Privacy Policy

Welcome to Primo Hoagies (referred to herein as "we," "us," "our," or "the Company"). We operate the website primohagiesgo.click and provide food-related products and services to our valued customers across the United States. We are deeply 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, place orders, interact with our services, or otherwise engage with us.

Please read this Privacy Policy carefully. If you disagree with its terms, please discontinue use of our website and services immediately. This policy applies to all information collected through our website (primohagiesgo.click), and any related services, sales, marketing, or events.

If you have questions or concerns about this policy, or our practices with regard to your personal information, please contact us at [email protected].

1. About Us

Primo Hoagies is a food service business operating within the United States. We offer a wide range of food products and dining options designed to bring quality and flavor to our customers. Our contact details for all privacy-related inquiries are as follows:

2. Information We Collect

We collect various types of information in connection with the services we provide. The categories of personal information we may collect include, but are not limited to, the following:

2.1 Personal Identification Information

When you register on our website, place an order, subscribe to our newsletter, or contact us for support, we may collect information such as:

• Full name
• Email address
• Mailing or delivery address
• Phone number
• Date of birth (where age verification is required)
• Username and password (for registered accounts)
• Payment and billing information (processed securely through third-party payment processors)
• Dietary preferences or food allergy information you voluntarily provide

2.2 Order and Transaction Information

When you place an order with us, we collect information related to the transaction, including:

• Items ordered
• Order history and frequency
• Delivery or pickup preferences
• Special instructions or customization requests
• Transaction amounts and payment methods used

2.3 Usage Data and Technical Information

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

• IP address
• Browser type and version
• Operating system
• Referring URLs
• Pages visited and time spent on those pages
• Links clicked and features used
• Time and date of access
• Device identifiers and device type (desktop, mobile, tablet)
• Geographic location data (derived from IP address)

2.4 Cookies and Tracking Technologies

We use cookies, web beacons, pixel tags, and similar tracking technologies to collect information about your interactions with our website. This helps us understand user preferences, improve our services, and deliver more relevant content and advertising. Please refer to Section 9 of this policy for more detailed information about our use of cookies.

2.5 Communications and Feedback

If you contact us via email, our website contact form, or any other communication channel, we may retain records of that correspondence, including:

• The content of your messages or inquiries
• Your feedback, reviews, or survey responses
• Customer service interaction records

2.6 Information from Third Parties

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

• Social media platforms (if you interact with our social media pages or log in using social credentials)
• Marketing and advertising partners
• Analytics providers
• Delivery and logistics partners
• Payment processors and fraud prevention services

3. How We Use Your Information

We use the information we collect for a variety of legitimate business purposes, including:

3.1 Service Provision and Order Fulfillment

• To process and fulfill your food orders
• To manage your account and provide customer support
• To communicate order confirmations, receipts, and delivery updates
• To respond to your inquiries, complaints, or requests
• To process payments and prevent fraudulent transactions

3.2 Personalization and User Experience

• To remember your preferences and customize your experience on our website
• To recommend menu items or promotions based on your past orders
• To save your delivery address and order history for convenience

3.3 Analytics and Service Improvement

• To monitor and analyze usage patterns, traffic, and trends on our website
• To evaluate the effectiveness of our features and content
• To develop new products, services, and features
• To diagnose technical problems and maintain website security

3.4 Marketing and Promotional Communications

• To send you promotional emails, newsletters, and special offers (with your consent where required)
• To deliver targeted advertisements through third-party platforms
• To notify you about loyalty rewards, new menu items, or limited-time promotions
• To conduct surveys and gather feedback to improve our offerings

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

3.5 Legal Compliance and Safety

• To comply with applicable federal, state, and local laws and regulations
• To enforce our Terms of Service and other agreements
• To protect the rights, property, and safety of Primo Hoagies, our customers, and the public
• To respond to lawful requests from government authorities or law enforcement

4. Legal Basis for Processing

We process your personal information based on one or more of the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill your orders and provide the services you have requested.
• Legitimate Interests: We process data where we have a legitimate interest in doing so (e.g., fraud prevention, marketing to existing customers, improving our services), provided those interests are not overridden by your rights.
• Consent: Where you have given your explicit consent to a specific type of processing (e.g., subscribing to our newsletter or accepting non-essential cookies).
• Legal Obligation: Where we are required to process your data to comply with a legal obligation under federal or state law.

5. Sharing Your Information with Third Parties

We do not sell your personal information. However, we may share your information with certain third parties under the circumstances described below:

5.1 Service Providers and Business Partners

We work with trusted third-party companies and individuals to help us operate our website and provide our services. These service providers may have access to your personal information only to the extent necessary to perform their functions and are contractually obligated to keep your information confidential. Categories of service providers include:

• Payment processors and financial institutions
• Delivery and logistics companies
• Cloud hosting and IT infrastructure providers
• Email marketing and communication platforms
• Analytics and website performance tools (e.g., Google Analytics)
• Customer relationship management (CRM) software providers
• Advertising networks and remarketing platforms
• Fraud detection and security services

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 requests by public authorities, including:

• In response to a court order, subpoena, or other legal process
• To comply with applicable federal or state laws and regulations
• To protect the rights and safety of Primo Hoagies, our employees, customers, or the public
• To detect, prevent, or address fraud, security issues, or technical problems

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website before your data is transferred and becomes subject to a different privacy policy.

