected to help us analyse market trends and improve our overall customer experience. We want to be transparent about the types of information that is collected from you:

• When you’re visiting our Site or placing a Primo order (this also refers to partner websites that we work together with in order to provide our Services), then you will be asked to provide certain information pertaining to yourself. This includes details such as your name, contact numbers, address, order details, loyalty scheme information (if applicable), payment details (debit or credit card information) and potentially age verification if you’re purchasing items that have an age restriction.
• Your usage of the Site and any information that comes through to us via phone, message, email or our chat function is also collected. All calls are recorded, both for training and improvement purposes, and notes are saved in relation to the call.
• Whether you are using a mobile, laptop or tablet, some technical information will also be collected. This includes your IP address, the operating system used and the connection type.

When using a mobile, then information about your phone carrier, performance and location data, interaction with QR codes, NFC tags or vouchers is also obtained. It will be used by us automatically unless you have opted for specific privacy settings on your device. Your health information, such as food allergies recorded on an order,  may also be processed and saved if you opt to volunteer and grant consent for this.

3. Using Your Information

In order for us to process any information that you provide, there must be a valid reason which is also in compliance with data protection law. If you have requested to use a service or if we are to enter into a contract, then there is information we would need to obtain. However, although you may opt not to provide us with the details required, we may not be able to offer you our Services. We need this in order to:

• Grant access to areas of our Site via the collection of cookies from the device you are using (check our Cookie Policy for further details).
• Supply our Services. We require your name, contact information, address for delivery, order detail.
• Collect payment. Any credit or debit card information needs to be acquired.
• Contact reasons. We may need to contact you from time to time to resolve issues relating to your order.

Processing of this information is only done where it is necessary and in compliance with data protection law. Reasons may be:

• To enhance the quality and efficiency of our Services for current and potential clients.
• In order to tailor-make our content that ourselves or our partners show you. This includes displaying partners who are within your vicinity or to target the advertising that would be of more relevance to you. The analysed data creates certain assumptions whereby we can ‘profile’ our clients to offer you partners you may prefer, inform you about products and deals as well as other material. If you need further details about ‘profiling’ and your rights, take a look at our section on Your Rights.
• For our customer support team to provide better assistance on any general enquiries or feedback.
• Us to be able to contact you so as to communicate any important changes (where you have requested this of us).
• So as to forward you any information about our Services, products or promotions via post. If you do not wish to receive such information, just get in touch via our Contact Details.
• To enable us to observe and analyse any activity on our Sites so as to further improve on developments.
• To allow us to expose, scrutinise and report any investigation into the prevention of fraudulent or criminal activity.
• In order to comply with any of our contractual terms we have entered into an agreement upon, for the defence of any legal claims and to protect the rights of parties involved, including (but not limited to) Primo, our partners and our riders.
• For compliance purposes, regulatory requirements and any legal obligations we may be subject to.

Our marketing or advertising material may include any feedback or comments which you choose to submit via our Sites or Services. The sole information displayed on this material will include your first name and your city of residence. The information could also be shared with our partners so as to allow them to improve and develop their services.

4. Primo Business

The information we gather could also be used to assess the potential interest in our Primo Business service. If the account seems to be used for business purposes, then we may contact you (via email or phone call) to provide you with further information relating to our Primo Business service. You may opt out of this by unsubscribing via our emails or our Contact Details listed in this document. If your company or your employer decide to sign up for our Primo Business service, then you may be offered to use this service, too. In that case, we will take note of this on your account and attach a Primo Business allowance to it. You can contact your employer if you’d like any further information relating to this. The information you provide will be processed as per what is stated within the Using Your Information section. Any data relating to your order whilst using a Primo Business account will be shared with your employer (including the time and date of the order, payment amount and the chosen partner).

5. Cookies

Cookies help maintain site function and accessibility. We just want to make you aware that should these cookies be disabled or refused (in part or in whole) from your browser, then the Site may not work optimally. Read through our Cookie Policy to find out more.

6.Marketing and Advertising

If you have granted consent or if we feel we have a valid reason for doing so (and where the law allows us to), you will be contacted via email, phone, post or push notification to provide you with information related to our Services and products. We try to ensure you are kept aware and are able to view our products by effective online advertising. Banners and adverts might pop up and appear whilst you are using other apps or websites, for example, on Facebook. They are based on information that is held about you (via an order you made on Primo or an ad you might have clicked on previously). Through a series of advertising technologies and digital marketing networks, we are able to communicate the most relevant information to you. If you want more details on your personal rights relating to cookies, visit our Cookie Policy. If you want additional details relating to your rights with this type of processing, take a look at Your Rights below. Control your marketing preferences easily, just follow the below steps:

• Visit our Site – www.primo.mt OR go the mobile APP.
• Click on the Account section (you’ll find this under the drop-down menu if you’re using the website).
• Find ‘Marketing Preferences’.

From here you may choose to stop receiving push notifications. There are still reasons as to why you may still be contacted via email, such as any interruptions to our Services or delivery safety. This list is not exhaustive and may include other valid reasons.

