Privacy Notice

Purpose of this notice

This privacy notice explains how we process the personal data we collect from you or that you provide to us when you visit our website (www.primark.com (our "Site")), that we collect through our various social media channels, such as Facebook, Instagram or Twitter or that you otherwise provide to us. "Personal data" is information such as your name, email address, IP address, device identifier and information about your preferences.

This privacy notice also tells you how you can exercise your rights (including the right to object to some of the data processing we carry out). More information about your rights and how you can exercise them is set out in the "Your Rights" section below.

Who are we?

The following Primark entities are responsible for use of data described in this notice. When we refer to "Primark", "we”, "our" or "us" in this notice and elsewhere on the Site, we mean:

• Primark Stores Limited (registered under company number 00453448 with registered address at Weston Centre, 10 Grosvenor Street, London, W1K 4QY United Kingdom); and

• Primark Limited (registered under company number IE047371 with registered address at Arthur Ryan House 22-24 Parnell Street Dublin, D01 P7W2 Ireland).

The entities described above act as 'Controllers' under data protection legislation of the personal data described in this notice and sometimes act as 'Joint Controllers' when we jointly are responsible for processing your personal data. Information about how to exercise your rights, including who to contact, is set out in the "Your Rights" section below.

What information do we collect about you?

We collect the following information about you when you visit our Site:

1. Information about your interactions with the Site

How do we use this data?

When you browse our Site, we collect:

• information about your use of our Site, such as standard internet log information and details of visitor behaviour patterns (such as browsing patterns and dwell time); and
• information about your computer – this includes your IP address (and location), operating system and browser type.

We use this information:

• to help maintain the security of our Site and to identify trends so that we can improve its performance;
• to understand whether the Site is operating correctly (e.g. if links are broken and need to be fixed);
• to customise the Site according to your interests, to ensure the Site's content is presented as effectively as possible for you and to help you get quicker access to the information on our Site that you are looking for;
• to inform our marketing activities with you where we have your consent;
• to remember your preferences when you interact with us
• to allow us and third parties to serve relevant ads to you; and
• to analyse aggregated user information with other interactions users have with Primark in order to continually improve our offering and to help us make decisions about the types of advertising we purchase;

Google will use your personal data such as your IP address if you use the Google Maps function on our Site to find your nearest store. For more information, see Google's Privacy Policy.

Data we collect using non-essential cookies is used on the basis of your consent. Any other information that we collect about your use of our Website is used on the basis that this is necessary for the purposes of our legitimate interests in maintaining and managing our Site, tailoring it to suit our users and ensuring its security. We will not process this information for these purposes if to do so would constitute an unwarranted interference with your own interests, rights and freedoms.

For more information about how we use tracking technology like cookies and how you can manage tracking technology and cookies on our Site, see our Cookie Policy.

How long do we keep this information for?

We will not hold your personal data for longer than is necessary. We keep information about your visit to our Site for different lengths of time depending on what it is used for, anything from a few minutes and up to 2 years unless it is retained for marketing purposes in which case data will be kept until we have not seen any activity from the contact for 2 years. For more information, see our Cookie Policy.

Who do we share this information with?

We share information about visitors to our Site with service providers who help us administer and manage the Site.

We use a third party, Google Analytics, to collect this information but it is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our Site.

Otherwise we will not share your information with any third party unless:

• we have your permission;
• we are required to do so by law;
• this is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party;
• this is necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser's advisers and will be passed to the new owners);
• where you have consented to non-essential cookies, we may share the data collected from non-essential cookies with third parties who provide us with services in connection with this data, such as hosting and analysing this data.

2. Information you give us when you sign up for marketing from us

If you sign up to receive promotional material from us, we will use your personal data for our direct marketing purposes.

How do we use this data?

With your consent, we will use the details you have provided to us, either directly on our website or via third party forms (including your first name, and email address, date of birth and any preferences shared with us (such as preferred store)) to deliver promotional information that (i) you request or (ii) that we feel may interest you.

We will only contact you for marketing purposes by email if you have specifically consented to this.

We will use your date of birth so that we can send you a promotional email near your birthday.

