Privacy Policy

Welcome to Primo Hoagies. We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website primohoagiesnew.rest, place orders, interact with our services, or otherwise engage with us. Please read this policy carefully. If you disagree with its terms, please discontinue use of our site.

This Privacy Policy applies to all users located in the United States and is designed to comply with applicable federal and state privacy laws, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), the Federal Trade Commission (FTC) Act, and other relevant regulations. Where you are a California resident, additional rights and disclosures apply to you as described throughout this document.

1. About Us

Primo Hoagies is a food service business operating through the website primohoagiesnew.rest. We offer hoagies, sandwiches, and related food products and services to our valued customers across the United States.

For any privacy-related inquiries, you may contact us at the email address listed above. We will respond to all legitimate privacy inquiries within a reasonable time frame, and no later than 45 days as required under applicable law.

2. Information We Collect

We collect various types of information in connection with your use of our website and services. The categories of personal information we may collect include the following:

2.1 Personal Identification Information

When you place an order, create an account, subscribe to our newsletter, participate in promotions, or contact us, we may collect information such as:

• Full name
• Email address
• Phone number
• Billing and shipping address
• Username and password (for registered accounts)
• Date of birth (when required for age verification purposes)
• Payment information (credit/debit card numbers processed through secure third-party processors; we do not store full card numbers)

2.2 Order and Transaction Information

When you place an order through our website, we collect information related to your transaction, including:

• Items ordered and customization preferences
• Order history and purchase frequency
• Delivery instructions and preferences
• Special dietary notes or requests submitted with your order
• Transaction amounts and payment methods used

2.3 Usage and Technical Data

When you visit our website, we automatically collect certain technical information about your device and browsing behavior, including:

• IP address and approximate geolocation derived from IP
• Browser type and version
• Operating system and device type
• Pages visited and time spent on each page
• Referring URLs (how you arrived at our site)
• Clickstream data and navigation paths
• Time and date of your visit
• Crash reports and error logs

2.4 Cookies and Tracking Technologies

We use cookies, web beacons, pixel tags, and similar tracking technologies to enhance your experience on our website. These technologies allow us to recognize your browser, remember your preferences, and gather analytics data. Please refer to Section 9 of this Privacy Policy for a more detailed discussion of our cookie practices.

2.5 Communications Data

If you contact us via email, contact form, phone, or social media, we may retain records of those communications, including:

• The content of your messages and inquiries
• Feedback and reviews you submit
• Customer service interaction logs
• Survey responses

2.6 Information from Third Parties

We may receive information about you from third-party sources, such as:

• Social media platforms, if you connect or interact with us through those channels
• Marketing and analytics partners
• Payment processors and fraud detection services
• Delivery and logistics partners who fulfill your orders

3. How We Use Your Information

We use the personal information we collect for the following purposes:

3.1 Order Processing and Service Delivery

• To receive, process, and fulfill your food orders
• To coordinate delivery or pickup of your orders
• To communicate order confirmations, updates, and notifications
• To manage payment and billing processes
• To handle returns, refunds, or complaints related to your orders

3.2 Account Management

• To create and maintain your customer account
• To allow you to view your order history and saved preferences
• To reset passwords and verify your identity
• To manage loyalty rewards or promotional credits, if applicable

3.3 Customer Support

• To respond to your inquiries, questions, and feedback
• To resolve disputes or issues with your orders or account
• To send administrative communications such as policy updates or service notices

3.4 Marketing and Promotions

• To send you promotional emails, newsletters, and special offers (where you have provided consent or where permitted by law)
• To personalize the content and offers you see on our website based on your preferences and order history
• To conduct contests, giveaways, or other promotional campaigns
• To show you relevant advertisements on third-party platforms using retargeting technologies

You may opt out of marketing communications at any time by clicking the "unsubscribe" link in any promotional email or by contacting us at [email protected].

3.5 Analytics and Website Improvement

• To understand how users interact with our website and services
• To identify technical errors, bugs, and areas for improvement
• To analyze purchasing trends and customer behavior to improve our menu and services
• To conduct research and develop new features

3.6 Legal and Compliance Purposes

• To comply with applicable laws, regulations, and legal obligations
• To detect, prevent, and respond to fraud, security incidents, and other harmful activities
• To enforce our Terms of Service and other legal agreements
• To respond to lawful requests from government authorities or law enforcement

4. Legal Basis for Processing Your Information

We process your personal information under the following legal grounds:

• Contractual Necessity: Processing is required to fulfill your orders and provide the services you have requested.
• Legitimate Interests: We process certain data to pursue our legitimate business interests, such as fraud prevention, website improvement, and direct marketing, provided these interests are not overridden by your privacy rights.
• Consent: Where required by law, we process your data only after obtaining your explicit consent, such as for certain marketing communications and non-essential cookies.
• Legal Obligation: We may process data where necessary to comply with a legal obligation, such as tax reporting or responding to law enforcement requests.