Automated Decision Making

If any fraudulent activity is detected, we may suspend or block your ability to place an order on our Sites or make use of our Services. All our customers are subject to fraud checks, so as to enable us to ensure that services ourselves and our partners participate in are duly paid for. We also aim to protect any fraudulent card transactions from occurring. We deal with large volumes of orders and customers so first-hand checks are impossible. We therefore use a highly automated system to analyse data and accept or decline an order. The system looks an industry indicators and fraud patterns detected via our Sites and provides an automated score which indicates the likelihood of a fraudulent transaction. If the score is high, then there is an increased chance that your order may be declined and we may block you from making use of our Services. These indicators are fluid and may change from time to time depending on the types of detected fraud locally and worldwide. The process of fraud detection aims to serve both our customers and Primo. The rights you have in relation to this can be found in the section Your Rights below. Any decision relating to fraud that has been made about you can be contested via our Contact Details listed above.

8. Information Retention

Any information of yours will not be retained for any period other than what we deem necessary and whatever periods are required by regulators or law. We will keep this data in order to abide by what we have set out in the Use Your Information section. The timeframe necessary to retain your information will take into account the following:

• Any contracts we have agreed upon
• Periods of time stipulated by applicable law(s)
• Statute of limitations under applicable law(s)
• Any valid and legitimate interests (please refer to the Use of Information section above)
• Enquiries, issues and disputes
• Guidelines stipulated by data protection authorities

Once your data is no longer required for the purposes intended, then it will be erased in a secure manner.

9. Disclosure Of Your Information

Any information collected is stored on our EU servers and is only shared with relevant parties for reasons explained in the Use Your Information section. This may include other Primo companies as well as third party service providers who offer a services on behalf of us, such as:

• Restaurant and Shop/ Grocery partners
• Riders
• Payment providers (online payment and fraud detection)
• IT service providers (such as cloud server providers)
• Our Customer Support teams (including those companies that provide assistance in relation to customer or technical support, as well as others).
• Marketing and Advertising partners (take a look at our Cookie Policy to understand our policy on website sharing).

Primo will share information with a third party if we are promoting or offering a product or service and to provide marketing assistance. The offer or programme will include the name of our partner, either by itself or in conjunction with ours, such as with those who provide our delivery services. Any comments, feedback or message we receive regarding Sites and Services may also be shared with out partners, including any information relevant to your health (such as food allergies or intolerances). This would be done if you volunteer and consent to allow us to do so. Primo ensures to treat your details and information safely and securely and takes all reasonable steps to abide by this Privacy Policy and any applicable laws. Should Primo and/ or our Site or Services be sold, merge or enters into a joint venture, your information may be disclosed to any of the relevant parties. The information we obtain may also be shared: If we are obliged to comply (and believe there is a legitimate duty to do so) by any law or regulatory requirement, including for the purpose of fraud and crime prevention. In order to protect the rights of Primo and our business, partners, riders and others from fraudulent activity With any third parties necessary for the prevention of crime, such as the police force. Information we obtain may not only be processed within the European Union or EEA (European Economic Area), but in other countries where Primo operates (you can check them on www.primo.mt). Although not every country will reserve the same protection for your data, we endeavour to ensure that they are processed in the same way as if it were to be within the EEA. We implement certain safeguards when data is processed outside of this area, such as using data transfer mechanisms approved by the Secretary of State.

10. Data and Security

We endeavour to utilise the most updated technology and policies in order to protect any information that we hold onto.

We strongly advise you not to share any passwords created for accessing our Sites with other parties. It is your responsibility to keep this password confidential.

We undertake specific steps to secure your information as much as reasonably possible. We aim to do our best to protect your data from any loss, damage, destruction, unlawful and unauthorised access and processing. However, any transmissions that take place across the internet is never truly secure. It is your choice to transmit certain information, and once we receive this, we will do our utmost to protect it.

11. Your Data Protection Rights

Our Data Protection Officer is available to be contacted regarding any rights you may have (according to applicable law) in relation to the data we retain. Use the Contact Details provided above. If you’d like more information or wish to exercise any of the rights listed below, please do reach out. The right to be informed. The information relating to how we use your data provided should be transparent and easily understood, which is why this Privacy Policy has been developed. The right of access. You have every right to access any data that is being processed about you, so you can rest your mind assured that we are using it in line with data protection law. To access this, just in get in touch via our Contact Details above. The right to rectification. If you notice that your data is incomplete or isn’t accurate, please do get in touch with us (see Contact Details) to have it rectified. The right to erasure. You are entitled to request that specific information about you is removed or deleted by contacting us (see Contact Details). This applies only in particular circumstances and is not an absolute right in itself. The right to restrict processing. Certain situations may call for the right to ‘block’ or ‘withhold’ use of certain information. The processing of the data may be restricted, but it could still be stored. The right to data and portability. The format in which you receive your data should be easily accessible and transferable. It may be used for your own reasons across various service providers. This is not an absolute right and there are exceptions to it. If you would like to learn more, please reach out (Contact Details above). The right to lodge a complaint. You’re entitled to file a complaint relating to our handling of data and information with a competent data protection authority. Please refer to our Complaints section. The right to withdraw consent. If you wish to withdraw any consent you’ve given, get in touch through our Contact Details. Using your information prior to the withdrawal of consent does not deem it unlawful. The right to object to processing. If you wish to object to profiling and processing you can amend your marketing preferences. Check our Cookies and Marketing and Advertising sections or feel free to contact us (Contact Details). You are also entitled to contest any decisions made via automated processes, such as those relating to fraud checks. See our Automated Decision Making or our Contact Details section.     

12. Privacy Policy Changes

Our Privacy Policy will be updated every now and then, so be sure to check for any changes that might be going on! When we feel it is necessary, we might reach out to you and notify you of anything that’s happening – usually by email or push notification. Last Update To Privacy Policy: 05/ 03/ 2021