Privacy Policy

This Privacy Policy describes how Primo Hoagies ("we," "us," "our," or "the Company") collects, uses, discloses, and protects your personal information when you visit our website at hoagies-primo.click (the "Website"), place orders, use our online services, or otherwise interact with us. We are committed to protecting your privacy and handling your personal data in a transparent, lawful, and responsible manner.

Please read this Privacy Policy carefully before using our Website or submitting any personal information. By accessing or using our Website, you acknowledge that you have read, understood, and agree to the practices described in this policy. If you do not agree with any part of this policy, please discontinue use of our Website and services immediately.

We operate in the United States and comply with applicable federal and state privacy laws, including but not limited to the Federal Trade Commission Act (FTC Act), the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), the CAN-SPAM Act, and other applicable state consumer protection statutes. Where applicable, we also adhere to food industry-specific regulations and data handling standards.

1. Who We Are

Primo Hoagies is a food service business operating in the United States. We provide fresh, high-quality hoagie sandwiches and related food products to our customers through our physical locations and digital platforms, including our Website at hoagies-primo.click.

For all privacy-related inquiries, concerns, or requests, you may contact us using the following information:

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 collect are described below.

2.1 Personal Information You Provide Directly

When you interact with our Website, create an account, place an order, subscribe to our newsletter, fill out a contact form, participate in promotions, or communicate with us, you may voluntarily provide us with personal information, including:

• Identity Information: First name, last name, username, or similar identifiers.
• Contact Information: Email address, telephone number, billing address, delivery address, and physical location (for order fulfillment purposes).
• Account Credentials: Username, password, and security questions used to create and manage your account on our platform.
• Order and Transaction Information: Details about the food products you purchase, order history, special dietary requests or allergen information you choose to disclose, payment method type (we do not store full payment card numbers), and billing records.
• Communications: Messages, feedback, complaints, or reviews you submit to us through forms, email, or customer service channels.
• Marketing Preferences: Your preferences regarding receiving marketing communications from us, including newsletter subscriptions and promotional offers.
• Survey and Promotion Data: Responses you provide when participating in surveys, contests, sweepstakes, or promotional campaigns.

2.2 Information Collected Automatically

When you access or use our Website, certain information is collected automatically through the use of cookies, web beacons, pixel tags, log files, and similar tracking technologies. This automatically collected data may include:

• Device Information: IP address, device type, device identifier, operating system, browser type and version, screen resolution, language settings, and hardware configuration.
• Usage Data: Pages you visit on our Website, time spent on each page, links clicked, features accessed, referring URLs (the website you came from before visiting ours), search terms used on our Website, and navigation patterns.
• Log Data: Server log files that record each request made to our servers, including timestamps, error reports, and access records.
• Location Data: General geographic location derived from your IP address (such as city or state). We do not collect precise GPS-based location unless you explicitly grant permission.
• Cookie Data: Information stored in cookies placed on your browser. Please see Section 8 (Cookie Usage) for more detailed information.
• Interaction Data: Information about how you interact with our emails and digital advertisements, including open rates, click-through rates, and conversion events.

2.3 Information Received from Third Parties

We may receive personal information about you from third-party sources, which we combine with information we collect directly. These sources include:

• Payment Processors: Transaction confirmation data and fraud prevention signals from our authorized payment processing partners.
• Analytics Providers: Aggregated and de-identified behavioral data from analytics services that help us understand how users interact with our Website.
• Social Media Platforms: If you interact with our social media pages, follow our accounts, or use social login features, those platforms may share certain information with us in accordance with their own privacy policies and your account settings.
• Delivery and Logistics Partners: Information needed to fulfill delivery orders, including delivery confirmation and address verification data.
• Marketing Partners: Information about your interests and demographics from advertising networks that help us serve relevant promotional content.
• Publicly Available Sources: Publicly available information such as business directories, public records, and other publicly accessible databases.

2.4 Sensitive Personal Information

We do not intentionally collect sensitive categories of personal information such as racial or ethnic origin, political opinions, religious beliefs, genetic data, or biometric data. However, if you voluntarily disclose dietary restrictions, allergies, or health-related food preferences when placing an order, we will use this information solely for the purpose of fulfilling your food order safely and accurately. We treat such information with heightened care and do not use it for marketing or analytics purposes.