5. Sharing Your Information with Third Parties

We do not sell, rent, or trade your personal information to third parties for their own marketing purposes. However, we may share your information in the following circumstances:

5.1 Service Providers and Business Partners

We engage trusted third-party service providers to assist us in operating our website and delivering our services. These providers are contractually obligated to protect your information and may only use it for the specific purposes we designate. They include:

• Payment Processors: Secure payment gateway providers who handle credit/debit card transactions on our behalf
• Delivery and Logistics Partners: Companies that assist in fulfilling food orders and deliveries
• Web Hosting and Cloud Services: Providers that host our website and store data securely
• Analytics Providers: Companies such as Google Analytics that help us understand website traffic and user behavior
• Email Service Providers: Platforms used to send transactional and marketing emails
• Customer Support Tools: Software platforms used to manage customer inquiries and support tickets
• Fraud Prevention Services: Tools that help us detect and prevent fraudulent transactions

5.2 Legal Requirements and Law Enforcement

We may disclose your personal information if required to do so by law, or in response to valid legal processes, including:

• Court orders, subpoenas, or other legal mandates
• Requests from government agencies or regulatory bodies
• Situations requiring disclosure to protect the safety of any person
• Situations requiring disclosure to protect against fraud or illegal activity

5.3 Business Transfers

In the event that Primo Hoagies undergoes a merger, acquisition, sale of assets, reorganization, or similar business transaction, your personal information may be transferred as part of that transaction. We will notify you via email or a prominent notice on our website prior to your information being subject to a different privacy policy.

5.4 With Your Consent

We may share your information with other parties where you have provided explicit consent for us to do so.

5.5 Aggregated and Anonymized Data

We may share aggregated or anonymized data that cannot reasonably be used to identify you with third parties for research, marketing, or business analysis purposes.

6. Data Security

Protecting your personal information is a top priority for us. We implement a variety of technical, administrative, and physical security measures designed to protect against unauthorized access, alteration, disclosure, or destruction of your personal data. These measures include:

• Encryption: We use SSL/TLS encryption to protect data transmitted between your browser and our website.
• Access Controls: Access to personal data is restricted to authorized personnel on a need-to-know basis.
• Secure Payment Processing: Payment transactions are processed through PCI-DSS compliant third-party payment processors. We do not store full credit card numbers on our servers.
• Regular Security Audits: We periodically review our security practices and update them as needed to address emerging threats.
• Data Minimization: We collect only the information necessary for the stated purposes and limit retention to what is required.
• Employee Training: Our staff are trained in data privacy and security best practices.

7. Your Privacy Rights

Depending on your location, you may have specific rights regarding your personal information. We honor the following rights for all users in the United States, with additional rights for California residents as described below.

7.1 Right to Access

You have the right to request a copy of the personal information we hold about you. Upon a verified request, we will provide you with the categories and specific pieces of personal information we have collected about you in the past 12 months.

7.2 Right to Correction

You have the right to request that we correct any inaccurate or incomplete personal information we hold about you. We will use reasonable efforts to correct the information promptly.

7.3 Right to Deletion

You have the right to request that we delete the personal information we have collected about you, subject to certain exceptions. We may deny a deletion request if retaining the information is necessary for us to:

• Complete a transaction or provide a service you requested
• Detect, prevent, or investigate security incidents or fraud
• Comply with a legal obligation
• Exercise or defend legal claims

7.4 Right to Data Portability

Where technically feasible, you have the right to receive your personal information in a structured, commonly used, and machine-readable format. You may also request that we transmit this data directly to another service provider.

7.5 Right to Opt Out of Marketing

You have the right to opt out of receiving marketing communications from us at any time. You can exercise this right by:

• Clicking the "unsubscribe" link in any marketing email we send you
• Contacting us at [email protected]

7.6 California Residents — Additional Rights Under CCPA/CPRA

• Right to Know: You may request disclosure of the categories of personal information collected, the categories of sources, the business or commercial purpose for collection, the categories of third parties with whom we share information, and the specific pieces of personal information collected about you.
• Right to Opt Out of Sale or Sharing: California law requires businesses to disclose whether they "sell" or "share" personal information. We do not sell your personal information. If this practice changes, we will provide a "Do Not Sell or Share My Personal Information" link on our homepage.
• Right to Limit Use of Sensitive Personal Information: You have the right to direct us to limit our use of sensitive personal information to what is necessary to perform our services.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. This means we will not deny you services, charge you different prices, or provide a different quality of service because you exercised your privacy rights.

To submit a request to exercise any of the rights described above, please contact us at [email protected]. We will verify your identity before processing your request and will respond within 45 days, with a possible extension of an additional 45 days where necessary.

You may also designate an authorized agent to make a request on your behalf. We may require written authorization and may verify your identity directly.

8. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The following retention periods generally apply:

Upon the expiration of applicable retention periods, we will securely delete, anonymize, or aggregate your personal information so that it can no longer be associated with you.

9. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to improve your browsing experience, analyze site traffic, and support our marketing efforts. Cookies are small text files placed on your device when you visit our website.