5.4 Affiliates

We may share your information with our corporate affiliates, subsidiaries, or parent companies, who are required to honor this Privacy Policy.

5.5 With Your Consent

We may share your personal information with third parties for purposes not described in this policy when we have obtained your explicit prior consent to do so.

6. Data Security

We take the security of your personal information seriously and implement a variety of administrative, technical, and physical security measures designed to protect your data from unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encryption: We use industry-standard SSL/TLS encryption to protect data transmitted between your browser and our servers.
• Secure Payment Processing: All payment card information is processed through PCI-DSS compliant third-party payment processors. We do not store full credit card numbers on our servers.
• Access Controls: Access to personal data is restricted to authorized personnel who need it to perform their job functions, and all staff are bound by confidentiality obligations.
• Firewalls and Intrusion Detection: We employ firewalls, intrusion detection systems, and monitoring tools to protect our network and systems.
• Regular Security Audits: We periodically review and update our security practices to address emerging threats and vulnerabilities.
• Data Minimization: We only collect the minimum amount of personal data necessary for the intended purpose.

7. 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 U.S. federal and state privacy laws, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and the Federal Trade Commission (FTC) Act.

7.1 Right to Know and Access

You have the right to request that we disclose what personal information we have collected, used, disclosed, and sold about you over the past 12 months. This includes the categories of personal information, the sources from which it was collected, the business purpose for collecting it, the categories of third parties with whom it was shared, and the specific pieces of personal information we hold about you.

7.2 Right to Correction

You have the right to request that we correct inaccurate personal information we maintain about you, taking into account the nature of the information and the purposes for which it is processed.

7.3 Right to Deletion

You have the right to request that we delete personal information we have collected from you, subject to certain exceptions provided by law (e.g., where retention is necessary for completing a transaction, detecting security incidents, or complying with a legal obligation).

7.4 Right to Opt Out of Sale or Sharing

We do not sell your personal information for monetary consideration. However, to the extent that sharing data with advertising partners for cross-context behavioral advertising may be considered a "sale" or "sharing" under California law, you have the right to opt out. You may exercise this right by contacting us at [email protected].

7.5 Right to Data Portability

Where technically feasible, you have the right to receive a copy of your personal information in a structured, commonly used, machine-readable format, and to transfer it to another organization.

7.6 Right to Limit Use of Sensitive Personal Information

Under the CPRA, California residents have the right to limit our use and disclosure of sensitive personal information (such as government-issued IDs, financial account data, or precise geolocation) to purposes reasonably necessary to provide requested services.

7.7 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, provide a different quality of service, or suggest you will receive a different level of service as a result of exercising your rights.

7.8 How to Exercise Your Rights

To exercise any of the rights described above, please submit a verifiable consumer request to us by:

• Email: [email protected]
• Website: primohagiesgo.click

We will respond to your request within 45 days of receipt. If we require more time, we will inform you of the reason and the extension period (up to an additional 45 days) in writing. We may need to verify your identity before fulfilling your request. You may also designate an authorized agent to make a request on your behalf, provided proper authorization is established.

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. Our data retention practices are as follows:

When personal information is no longer required for any lawful purpose, we will securely delete, destroy, or anonymize it in accordance with our internal data retention and disposal procedures.

9. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze site traffic, and deliver relevant content and advertising. A cookie is a small text file stored on your device when you visit our website.

9.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the operation of our website (e.g., maintaining your session, enabling checkout functionality). These cannot be disabled.
• Performance and Analytics Cookies: These cookies collect anonymous information about how visitors use our website (e.g., Google Analytics), helping us improve performance and user experience.
• Functional Cookies: These enable enhanced functionality and personalization, such as remembering your language preferences or saved delivery addresses.
• Targeting and Advertising Cookies: Used to deliver ads that are more relevant to you and your interests, and to measure the effectiveness of advertising campaigns.

9.2 Managing Your Cookie Preferences

You may control or disable cookies through your browser settings. Most browsers allow you to refuse or delete cookies. However, please note that disabling cookies may impact the functionality of our website and your ability to use certain features. You may also opt out of interest-based advertising through the Network Advertising Initiative (NAI) at www.networkadvertising.org or the Digital Advertising Alliance (DAA) at www.aboutads.info.

For more detailed information about the cookies we use, their purposes, and how long they remain on your device, please refer to our full Cookie Policy available on our website at primohagiesgo.click.