We will also use the information we gather via our marketing activities:

• to gain insights into the needs and interests of our consumer base;
• to evaluate the effectiveness of our marketing activities (e.g. tracking email open and bounce rates);
• to classify our users into groups or segments (e.g. using information regarding your personal or professional interests, demographics, experiences with our products and contact preferences);
• to personalise and target our advertising through our online advertising partners, including social media platforms; and
• to measure and understand how our users respond to a variety of marketing activity so we can ensure our activity is well targeted, relevant and effective; and
• to help us make decisions about the types of advertising we purchase.

For more information about how we use cookies and similar tracking technologies for the purposes set out above, see our Cookie Policy.

When we use your data for direct marketing purposes we do so because you have given us consent to do this and for our legitimate business interests in developing and promoting our goods and services and communicating with you in accordance with your wishes and expectations. You can object to our use of your data for any or all of these purposes at any time.

We will also use this data for the purpose of our legitimate interests in accessing appropriate professional advice and in order to ensure we comply with legal obligations to which our business is subject.

How long do we keep this information for?

We will not hold your personal data for longer than is necessary. We keep information for direct marketing purposes for as long as you continue to be interested in receiving our marketing communications. We use tracking technology to help us monitor the effectiveness of our e-marketing and we delete contacts from our database when we have not seen any activity from the contact for 2 years.

If you would like to unsubscribe or otherwise manage your email preferences, you can do so via the Preference Centre which can be accessed using the link at the bottom of each promotional email we send to you.

Who do we share this information with?

We use social media platform tools to advertise our products (e.g. Facebook Custom Audiences). For that purpose, we may provide your email address to the social media platform in hashed form for them to present sponsored posts in your social media feed.

We also share this data where necessary with our suppliers, service providers and professional advisers who provide us with services in connection with this data, such as hosting and analysing this data.

When you first use our Site, we ask for your permission to use cookies and similar technologies in order to serve more relevant adverts to you. If you give consent to this, we will share information with third parties for this purpose. Our Cookie Policy has more information on this.

Otherwise we will not share your information with any third party unless:

• we have your permission;
• we are required to do so by law;
• this is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party; or
• this is necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser's advisers and will be passed to the new owners).

3. Information we obtain via social media

If you visit our social media pages, or post images or comments relevant to Primark on social media, we may contact you to ask if you'd like to feature in our advertising material or to ask if we can help with any customer service concerns.

What information do we collect about you and how do we use this data?

Primark engages with customers on social media in a number of different ways. Our Cookie Policy has more information about this.

• We collect information about you through social media channels such as Facebook, Instagram, TikTok and Twitter when we use these channels for advertising, analytics purposes or to enrich your profile with Primark. This may include any social media information that is publicly available such as your social media handles, social media interactions and public postings, your “Likes” and other reactions, your social media connections, your photos that are public, or those you send to us by mentioning us or following our social media posts by using “handles” or “hashtags”, comments or messages you shared with us publicly or privately on social media platforms. Also, we may be able to obtain information indirectly from social media companies when we advertise on these platforms, which may include your participation and membership on particular topics and/or groups, your profile settings and preference and your behaviour on different platforms owned by the same company.

• If you visit our social media sites, the social media site will share statistical information with us about the way our site is being used. This is aggregate information and cannot be used to identify you. For example, the statistics may tell us the age ranges of our visitors and whether they are male or female.

• If you upload images on your Instagram account using the hashtags #Primania and/or #Primark, your image may be selected for use in the Primania gallery on our site. More information about this can be found in our Website Terms of Use and Primania Gallery Terms. If your image is selected for the Primania gallery, you will receive an Instagram comment from @primark (Instagram), requesting permission from you to use your image in our gallery, in our social media postings, on our website, in our stores and in our marketing communications. Please be aware that everyone in the image must have provided permission for the image to be posted in the Primania gallery, which includes parental permission where necessary. .

When we use your personal data for these purposes, we do so for our legitimate interests in managing and improving our services, in promoting our brand and in managing customer services. We will not process this information for these purposes if to do would constitute an unwarranted interference with your own interests, rights and freedoms.

How long do we keep this information for?

