Privacy Policy
Privacy Policy
Last Updated: 10-21-25
This Privacy Policy explains how ONeill Development LLC, doing business as Primal Plunges (“Primal Plunges,” “we,” “our,” or “us”), collects, uses, discloses, and safeguards information from individuals who visit or use www.primalplunges.com (the “Site”), purchase our products, interact with our customer support or marketing, or otherwise engage with us (collectively, the “Services”). By using the Services, you agree to this Privacy Policy.
1. Scope
This Privacy Policy applies to personal information collected online and offline in connection with our consumer-facing products and website. It does not apply to information collected by third parties that we do not control, including financing providers (e.g., Affirm), carriers, or websites linked from the Site.
2. Who We Are & How to Contact Us
Controller: ONeill Development LLC dba Primal Plunges
Address: 708 W 1940 S, Bldg 20, Suite 102, Logan, UT 84321
Phone: 435-361-4085
Website: www.primalplunges.com
3. Information We Collect
We collect the following categories of information, depending on how you interact with us:
• Identifiers: name, postal address, email address, phone number, IP address, device identifiers.
• Commercial Information: products viewed, cart contents, orders, purchase history, service requests.
• Payment & Financing Information: payment method details (processed by our payment providers), and limited financing application metadata if you choose Affirm (credit decisions and sensitive financial data are handled by Affirm).
• Internet/Network Activity: browsing data, referral URLs, pages viewed, time on page, clickstream, approximate geolocation, and analytics cookies.
• Communications: emails, SMS/MMS, chat messages, call recordings (where permitted), support tickets, survey responses.
• Inferences & Preferences: product preferences, marketing preferences, and segments derived from the above.
• Photos/UGC: if you voluntarily submit reviews, photos, or videos.
4. Sources of Information
• Directly from you when you create an account, place an order, contact support, or opt into SMS/email.
• Automatically through cookies, pixels, SDKs, and similar tools when you browse the Site.
• From service providers and partners (e.g., payments, financing, logistics, analytics, marketing).
5. How We Use Information
We use personal information for the following purposes:
• To provide and improve the Services, fulfill and deliver orders, and process payments.
• To communicate with you about orders, warranty, returns, safety notices, and customer support.
• To send marketing communications (email/SMS) with your consent where required.
• To personalize your experience, content, and offers.
• To conduct analytics, debug, and prevent fraud or abuse.
• To comply with legal obligations and enforce our Terms of Service, Shipping, Return, and Warranty Policies.
• For other purposes with your consent.
6. Lawful Bases for Processing (GDPR/EEA/UK Visitors)
Where GDPR or similar laws apply, we rely on the following legal bases: (i) contract performance (e.g., order fulfillment), (ii) legitimate interests (e.g., site security, fraud prevention, product improvement, marketing to existing customers), (iii) consent (e.g., SMS/email marketing, cookies where required), and (iv) legal obligations.
7. Cookies, Analytics, and Advertising
We and our partners use cookies and similar technologies (pixels, tags, SDKs) to operate the Site, measure performance, understand usage, and deliver ads. You can manage cookies via your browser settings. If required by law, we will present a consent mechanism. Disabling cookies may impact Site functionality.
8. How We Share Information
We may disclose personal information to:
• Service Providers: hosting, payment processing, financing (Affirm), logistics/shipping, fulfillment, customer support,
analytics, advertising/marketing, security, and IT.
• Business Partners: if we jointly offer products or run co-marketing (with your consent where required).
• Legal/Compliance: to comply with law, respond to lawful requests, or protect rights, safety, or property.
• Corporate Transactions: in connection with a merger, acquisition, financing, or sale of assets.
We do not sell personal information for money. We may “share” (as defined under some laws) limited data for cross-context behavioral advertising. Where required, we will provide opt-out mechanisms.
9. Financing Through Affirm
If you choose Affirm at checkout, you will be redirected to Affirm to apply and complete your financing. Any information you provide to Affirm is governed by Affirm’s privacy policy and terms, not this Privacy Policy. We may receive limited status updates (e.g., approval status, transaction reference) to complete your order.
10. SMS and Email Marketing (A2P 10DLC-Compliant)
By providing a mobile number or email and affirmatively opting in (where required), you consent to receive marketing and transactional messages from Primal Plunges. Consent is not a condition of purchase. Message and data rates may apply. Message frequency varies.
Opt-Out (SMS): Reply STOP to any message to opt out. For help, reply HELP or contact support@primalplunges.com. Opt-Out (Email): Use the unsubscribe link in any marketing email. We may still send order, account, or service messages after you opt out of marketing.
Program details: We use registered A2P 10DLC routes and approved sender IDs where applicable. Carriers are not liable for delayed or undelivered messages. You agree to provide a valid mobile number and update it if it changes.