3. How We Use Your Information

We use the personal information we collect for specific, legitimate, and documented purposes. We do not use your data for purposes that are incompatible with those stated below without providing you with prior notice.

3.1 Service Provision and Order Fulfillment

• To process and fulfill your food orders, including preparation, packaging, and delivery coordination.
• To manage your account and provide you with access to account features and order history.
• To communicate with you about your orders, including order confirmations, updates, and delivery notifications.
• To handle returns, refunds, complaints, and customer service inquiries.
• To verify your identity and authenticate your account for security purposes.

3.2 Business Operations and Administration

• To maintain and improve our Website's functionality, performance, and user experience.
• To troubleshoot technical issues and conduct quality assurance testing.
• To manage our internal business records, accounting, and compliance obligations.
• To enforce our Terms of Service and other applicable agreements.
• To detect, prevent, and respond to fraud, unauthorized access, and other illegal activities.

3.3 Analytics and Performance Measurement

• To analyze usage patterns on our Website and understand which features and content are most valuable to our users.
• To measure the effectiveness of our marketing campaigns and promotional activities.
• To conduct market research and gain insights into consumer preferences related to our food products and services.
• To generate aggregated, de-identified statistical reports about our user base and business performance.

3.4 Marketing and Communications

• To send you promotional emails, newsletters, special offers, and information about new menu items, seasonal promotions, or loyalty program updates — but only if you have opted in or otherwise consented to receiving such communications.
• To personalize your Website experience and display content, offers, and recommendations tailored to your preferences and past orders.
• To serve you relevant advertisements on our Website and third-party platforms, using cookie-based or interest-based targeting.
• To conduct surveys, competitions, and promotional campaigns in which you choose to participate.

Your Right to Opt Out: You may opt out of marketing communications at any time by clicking the "unsubscribe" link in any marketing email, updating your preferences in your account settings, or contacting us at [email protected]. Opting out of marketing will not affect transactional communications related to active orders.

3.5 Legal Compliance and Safety

• To comply with applicable laws, regulations, legal processes, and lawful government requests.
• To protect the rights, property, and safety of our company, our employees, our customers, and the public.
• To respond to lawful requests from law enforcement, regulatory bodies, or courts of competent jurisdiction.

4. Sharing Your Information with Third Parties

We do not sell your personal information to third parties for monetary compensation. However, we may share your personal information with the following categories of recipients under the circumstances described below.

4.1 Service Providers and Business Partners

We engage trusted third-party companies and individuals to perform services on our behalf, such as:

• Payment processing and fraud prevention services.
• Food delivery and logistics companies (when applicable).
• Website hosting, cloud storage, and IT infrastructure providers.
• Customer relationship management (CRM) platforms.
• Email marketing and communications service providers.
• Analytics and data insights providers (such as Google Analytics).
• Advertising networks and digital marketing platforms.
• Legal, accounting, and professional advisory services.

These service providers are contractually obligated to handle your information only as directed by us, to maintain appropriate security standards, and not to use your information for their own independent purposes.

4.2 Legal Requirements and Law Enforcement

We may disclose your personal information if required to do so by law, or if we believe in good faith that such disclosure is necessary to:

• Comply with a legal obligation, court order, subpoena, or governmental request.
• Enforce our Terms of Service or other agreements.
• Protect and defend the rights or property of Primo Hoagies.
• Prevent or investigate possible wrongdoing in connection with our services.
• Protect the personal safety of our users, employees, or the public.

4.3 Business Transfers

If Primo Hoagies undergoes a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of its assets, your personal information may be transferred as part of that transaction. We will notify you via email or a prominent notice on our Website before your personal information becomes subject to a materially different privacy policy as a result of such a transaction.

4.4 Aggregated or De-Identified Data

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you with third parties for marketing research, industry analysis, or other legitimate purposes.

4.5 With Your Consent

We may share your personal information with other third parties when you have explicitly given us your consent to do so, for example, when you participate in a co-branded promotion or loyalty partnership.

5. Data Security

We take the security of your personal information seriously and have implemented a range of technical, administrative, and physical safeguards designed to protect your data from unauthorized access, disclosure, alteration, or destruction.