With images originally posted on social media, the customer may delete the picture from their social media account at any stage, which will also delete the image from our Site. We also delete pictures from our Site in response to requests from customers, as set out in our Community Guidelines.

Where social media images are not deleted by the customer, we keep them for a maximum of a two year period from the date of posting on our Site.

Who do we share this information with?

We share your information with service providers who help us to engage on social media. If you agree that we can use your image in our materials, then this will be shared wherever the publicity is used.

Otherwise we will not share your information with any third party unless:

• we have your permission;
• we are required to do so by law;
• this is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party; or
• this is necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser's advisers and will be passed to the new owners).

4. Information you give us when you complete a survey

How do we use this data?

If you choose to complete a survey, you will be asked to provide us with your contact details and we will use the personal data you provide to improve our understanding of the needs and interests of our customers and contacts.

When we use your personal data for these purposes, we do so for our legitimate business interests in developing our goods and services.

How long do we keep this information for?

Information we hold for market research purposes is not usually held in a form that will identify you for longer than 12 months.

Who do we share this information with?

We share this data where necessary with our suppliers, service providers and professional advisers.

Otherwise we will not share your information with any third party unless:

• we have your permission;
• we are required to do so by law;
• this is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party; or
• this is necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners).

5.Information you give us when you enter a competition, prize draw, or promotion

How do we use this data?

When you enter a competition, prize draw or promotion, we collect personal data from you as part of your entry. We use this to administer our competition, to communicate results where relevant and to deliver prizes. When we use your personal data for these purposes, we do so because it is necessary for us to collect and use this information for the performance of our contract with you in accordance with our promotion rules.

If you are lucky enough to win a competition, prize draw or promotion we use your data in additional ways. Unless you ask us not to, we will make your surname and county of residence available: (a) on request to anyone who sends us a self-addressed envelope within 10 weeks of the closing date of the competition; and (b) to the Advertising Standards Authority (ASA) if they ask us. We do this because it is necessary for the purpose of our legitimate interests in complying with the UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (the Code).

You have the right to object to our publication of this data. Please contact us as soon as possible, and within a week of receiving your winner’s notification if you want to object.

If we haven’t heard from you within a week, and we are asked to publish the information, we will do so. If you object later, we may have already published the information.

Where we are asked to disclose information to the ASA, and you object before we have disclosed the information, we will take into account your reasons for objecting although we may still be required to disclose this information, if for example, we are required to demonstrate that a valid award took place.

We also ask winners to agree to reasonable publicity and so we use winners’ names and other data provided as part of that publicity (e.g. photos) to publicise your win and our brand. We use your information in this way as it is in our legitimate interests to publicise the winner(s) but you can object to our use of this data at any time by contacting us as soon as possible after you hear that you’ve won.

How long do we keep this information for?

Information we hold in connection with the management of competitions, prize draws, and promotions is usually held for 6 years.

Who do we share this information with?

We share this data where necessary with our suppliers, service providers and professional advisers and as required by the Code.

Otherwise we will not share your information with any third party unless:

• we have your permission;
• we are required to do so by law;
• this is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party; or
• this is necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners).

6. Information you give us when you contact our Customer Services Team

If you contact our Customer Services Team by phone, email or online via social media, chatbot or online form we will use your data in order to deal with your enquiry.

What information do we collect about you?

We collect the following data about you:

Information you knowingly give to us

• Your name, postal address, phone number, email address, instant messaging ID and social media username;
• Information you include in any correspondence you send to us (whether by submitting a completed "Contact Us" form, via chatbot, by social media, email, post or otherwise);
• Special categories of personal data which you choose to send to us, for example, photographs, medical information, information about your personal circumstances, and specific information regarding your reason for contacting us;

Information about your interaction with us

• when you interact with chatbots (automated messengers) we will also record what you respond to these chatbots, how you interact with them and we will store data related to the device that you use. Depending on the platform for the chatbot and your permission, we may collect device data such as: IP address, social media handle, time zone, country and GPS location;
• information concerning your use of our Site such as traffic data, location data, and other communication data; and
• information about your computer, including your IP address, operating system and browser type. This is statistical data and does not identify you specifically.

How will we use your data?