10. Children's Privacy

Primo Hoagies does not direct its food ordering services, website content, or marketing communications to children under 18. In compliance with the Children's Online Privacy Protection Act (COPPA), we do not knowingly collect personal information from children under the age of 13 without verifiable parental consent.

If we become aware that we have inadvertently collected personal information from a child under 18 without appropriate consent, we will take immediate steps to delete that information from our systems. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at [email protected] so we can take appropriate action.

11. International Data Transfers

Primo Hoagies is a United States-based business, and our primary data processing activities occur within the United States. If you access our website or services 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 us with your personal information, you acknowledge and consent to the transfer of your information to the United States. We take appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Policy and applicable data protection laws, regardless of where it is processed.

If you are located in a jurisdiction with specific data transfer requirements (such as the European Economic Area), please note that while our primary market is the United States, we are committed to ensuring any cross-border transfers comply with applicable legal frameworks. Please contact us if you have specific questions about international data transfers as they may apply to you.

12. California Privacy Rights (CCPA/CPRA)

If you are a resident of the State of California, you have specific privacy rights under the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act of 2020 (CPRA). This section supplements the information provided in Section 7 of this Privacy Policy.

12.1 Categories of Personal Information Collected

In the past 12 months, we have collected the following categories of personal information as defined by the CCPA:

• Identifiers (name, email address, IP address, device identifiers)
• Personal information categories listed in the California Customer Records statute (name, address, phone number, payment information)
• Commercial information (order history, products purchased)
• Internet or other electronic network activity (browsing history, interactions with our website)
• Geolocation data (general location derived from IP address)
• Inferences drawn from personal information to create a profile about you

12.2 Sources of Personal Information

We collect personal information directly from you, automatically from your device as you use our website, and from third-party partners as described in Section 2.6 of this policy.

12.3 Business Purposes for Collection

We collect personal information for the business and commercial purposes described in Section 3 of this Privacy Policy.

12.4 "Do Not Sell or Share My Personal Information"

California residents have the right to opt out of the sale or sharing of their personal information. As stated above, we do not sell personal information. If our sharing practices with advertising technology partners are considered "sharing" under CPRA, you may submit an opt-out request by emailing us at [email protected] with the subject line "Do Not Sell or Share My Personal Information."

12.5 Shine the Light Law

California's "Shine the Light" law (Civil Code § 1798.83) permits California residents to request information about the personal data we disclose to third parties for direct marketing purposes. To make such a request, please contact us at [email protected].

13. Federal Consumer Protection Laws

Our privacy practices are also governed by applicable federal laws, including regulations enforced by the Federal Trade Commission (FTC) under the FTC Act (15 U.S.C. § 41 et seq.), which prohibits unfair or deceptive practices in commerce, including the misuse of consumer data. We are committed to complying with all applicable FTC guidelines and rules regarding privacy notices, data security, and consumer protection.

14. Third-Party Links and Services

Our website may contain links to third-party websites, applications, or services that are not operated by us. For example, we may link to social media platforms, delivery service partners, or promotional partners. We have no control over the content, privacy policies, or practices of these third-party sites and are not responsible for them.

We strongly encourage you to review the privacy policy of every website you visit. The inclusion of a link on our website does not imply our endorsement of the linked site or its content.

15. How to File a Complaint

If you believe your privacy rights have been violated, we encourage you to first contact us directly so we can attempt to resolve the issue:

• Email: [email protected]
• Website: primohagiesgo.click

We will investigate all complaints and respond within a reasonable timeframe. If you are not satisfied with our response, you may escalate your complaint to the relevant data protection or consumer protection authorities:

15.1 Federal Trade Commission (FTC)

The FTC is the primary federal agency responsible for consumer protection and privacy enforcement in the United States. You may file a complaint with the FTC at:

• Website: www.ftc.gov/complaint
• Phone: 1-877-FTC-HELP (1-877-382-4357)
• Mail: Federal Trade Commission, 600 Pennsylvania Avenue NW, Washington, DC 20580

15.2 California Residents – California Privacy Protection Agency (CPPA)

California residents may file a complaint with the California Privacy Protection Agency (CPPA), which oversees enforcement of the CCPA/CPRA:

• Website: cppa.ca.gov
• Email: [email protected]

15.3 State Attorney General

Residents of any U.S. state may also file complaints with their respective State Attorney General's office regarding potential violations of state consumer protection or privacy laws. Contact information for your State Attorney General can be found through the National Association of Attorneys General (NAAG) at www.naag.org.

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 to this policy, we will notify you by:

• Updating the "Last Updated" date at the top of this page
• Sending an email notification to the address associated with your account (where applicable)
• Posting a prominent notice on our website

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 and services after the posting of changes constitutes your acceptance of those changes.

17. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please do not hesitate to contact our Privacy Team:

We are committed to working with you to resolve any concerns you may have about the way we handle your personal information. All privacy inquiries will be acknowledged within 5 business days and fully addressed within 30 days, unless additional time is required due to the complexity of the request.