9.1 Types of Cookies We Use

• Strictly Necessary Cookies: These are essential for the website to function properly. They enable core functions such as security, order processing, and account login. These cookies cannot be disabled.
• Performance and Analytics Cookies: These cookies collect information about how visitors use our website, such as which pages are visited most often and whether users encounter error messages. We use this data to improve site performance.
• Functionality Cookies: These cookies allow our website to remember choices you make (such as your preferred language or region) and provide enhanced, personalized features.
• Marketing and Targeting Cookies: These cookies are used to deliver advertisements relevant to your interests. They may also be used to limit the number of times you see an advertisement and to measure the effectiveness of advertising campaigns.

9.2 Managing Your Cookie Preferences

You can control and manage cookies in several ways:

• Using the cookie preference settings presented when you first visit our website
• Adjusting your browser settings to refuse all or certain cookies
• Opting out of analytics tracking through tools such as the Google Analytics Opt-Out Browser Add-On

Please note that disabling certain cookies may affect your ability to use some features of our website.

For more detailed information about the specific cookies we use and how to manage them, please refer to our Cookie Policy available on our website.

10. Children's Privacy

Our website and services are intended for use by individuals who are 18 years of age or older. We do not knowingly collect, solicit, or use personal information from children under the age of 13. Our practices are aligned with the Children's Online Privacy Protection Act (COPPA).

If we become aware that we have inadvertently collected personal information from a child under the age of 13 without verified parental consent, we will take immediate steps to delete that information from our records. If you believe we may have collected information from a child under 13, please contact us immediately at [email protected].

Individuals between the ages of 13 and 17 should obtain parental or guardian consent before using our services or submitting any personal information through our website.

11. International Data Transfers

Primo Hoagies is based in the United States, and the information we collect is governed by U.S. law. Our servers and operations are primarily located within the United States. However, some of our third-party service providers may operate in other countries and may process your personal data in those jurisdictions.

If you are accessing our website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country of residence. By using our website and providing your personal information, you consent to this transfer.

We take steps to ensure that any international transfers of personal data are conducted in compliance with applicable law and that appropriate safeguards are in place to protect your information. If you have questions about our international data transfer practices, please contact us at [email protected].

12. Third-Party Websites and Links

Our website may contain links to third-party websites, social media platforms, or other services that are not owned or operated by Primo Hoagies. This Privacy Policy does not apply to those third-party websites, and we are not responsible for their privacy practices.

We encourage you to review the privacy policies of any third-party websites you visit before submitting personal information. The inclusion of a link on our website does not imply endorsement of that third party's privacy practices.

13. Do Not Track Signals

Some web browsers have a "Do Not Track" (DNT) feature that signals to websites that the user does not wish to be tracked. Currently, there is no universally agreed-upon standard for how websites should respond to DNT signals. As a result, our website does not currently respond to DNT browser signals.

However, you may use the cookie preference tools described in Section 9 to limit tracking on our website.

14. FTC Act Compliance

As a business operating in the United States, Primo Hoagies is subject to the authority of the Federal Trade Commission (FTC) under the Federal Trade Commission Act. We are committed to maintaining fair and transparent data practices in accordance with FTC guidelines.

We do not engage in deceptive or unfair practices with respect to the collection, use, or disclosure of your personal information. Our privacy practices are designed to be clear, honest, and consistent with our stated commitments in this Privacy Policy. If we become aware that our practices do not reflect the promises made in this Policy, we will take immediate corrective action.

15. How to File a Privacy Complaint

If you have a concern about how we are handling your personal information, we encourage you to contact us first so that we may address the issue directly.

15.1 Contact Us

Please submit your complaint or concern to us by email at:

Email: [email protected]
Website: primohoagiesnew.rest

We will acknowledge receipt of your complaint within 10 business days and aim to resolve it within 30 to 45 days. If we need additional time, we will inform you of the reason and the expected resolution timeline.

15.2 Filing a Complaint with a Regulatory Authority

If you are not satisfied with our response, or if you believe we are not processing your personal information in accordance with applicable law, you have the right to file a complaint with the relevant data protection authority.

For California Residents:
You may file a complaint with the California Privacy Protection Agency (CPPA):

• Website: https://cppa.ca.gov

For All U.S. Residents:
You may file a complaint with the Federal Trade Commission (FTC):

• Website: https://www.ftc.gov/complaint
• Phone: 1-877-382-4357

16. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page
• Post a notice on our website homepage
• Where required by law or appropriate, notify you by email

Your continued use of our website after any changes to this Privacy Policy constitutes your acceptance of the revised policy. We encourage you to review this page periodically to stay informed about how we are protecting your information.

17. Contact Information for Privacy Inquiries

If you have any questions, concerns, or requests related to this Privacy Policy or our data practices, please do not hesitate to reach out to us:

We are dedicated to resolving any privacy concerns you may have in a prompt, fair, and transparent manner. Your privacy matters to us, and we are committed to maintaining your trust by handling your personal information responsibly and in accordance with this Privacy Policy and all applicable laws.