We will use your data:

• to provide a response to your query and/or resolve your complaint;
• for quality control and internal reporting purposes and to identify trends;
• for the purpose of obtaining professional advice and complying with our legal obligations;
• for the purpose of system administration and internal record keeping;
• to manage the performance of, and evaluate use of, our Site;
• to provide you with enhanced services; to enable you to participate in interactive features of the Site, when you choose to do so;
• to monitor Site and chatbot usage in order to help us develop and maintain the Site and our chatbot function.

Your data is processed by us:

• because this is necessary for the purpose of legitimate interests pursued by us in connection with responding to and handling your request/ complaint;
• because this is necessary for the purpose of our legitimate interests in maintaining internal administrative records;
• because this is necessary for the purpose of our legitimate interests in relation to the management, operation and enhancement of the Site;
• because this is necessary for the purpose of our legitimate interests in relation to quality control and business planning;
• in the case of sensitive personal data (see below), because you have given us your explicit consent; and/or for the purposes of establishing or exercising or defending legal rights.

We will not process your personal data for the purpose of our legitimate interests set out above if to do so would constitute an unwarranted interference with your own interests, rights and freedoms.

How long do we keep this information for?

Wherever possible, we will use your data in a form that does not identify you. We will only retain your data in a form that identifies you for as long as necessary to conclude your request/complaint and for record-keeping. This means that we will not usually retain your personal data for longer than 6 years. Your data may be retained for longer periods where it is necessary in connection with the resolution of a dispute.

We may disclose your data to the following recipients:

• our service providers;
• our professional advisers;
• affiliated Primark companies that have a relationship with you (where this is necessary to investigate or resolve your query or complaint);
• public authorities or judicial authorities (where disclosure is required by law or is necessary so that we can enforce our legal rights, or so that third parties can enforce their legal rights, or so that public authorities can exercise their functions in the public interest); or
• commercial partners (where disclosure is necessary in connection with the sale of a business or its assets).

Where do we transfer information to?

Information we collect is shared with service providers, some of whom are outside the European Economic Area and the UK, in countries which do not have the same data protection laws as the European Economic Area or the UK. Where we transfer data to these countries, we protect the data in ways which are approved by the European Commission and the UK government, such as ensuring that recipients have Processor Binding Corporate Rules in place, or by asking them to enter into standard contractual clauses (which are data transfer agreements approved by the European Commission). If you require further information about these safeguards, please contact us at dataprotection@primark.com.

Children

Users of our Site need to be over 16 years old to sign up to receive our regular emails. We do not knowingly collect personal data from children under the age of 16. If you are under the age of 16, please do not submit any personal data to our Site. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this notice by instructing their children never to provide personal data to our Site without their permission. If you have reason to believe that a child under the age of 16 has provided personal data to us, please contact us using the details provided below.

Your rights

You have a number of legal rights over the personal data that we hold about you. These rights give you control over how your data is used and managed.

• You can ask us at any time to provide you with a copy of your personal data. In relation to personal data you have supplied to us, and which is held by us for the purpose of entering into a contract between us or on the basis of your consent, you are entitled to ask us for a copy of this information in a structured, commonly used and machine readable format so that you can reuse it or share it with other organisations.
• If you think the personal data we hold about you is inaccurate or incomplete, you can ask us to correct it or complete it.
• In some circumstances, you also have the right to object to our processing of your data and can ask us to restrict our use of your data and to delete it.

There are some exceptions to these rights, however. For example, it will not be possible for us to delete your data if we are required by law to keep it or if we hold it in connection with a contract with you. Similarly, access to your data may be refused if making the information available would reveal personal data about another person or if we are legally prevented from disclosing such information.

If you wish to exercise any of these rights you should Contact Us using the details provided below.

Contact Us

If you would like to unsubscribe or otherwise manage your email preferences, you can do so via the Preference Centre which can be accessed using the link at the bottom of each promotional email we send to you. Questions, comments or requests concerning this privacy notice are welcomed and should be sent to dataprotection@primark.com. If you have a concern about the way we handle your personal data you have the right to complain to the data protection authority in the country where you live, work, or where you believe a breach has occurred. We keep our privacy notice under regular review. This privacy notice was last updated on 30 March 2022.