5.1 Security Measures We Employ

• Encryption: We use industry-standard SSL/TLS encryption to protect data transmitted between your browser and our servers. Sensitive information such as payment data is encrypted both in transit and at rest.
• Access Controls: Access to personal data is restricted to authorized employees and contractors who need it to perform their job functions. We enforce role-based access controls and require strong authentication.
• Secure Payment Processing: We do not store full credit card numbers on our servers. Payment transactions are processed by PCI-DSS compliant third-party payment processors.
• Regular Security Audits: We conduct periodic reviews of our data collection, storage, and processing practices to identify and remediate potential security vulnerabilities.
• Incident Response: We maintain a data breach response plan and will notify affected users and relevant authorities in the event of a qualifying security incident as required by applicable law.
• Employee Training: Our staff receives regular training on data privacy best practices and their obligations under this Privacy Policy.

6. Your Privacy Rights

Depending on your state of residence, you may have certain rights with respect to your personal information. We are committed to honoring these rights in accordance with applicable federal and state law.

6.1 Rights Available to All Users

• Right to Know / Access: You have the right to request information about the categories and specific pieces of personal data we have collected about you, the sources of that data, the purposes for which we use it, and the categories of third parties with whom we share it.
• Right to Correction: You have the right to request that we correct inaccurate or incomplete personal information we hold about you.
• Right to Deletion: You have the right to request the deletion of personal information we have collected about you, subject to certain exceptions (such as where we are legally required to retain the information).
• Right to Opt Out of Marketing: You have the right to opt out of receiving marketing communications from us at any time.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights. We will not deny you goods or services, charge you different prices, or provide you with a lower quality of service because you exercised your privacy rights.

6.2 Additional Rights for California Residents (CCPA/CPRA)

If you are a resident of California, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Right to Know (Detailed): The right to request disclosure of specific pieces of personal information collected about you over the past 12 months.
• Right to Opt Out of Sale or Sharing: The right to opt out of the sale or sharing of your personal information for cross-context behavioral advertising. To exercise this right, click on "Do Not Sell or Share My Personal Information" or contact us at [email protected].
• Right to Limit Use of Sensitive Personal Information: The right to limit the use and disclosure of your sensitive personal information to that which is necessary to perform the requested services.
• Right to Data Portability: The right to receive a copy of your personal information in a portable, usable format, where technically feasible.
• Right to Appeal: If we decline to act on your request, you have the right to appeal our decision. Instructions for submitting an appeal will be provided in any denial notice we send you.

6.3 Additional Rights Under Other State Laws

Residents of other U.S. states including, but not limited to, Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Texas (TDPSA), Florida (FDBR), and other states with enacted privacy legislation may have similar rights to access, correct, delete, and port their personal data, and to opt out of certain data processing activities. We honor these rights in compliance with applicable state laws.

6.4 How to Submit a Privacy Rights Request

To exercise any of your privacy rights, you may contact us through the following channels:

• Email: [email protected]
• Website: hoagies-primo.click

We will acknowledge receipt of your request within 10 business days and will respond substantively within 45 calendar days. If we require additional time (up to a total of 90 days), we will notify you in writing and explain the reason for the delay. We may need to verify your identity before processing your request to protect your data from unauthorized disclosure or deletion.

7. Data Retention

We retain your personal information only for as long as is necessary to fulfill the purposes for which it was collected, comply with our legal obligations, resolve disputes, enforce our agreements, and support our legitimate business operations. The following general retention guidelines apply:

After the applicable retention period, we will securely delete or anonymize your personal information in accordance with our internal data destruction procedures.

8. Cookie Usage

Our Website uses cookies and similar tracking technologies (including web beacons, pixel tags, and local storage objects) to enhance your browsing experience, analyze usage patterns, and deliver relevant advertising.

8.1 Types of Cookies We Use

• Strictly Necessary Cookies: These cookies are essential for the Website to function and cannot be switched off. They enable core features such as shopping cart management, session authentication, and security.
• Performance and Analytics Cookies: These cookies collect information about how visitors use our Website, including which pages are most visited and whether users encounter error messages. This data helps us improve Website performance.
• Functionality Cookies: These cookies allow our Website to remember your preferences (such as your location, language, and previously selected menu items) to provide a more personalized experience.
• Targeting and Advertising Cookies: These cookies are set by us and our advertising partners to build a profile of your interests and show you relevant advertisements on our Website and other sites across the internet.

