Privacy Policy

Effective Date: July 2, 2026  |  Last Updated: July 2, 2026

1. Introduction and Scope

Welcome to Primo Hoagies. We are committed to protecting the privacy and security of your personal information. This Privacy Policy applies to all personal data collected through our website primohoagiesnew.click, our online ordering systems, our customer communications, and any other digital or physical touchpoints where we collect your information.

This policy is designed to comply with applicable United States federal and state privacy laws, including but not limited to the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), the Federal Trade Commission Act (FTC Act), and other relevant federal and state consumer protection regulations. We take our obligations under these laws seriously and are dedicated to maintaining transparency about our data practices.

This Privacy Policy governs:

• All visitors to our website, whether or not they place an order
• Customers who place online or in-store orders
• Individuals who subscribe to our newsletters or marketing communications
• Individuals who participate in promotions, surveys, or loyalty programs
• Job applicants and prospective employees
• Any individual who contacts us for support or inquiries

If you do not agree to the terms of this Privacy Policy, please discontinue use of our website and services immediately. For questions or concerns, please refer to the contact information provided in Section 14 of this policy.

2. Information We Collect

We collect various categories of personal information depending on how you interact with Primo Hoagies. The information we gather falls into the following broad categories:

2.1 Personal Identification Information

When you create an account, place an order, or contact us, we may collect:

• Full name (first and last)
• Email address
• Phone number
• Billing and shipping address
• Date of birth (where applicable for age verification or loyalty programs)
• Profile username and password (encrypted)
• Payment information (processed securely through third-party payment processors; we do not store full credit card numbers)
• Dietary preferences and food allergy information (when voluntarily provided)

2.2 Order and Transaction Data

When you place an order through our website, we collect:

• Order history, including items ordered, quantities, and customizations
• Order totals, discounts applied, and payment method type (e.g., credit card, debit card, digital wallet)
• Delivery or pickup preferences
• Special instructions or notes associated with orders
• Transaction confirmation numbers and timestamps

2.3 Usage and Technical Data

When you visit our website, we automatically collect certain technical information, including:

• Internet Protocol (IP) address
• Browser type, version, and language settings
• Operating system and device type (desktop, mobile, tablet)
• Referring URLs (the website you visited before ours)
• Pages viewed on our website, time spent on each page, and navigation paths
• Search queries entered on our website
• Click-through behavior and interaction patterns
• Time zone and geographic region (derived from IP address)
• Session duration and frequency of visits

2.4 Cookie and Tracking Technology Data

We use cookies, web beacons, pixel tags, local storage, and similar tracking technologies to collect information about your browsing activities. This data helps us improve our website, remember your preferences, and deliver relevant content. Please refer to Section 9 of this policy for detailed information about our cookie practices.

2.5 Communications Data

When you contact us via email, phone, or any other channel, we collect:

• The content of your messages, inquiries, complaints, or feedback
• Your contact details as provided in the communication
• Records of our responses to your inquiries
• Call recordings, where permitted by law and after appropriate notice

2.6 Marketing and Preference Data

If you opt in to marketing communications or loyalty programs, we collect:

• Email subscription preferences and communication opt-ins/opt-outs
• Survey responses and feedback
• Loyalty program participation, points earned, and rewards redeemed
• Preferences you set regarding promotions and special offers

2.7 Information from Third Parties

We may also receive information about you from third parties, including:

• Social media platforms if you interact with our social media pages or use social login features
• Third-party delivery platforms or food aggregator services that process your orders
• Analytics and advertising partners who provide aggregated or pseudonymized data about user behavior
• Payment processors who confirm successful transactions

3. How We Use Your Information

Primo Hoagies uses the personal information we collect for several legitimate business purposes. We are committed to using your data only in ways that are consistent with this policy and applicable law.