11. Data Retention
We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Policy, including to provide the Services, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods vary based on record type, legal requirements, and business needs.
12. Security
We implement commercially reasonable physical, technical, and administrative safeguards designed to protect personal information. However, no system is 100% secure, and we cannot guarantee absolute security.
13. Children’s Privacy
The 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 us information, please contact us and we will take appropriate steps to delete such information.
14. Your Privacy Rights
Depending on your jurisdiction, you may have rights to access, correct, delete, or receive a portable copy of your personal information, to opt out of certain processing (such as cross-context behavioral advertising), to limit use of sensitive information, and to appeal denials. You may exercise rights by contacting support@primalplunges.com. We will verify your request and respond as required by law.
For EEA/UK individuals, you may also object to processing based on legitimate interests and lodge a complaint with your local supervisory authority.
15. “Do Not Sell or Share” / Ad Choices
Where applicable law provides, you may opt out of the “sale” or “sharing” (as defined by law) of personal information for targeted advertising by adjusting cookie preferences, using platform-level ad settings, or contacting us. We honor the Global Privacy Control (GPC) where required.
16. International Data Transfers
We are based in the United States. If you access the Services from outside the U.S., your information may be transferred to, stored in, or processed in the U.S. or other countries that may not provide the same level of data protection as your home jurisdiction. Where required, we use appropriate safeguards for cross-border transfers.
17. Do Not Track
Some browsers transmit “Do Not Track” signals. There is currently no industry standard for how to respond to such signals. We respond to legally recognized browser signals only where required by law.
18. Third-Party Links & Services
The Site may contain links to third-party sites and services. We are not responsible for the privacy practices of those third parties. Your interactions with third-party services are governed by their terms and privacy policies.
19. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The “Last Updated” date reflects the effective date. Material changes will be posted on the Site, and, where required by law, we will obtain your consent.
20. State Law Disclosures (U.S.)
For residents of California, Colorado, Connecticut, Utah, Virginia, and other states with privacy laws, this section supplements the information above: categories of data collected, sources, purposes, and disclosures are described in Sections 3–8. We do not sell personal information for monetary consideration. We may “share” limited data for cross-context behavioral advertising as described in Section 8. You may exercise rights as outlined in Section 14.
21. Contact & Related Policies
If you have questions or wish to exercise your rights, contact us at 435-361-4085. You may also write to: ONeill Development LLC dba Primal Plunges, 708 W 1940 S, Bldg 20, Suite 102, Logan, UT 84321.
Related Policies: Terms of Service, Shipping Policy, Warranty Policy, and Return Policy are available on our Site.
22. PrimalOS Mobile App Data and Privacy
Primal Plunges operates a mobile application known as PrimalOS (the “App”), which allows users to track and record cold plunge activities. The App collects certain data to enhance the user experience and to support product functionality.
Information Collected Through the App
When using the PrimalOS App, we collect and store data about your cold plunge sessions, including but not limited to water temperature, duration, date, time, and usage frequency. The App may also collect device information, app usage metrics, and crash data to help improve performance.
Additionally, the App enables users to take and save photos through the App. These images are securely stored on Primal Plunges’ servers to support in-app features such as progress tracking, user history, or session summaries. These photos are not used for marketing, promotional, or public purposes, and they are not shared with other users or third parties.
Data Sharing and Use
The PrimalOS App includes social and community features where certain non-sensitive session data—such as plunge times, water temperatures, durations, and streak statistics—may be visible to other users in dashboard, leaderboard, or community-style displays. By using the App, you acknowledge and agree that these forms of data sharing are part of the App’s design and cannot be disabled or opted out of.
Primal Plunges may use aggregated or anonymized data derived from PrimalOS for internal analytics, research, and marketing insights. This helps us understand user behavior and improve the App experience. Any use of such data will not include personally identifiable information or user photos.
Data Retention and Security
Data collected through the App is stored securely on Primal Plunges’ servers and is retained for as long as your account remains active, or as required by law. You may contact us at support@primalplunges.com to request deletion of your account and related data, subject to applicable retention requirements. We use commercially reasonable safeguards to protect your information, but no system is completely secure.
Third-Party Services and Integrations
The PrimalOS App may use third-party services for analytics, cloud storage, and performance monitoring. These third parties may have access to limited data to perform services on our behalf, and are bound by confidentiality and data protection obligations.
Health Disclaimer
PrimalOS is intended for wellness tracking only and is not a medical or diagnostic application. Information displayed by the App, including plunge duration or temperature recommendations, is for general informational purposes. You should consult a qualified healthcare provider before engaging in cold exposure routines. Primal Plunges is not responsible for any injury or health outcomes resulting from use of the App or related products.