8.2 Managing Your Cookie Preferences

You can control and manage cookies through your browser settings. Most browsers allow you to refuse all cookies, accept only certain types, or delete cookies that have already been placed on your device. Please note that disabling certain cookies may impair the functionality of our Website. For more detailed information about the specific cookies we use, their purposes, durations, and how to manage them, please refer to our full Cookie Policy, available on our Website.

9. 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 process personal information from individuals under the age of 18.

If you are a parent or guardian and believe that your child under the age of 18 has provided us with personal information without your consent, please contact us immediately at [email protected]. Upon receiving such a notification, we will take prompt steps to delete the relevant information from our records.

We comply with the Children's Online Privacy Protection Act (COPPA) and do not direct any portion of our Website or online services toward children under the age of 13. If we discover that we have inadvertently collected personal information from a child under 13, we will delete it as soon as reasonably practicable.

10. International Data Transfers

Primo Hoagies is based in the United States, and the personal information we collect is primarily stored and processed on servers located within the United States. However, some of our third-party service providers may be located in, or operate servers in, countries outside the United States.

If we transfer your personal information outside of the United States, we take steps to ensure that your information receives an adequate level of protection wherever it is processed. These steps may include:

• Entering into data processing agreements with our service providers that include standard contractual clauses or equivalent data transfer safeguards.
• Only transferring data to countries or service providers that provide an adequate level of data protection as determined by applicable law.
• Implementing technical and organizational measures to ensure the security of transferred data.

By using our Website and services, you acknowledge and agree that your personal information may be transferred to and processed in the United States or other countries where privacy laws may differ from those in your home jurisdiction. We are committed to ensuring that any such transfers are carried out lawfully and securely.

11. Third-Party Links and Services

Our Website may contain links to third-party websites, applications, social media platforms, or other online services that are not operated or controlled by Primo Hoagies. This Privacy Policy applies only to our Website and our services. We are not responsible for the privacy practices of any third-party websites, and we encourage you to review the privacy policies of any external services you visit.

We also integrate third-party tools and services on our Website, such as social media sharing buttons, embedded maps, and video players. These third parties may collect information about your interactions with their features, independent of our data collection practices.

12. FTC Compliance and Consumer Protection

Primo Hoagies is subject to the jurisdiction of the Federal Trade Commission (FTC) under Section 5 of the FTC Act, which prohibits unfair or deceptive acts or practices in or affecting commerce. We are committed to complying with all applicable FTC regulations and guidance, including the FTC's standards for online privacy, data security, and truthful advertising.

Our marketing communications comply with the CAN-SPAM Act. All commercial emails we send include a clear identification of the sender, a valid physical address, a clear subject line that accurately represents the content, and an easy-to-use opt-out mechanism. We honor opt-out requests within 10 business days.

If you believe that we have engaged in any deceptive or unfair practice, you may file a complaint with the FTC at www.ftc.gov or by calling 1-877-FTC-HELP (1-877-382-4357).

13. How to File a Complaint

If you have concerns about how we handle your personal information and are not satisfied with our response, you have the right to file a complaint with the appropriate regulatory authority. In the United States, the following resources are available to you:

• Federal Trade Commission (FTC): www.ftc.gov/complaint | Phone: 1-877-382-4357
• California Residents – California Privacy Protection Agency (CPPA): cppa.ca.gov
• California Attorney General: oag.ca.gov/privacy
• Your State Attorney General's Office: Most states have an Attorney General's office that handles consumer privacy complaints. You can find your state's office through the National Association of Attorneys General at www.naag.org.

We encourage you to contact us first at [email protected] so that we have the opportunity to address your concerns directly before you escalate to a regulatory authority.

14. Changes to This Privacy Policy

We reserve the right to update, modify, or revise this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes to this policy, we will:

• Post the updated Privacy Policy on this page with a new "Last Updated" date.
• Send an email notification to registered users (where we have your email address and such notification is required by law).
• Display a prominent banner or notice on our Website to draw attention to the changes.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of our Website after any changes to this policy constitutes your acceptance of the revised policy. If you do not agree to the updated terms, you should discontinue use of our Website and contact us to request deletion of your personal data.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data handling practices, or if you wish to exercise any of your privacy rights, please do not hesitate to contact us:

We are dedicated to resolving privacy-related inquiries promptly and professionally. We will make every effort to respond to your inquiry within 10 business days of receipt.