3.1 Order Fulfillment and Service Delivery

• Processing and fulfilling your food orders, whether for pickup or delivery
• Communicating order confirmations, updates, and delivery tracking information
• Managing your account and providing access to order history
• Processing payments and issuing refunds where applicable
• Accommodating special dietary requirements or customizations you have requested

3.2 Customer Support

• Responding to inquiries, complaints, or requests for assistance
• Investigating and resolving issues with orders or transactions
• Providing follow-up communications to ensure your satisfaction

3.3 Analytics and Service Improvement

• Analyzing usage patterns to understand how customers interact with our website
• Identifying trends in menu preferences, popular items, and peak ordering times
• Conducting internal research and development to improve our menu, services, and technology
• Monitoring website performance and identifying technical issues
• A/B testing to improve user experience and interface design

3.4 Marketing and Communications

• Sending promotional emails, newsletters, and special offers (with your consent where required)
• Administering loyalty programs, contests, and promotions
• Personalizing marketing content based on your ordering history and preferences
• Delivering targeted advertising on third-party platforms (subject to your preferences)
• Notifying you of new menu items, seasonal specials, and location updates

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

3.5 Legal Compliance and Security

• Complying with applicable federal, state, and local laws and regulations
• Responding to lawful requests from government authorities, courts, or law enforcement
• Detecting, preventing, and investigating fraud, unauthorized access, or other illegal activities
• Enforcing our Terms of Service and other legal agreements
• Protecting the rights, property, and safety of Primo Hoagies, our customers, and the public

4. Sharing Your Information with Third Parties

We do not sell your personal information to third parties for monetary consideration. However, we may share your information with certain categories of third parties as described below. Under the CCPA/CPRA, some of these sharing practices may constitute a "sale" or "sharing" of personal information for cross-context behavioral advertising purposes. California residents may opt out of such practices as described in Section 11.

4.1 Service Providers and Business Partners

We engage third-party service providers who assist us in operating our business. These providers are contractually obligated to use your information only as directed by us and in accordance with this policy:

• Payment Processors: Secure processing of credit/debit card and digital wallet payments
• Delivery Platforms: Third-party delivery services that fulfill delivery orders on our behalf
• Email Marketing Platforms: Services used to manage and send promotional emails and newsletters
• Analytics Providers: Services such as Google Analytics that help us understand website usage
• Customer Support Tools: Platforms used to manage customer inquiries and support tickets
• Cloud Hosting Providers: Services that host our website and store data securely
• Loyalty Program Administrators: Third-party platforms used to manage rewards programs

4.2 Advertising and Analytics Partners

We may share pseudonymized or aggregated data with advertising networks and analytics companies to serve targeted advertisements and measure marketing effectiveness. This may include sharing data with platforms such as Meta (Facebook/Instagram), Google Ads, and similar services. These activities may be subject to opt-out rights under applicable law.

4.3 Legal and Regulatory Disclosures

We may disclose your information when we believe in good faith that disclosure is necessary to:

• Comply with a legal obligation, court order, or government request
• Enforce our Terms of Service or other agreements
• Protect against fraud, security threats, or illegal activity
• Protect the vital interests of any person

4.4 Business Transfers

In the event of a merger, acquisition, bankruptcy, reorganization, or sale of all or substantially all of our assets, your personal information may be transferred as part of that transaction. We will notify you via email or prominent notice on our website if such a transfer results in a material change to this Privacy Policy.

4.5 With Your Consent

We may share your information with other third parties if you have given us explicit consent to do so, such as through participation in co-branded promotions or partnerships.

5. Data Security

Primo Hoagies takes the security of your personal information seriously and employs a range of technical, administrative, and physical safeguards to protect your data from unauthorized access, loss, misuse, disclosure, or destruction.

5.1 Technical Safeguards

• Encryption: All data transmitted between your browser and our website is protected using SSL/TLS encryption (HTTPS).
• Secure Payment Processing: We use PCI-DSS compliant payment processors and do not store full credit card numbers on our servers.
• Access Controls: Access to personal data within our systems is restricted to authorized personnel on a need-to-know basis.
• Firewalls and Intrusion Detection: We maintain firewalls and monitoring systems to detect and prevent unauthorized access attempts.
• Password Hashing: User passwords are stored using industry-standard cryptographic hashing algorithms.

5.2 Administrative Safeguards

• Regular employee training on data privacy and security best practices
• Data access and processing policies for staff who handle personal information
• Vendor due diligence and contractual data protection obligations for third-party processors
• Periodic security assessments and vulnerability testing

5.3 Data Breach Response

In the event of a data breach that affects your personal information, we will notify affected individuals and relevant authorities in accordance with applicable law, including applicable state breach notification statutes. We will provide timely notice and describe the nature of the breach, the type of information affected, and steps you can take to protect yourself.

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 law.

6.1 Rights Available to All Users

• Right to Know / Access: You have the right to request a copy of the personal information we hold about you and to receive information about how it is used and shared.
• Right to Correction: You have the right to request that we correct inaccurate or incomplete personal information about you.
• Right to Deletion: You have the right to request that we delete your personal information, subject to certain exceptions (such as completing a transaction or complying with legal obligations).
• Right to Opt Out of Marketing: You may opt out of receiving marketing communications from us at any time without affecting the legality of service-related communications.

6.2 Additional Rights for California Residents (CCPA/CPRA)

If you are a California resident, you have the following additional rights under the CCPA as amended by the CPRA:

• Right to Know: The right to know what personal information we collect, use, disclose, and sell, including the categories and specific pieces of information.
• Right to Delete: The right to request deletion of personal information we have collected about you, subject to exceptions.
• Right to Correct: The right to request correction of inaccurate personal information.
• Right to Opt Out of Sale/Sharing: The right to opt out of the sale of your personal information or its sharing for cross-context behavioral advertising.
• Right to Limit Use of Sensitive Personal Information: The right to limit the use and disclosure of sensitive personal information to that which is necessary to perform the services you have requested.
• Right to Data Portability: The right to receive your personal information in a portable and readily usable format.
• Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights. We will not deny you services, charge different prices, or provide a different quality of service because you exercised your rights under the CCPA/CPRA.

6.3 How to Exercise Your Rights

To exercise any of your privacy rights, please contact us using one of the following methods:

• Email: [email protected] (subject line: "Privacy Rights Request")
• Website: primohoagiesnew.click

We will acknowledge your request within 10 business days and respond substantively within 45 days of receipt. If we require additional time, we will notify you of the extension and the reason for it. We may need to verify your identity before processing your request to protect against fraudulent submissions.

6.4 Authorized Agents

California residents may designate an authorized agent to submit privacy rights requests on their behalf. The authorized agent must provide written proof of authorization, and we may still require direct verification from the consumer to confirm the request.

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this policy, unless a longer retention period is required or permitted by law. The specific retention periods we apply are as follows:

After the applicable retention period, we will securely delete or anonymize your personal information unless we are legally required to retain it longer.

8. Children's Privacy

Primo Hoagies does not knowingly collect, solicit, or maintain personal information from individuals under the age of 18. By using our website, you represent and warrant that you are at least 18 years of age. If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact us immediately at [email protected].

Upon receipt of a verified parental request, we will delete any personal information collected from a minor as quickly as reasonably practicable. We comply with the Children's Online Privacy Protection Act (COPPA) and do not knowingly engage in any data practices that involve the personal information of children under 13.

If we become aware that we have inadvertently collected personal information from a child under the age of 18, we will take immediate steps to remove such information from our records and cease any further collection from that individual.

9. Cookie Policy and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze site traffic, and support our marketing efforts. This section provides a summary of our cookie practices.

9.1 Types of Cookies We Use

• Strictly Necessary Cookies: These cookies are essential for the website to function properly. They enable core features such as page navigation, secure login, and shopping cart functionality. You cannot opt out of these cookies without significantly impairing the functionality of our website.
• Performance and Analytics Cookies: These cookies collect information about how visitors use our website, such as which pages are most visited and whether users encounter error messages. This data is used in aggregate form to improve website performance.
• Functionality Cookies: These cookies allow our website to remember choices you make (such as your location, language preferences, or saved items) to provide a more personalized experience.
• Marketing and Advertising Cookies: These cookies track your browsing activity across websites to deliver relevant advertising. They may be set by third-party advertising partners with our permission.
• Social Media Cookies: These cookies are set by social media platforms to enable sharing features and to track conversions from social media advertising.

9.2 Managing Your Cookie Preferences

You can control and manage cookies in several ways:

• Using our cookie consent banner when you first visit our website
• Adjusting your browser settings to block or delete cookies (note: this may affect website functionality)
• Using opt-out tools provided by analytics providers (e.g., Google Analytics Opt-out Browser Add-on)
• Opting out of interest-based advertising through the Digital Advertising Alliance (DAA) at optout.aboutads.info

For a more detailed explanation of our cookie practices, including a full list of cookies used and their specific retention periods, please refer to our full Cookie Policy available on our website at primohoagiesnew.click.

10. International Data Transfers

Primo Hoagies is based in the United States, and our primary data processing activities occur within the United States. However, some of our third-party service providers, including cloud hosting, analytics, and email marketing platforms, may process data in other countries.

If your personal information is transferred outside of the United States, we take steps to ensure that adequate protections are in place, including:

• Requiring our service providers to comply with applicable data protection standards
• Implementing contractual safeguards such as data processing agreements
• Verifying that third-party processors in other countries maintain adequate security standards

By using our website and services, you acknowledge that your personal information may be processed in the United States and in other countries where our service providers operate, and you consent to such transfers in accordance with this policy.

11. California-Specific Disclosures

This section provides additional disclosures required under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) for California residents.

11.1 Categories of Personal Information Collected

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

• Identifiers (name, email address, IP address, account ID)
• Commercial information (order history, products purchased, transaction data)
• Internet and electronic network activity information (browsing history, search queries, page interaction data)
• Geolocation data (derived from IP address or provided delivery address)
• Inferences drawn from other personal information to create a profile about preferences and behavior
• Sensitive personal information (payment card information, processed by third-party processors)

11.2 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 for cross-context behavioral advertising. To exercise this right, please contact us at [email protected] with the subject line "Do Not Sell or Share My Personal Information."

11.3 Shine the Light Law

California Civil Code Section 1798.83 (the "Shine the Light" law) permits California residents who are our customers to request certain information about our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the details in Section 14.

12. Third-Party Links and Services

Our website may contain links to third-party websites, including social media platforms, delivery partners, and other external services. This Privacy Policy applies only to our website and services. We are not responsible for the privacy practices of third-party websites or platforms, and we encourage you to review the privacy policies of any third-party sites you visit.

When you interact with social media plugins or links on our site (e.g., a "Follow us on Instagram" button), the third-party social media platform may collect information about your visit and your interaction. Please refer to the privacy policies of those platforms for information about their data practices.

13. 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:

• Post the updated policy on our website with a new "Last Updated" date
• Provide notice via email to registered users (where the changes materially affect their rights)
• Display a prominent notice on our website homepage

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

14. How to File a Complaint

If you believe that we have not handled your personal information in accordance with this policy or applicable law, we encourage you to contact us first so we can attempt to resolve the matter directly. Our contact details are provided below.

If you are not satisfied with our response, you may have the right to file a complaint with relevant regulatory authorities:

• California Residents: You may file a complaint with the California Privacy Protection Agency (CPPA) at cppa.ca.gov or the California Attorney General's Office.
• Federal Complaints: You may file a complaint with the Federal Trade Commission (FTC) at reportfraud.ftc.gov or by calling 1-877-FTC-HELP (1-877-382-4357).
• Other States: Residents of other states may contact their respective state Attorney General's office or consumer protection agency for guidance on filing a complaint related to data privacy.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please do not hesitate to contact us. We have a dedicated team available to assist with all privacy-related inquiries.

When contacting us regarding a privacy rights request, please provide sufficient information to allow us to identify your account or records and verify your identity. We will respond to all verified requests within the timeframes required by applicable law.