Privacy Policy

Effective Date: July 18, 2026  |  Last Updated: July 18, 2026

1. Introduction and Who We Are

Welcome to the Privacy Policy of Primo Hoagies Cafe ("we," "us," "our," or "the Company"). We operate the website located at primohoagiescafe.click and provide food-related services to our valued customers across the United States.

We are deeply committed to protecting your privacy and handling your personal information with the highest degree of care, transparency, and respect. This Privacy Policy has been drafted in compliance 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) governing unfair or deceptive practices
• The Children's Online Privacy Protection Act (COPPA)
• The CAN-SPAM Act governing commercial email communications
• Any other applicable federal and state privacy regulations

By accessing or using our website and services, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. If you do not agree with these terms, please discontinue use of our website immediately.

1.1 Contact Information

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

2. Information We Collect

We collect several categories of information depending on how you interact with our website and services. The types of information we collect include personal information you provide voluntarily, information collected automatically through your use of our website, and information obtained from third-party sources.

2.1 Personal Information You Provide to Us

When you interact with our website or services — such as placing an online food order, signing up for our newsletter, making a reservation, submitting a contact form, or participating in a promotional offer — you may voluntarily provide us with personal information, including:

• Identity Information: Your full name, username, or similar identifier
• Contact Information: Email address, telephone number, billing address, delivery address, and postal code
• Payment Information: Credit or debit card details, billing information, and transaction records (note: full payment card data is processed by secure third-party payment processors and is not stored on our servers)
• Order Information: Details about food items ordered, dietary preferences, special instructions, and order history
• Account Information: Username, password, profile preferences, and loyalty program details
• Communications Data: Messages, feedback, complaints, or inquiries you send to us via email, contact forms, or other channels
• Marketing Preferences: Your preferences regarding receiving marketing communications from us

2.2 Information Collected Automatically

When you visit our website, we automatically collect certain technical and usage information through cookies, web beacons, pixels, log files, and similar tracking technologies. This information includes:

• Device Information: Device type, operating system, browser type and version, screen resolution, and device identifiers
• Log Data: Your IP address, browser type, pages visited, time and date of visit, time spent on pages, and referring website URLs
• Usage Data: Clickstream data, navigation patterns, links clicked, search terms used on our site, and features accessed
• Location Data: General geographic location derived from your IP address (city, state, country level) and, with your explicit consent, more precise location data from your mobile device
• Cookie and Tracking Data: Information stored in cookies and similar tracking technologies (see Section 7 for full details on our cookie practices)

2.3 Information from Third-Party Sources

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

• Food delivery platforms and third-party ordering systems that process orders on our behalf
• Social media platforms if you interact with our social media profiles or use social login features
• Analytics providers that help us understand how users interact with our website
• Advertising partners and marketing networks
• Review platforms where customers leave feedback about our food and services

3. How We Use Your Information

We use the information we collect for a variety of legitimate business purposes. We will only use your personal information for the purposes described below, or in ways that are compatible with these purposes.

3.1 Service Provision and Order Fulfillment

• Processing and fulfilling your food orders, including delivery or pickup arrangements
• Managing your account and providing customer support
• Sending order confirmations, receipts, and delivery status updates
• Processing payments and preventing fraudulent transactions
• Managing reservations and catering requests
• Responding to your inquiries, complaints, and feedback

3.2 Business Operations and Service Improvement

• Analyzing usage patterns and customer behavior to improve our website functionality and food offerings
• Conducting internal research and development to enhance our products and services
• Monitoring and analyzing trends in food preferences and order patterns
• Troubleshooting technical issues and ensuring the security of our platform
• Training our staff and improving the quality of our customer service

3.3 Marketing and Communications

• Sending you promotional offers, discounts, seasonal specials, and new menu item announcements (with your consent where required)
• Delivering personalized marketing content based on your order history and preferences
• Administering loyalty programs, contests, sweepstakes, and promotional events
• Sending newsletters and updates about our food offerings and company news
• Displaying targeted advertisements on our website and third-party platforms

3.4 Legal and Compliance Purposes

• Complying with applicable laws, regulations, and legal obligations
• Responding to lawful requests from government authorities and law enforcement agencies
• Enforcing our Terms of Service and other agreements
• Protecting the rights, property, and safety of Primo Hoagies Cafe, our customers, and the public
• Resolving disputes and handling legal claims

4. Legal Basis for Processing Your Information

As a United States-based business, we process your personal information based on the following lawful grounds:

• Contractual Necessity: Processing is necessary to fulfill our contractual obligations to you, such as processing and delivering your food orders
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as improving our services, preventing fraud, and marketing our food offerings, where these interests are not overridden by your privacy rights
• Legal Obligation: Processing is required to comply with applicable federal and state laws
• Consent: Where required by law, we will obtain your explicit consent before processing your personal information for specific purposes, such as targeted advertising or sensitive data collection

5. Sharing Your Information with Third Parties

We respect your privacy and do not sell your personal information to third parties for monetary compensation. However, we may share your information with trusted third parties in the following circumstances:

5.1 Service Providers and Business Partners

We work with carefully selected third-party service providers who assist us in operating our business and providing our services. These service providers may have access to your personal information only to the extent necessary to perform their specific functions and are contractually obligated to maintain the confidentiality and security of your data. Our service providers include:

• Payment Processors: Companies that securely process credit card transactions and online payments
• Food Delivery Partners: Third-party delivery services that facilitate the delivery of your food orders
• Cloud Hosting Providers: Companies that host our website and store data on secure servers
• Analytics Providers: Services such as Google Analytics that help us understand website traffic and user behavior
• Email Marketing Platforms: Services that help us send marketing communications and newsletters
• Customer Support Tools: Software platforms that help us manage customer inquiries and support tickets
• Advertising Networks: Partners that help us display relevant advertisements to potential customers

5.2 Legal Requirements and Law Enforcement

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

• Comply with a legal obligation, court order, subpoena, or other governmental request
• Cooperate with law enforcement investigations or regulatory inquiries
• Protect and defend our legal rights and property
• Prevent or investigate potential wrongdoing in connection with our services
• Protect the personal safety of our customers, employees, or the public

5.3 Business Transfers

In the event that Primo Hoagies Cafe undergoes a merger, acquisition, restructuring, or sale of all or a portion of its assets, your personal information may be transferred to the acquiring entity 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 different privacy policy.

5.4 California Privacy Rights — CCPA/CPRA Notice

6. Data Security Measures

The security of your personal information is of paramount importance to us. We implement a comprehensive set of technical, administrative, and physical security measures designed to protect your information from unauthorized access, disclosure, alteration, loss, or destruction.

6.1 Technical Security Measures

• Encryption: We use industry-standard SSL/TLS encryption to protect data transmitted between your browser and our servers
• Secure Payment Processing: All payment transactions are processed through PCI DSS-compliant payment processors
• Access Controls: We implement role-based access controls to ensure that only authorized personnel can access personal data
• Firewalls and Intrusion Detection: We deploy firewalls, intrusion detection systems, and other network security tools to protect our infrastructure
• Regular Security Audits: We conduct periodic security assessments and vulnerability scans of our systems
• Data Minimization: We collect only the minimum amount of personal information necessary for the stated purposes

6.2 Administrative and Organizational Measures

• Employee training on data protection and privacy best practices
• Strict confidentiality agreements with all staff and contractors who handle personal data
• Data breach response procedures to minimize the impact of any potential security incident
• Vendor security assessments before engaging third-party service providers

7. Cookie Policy and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze website traffic, and deliver personalized content and advertising. This section provides a brief overview of our cookie practices.

7.1 Types of Cookies We Use

7.2 Managing Your Cookie Preferences

You have the right to accept or decline non-essential cookies. You can manage your cookie preferences through your browser settings or through our cookie consent tool on our website. Please note that disabling certain cookies may affect the functionality of our website and your ability to place orders online.

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

8. Your Privacy Rights

Depending on your location and applicable law, you may have certain rights with respect to your personal information. We are committed to honoring these rights and will respond to all legitimate requests in a timely manner.

8.1 Rights Available to All Users

• Right to Access: You have the right to request a copy of the personal information we hold about you
• Right to Correction: You have the right to request that we correct any inaccurate or incomplete personal information we hold about you
• Right to Deletion: You have the right to request that we delete your personal information, subject to certain legal exceptions
• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format
• 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

8.2 Additional Rights for California Residents (CCPA/CPRA)

If you are a resident of California, you have the following additional rights under the CCPA/CPRA:

• Right to Know: The right to know what categories and specific pieces of personal information we have collected about you in the past 12 months
• Right to Know About Disclosures: The right to know the categories of personal information we have disclosed for business purposes
• Right to Opt Out of Sale/Sharing: The right to opt out of the sale or sharing of your personal information with third parties
• Right to Limit Use of Sensitive Personal Information: The right to limit our use of sensitive personal information to purposes necessary to provide our services
• Right to Correct: The right to request correction of inaccurate personal information
• Authorized Agent: You may designate an authorized agent to submit requests on your behalf

8.3 How to Exercise Your Rights

To exercise any of your privacy rights, please submit a verifiable request to us using the following methods:

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

We will acknowledge your request within 10 business days and respond to your request within 45 calendar days. If we require additional time to respond, we will notify you and may extend this period by an additional 45 days where reasonably necessary.

To protect your privacy and security, we will verify your identity before processing your request. Verification may require you to provide proof of identity, such as your name, email address, and order history.

9. Data Retention Periods

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 the retention period expires, we will securely delete or anonymize your personal information so that it can no longer be associated with you. In some cases, we may retain anonymized, aggregated data indefinitely for statistical and research purposes.

10. Children's Privacy

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

We do not knowingly target or direct our services, marketing communications, or website content to minors. If you are under the age of 18, please do not use our website or provide any personal information to us without the supervision and consent of a parent or legal guardian.

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

11. International Data Transfers

Primo Hoagies Cafe is based in the United States and primarily operates within the United States. If you are accessing our website from outside the United States, please be aware that your personal information may be transferred to, stored, and processed in the United States, where privacy laws may differ from those in your home country.

When we transfer personal information internationally, we take appropriate safeguards to ensure that your information receives adequate protection, including:

• Using service providers that maintain adequate security standards and contractual protections
• Implementing data transfer agreements with appropriate contractual clauses
• Ensuring that any international transfers comply with applicable United States and international data protection laws

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 and its processing in accordance with this Privacy Policy.

12. Third-Party Links and External Websites

Our website may contain links to third-party websites, social media platforms, food delivery platforms, or other external services. These links are provided for your convenience and informational purposes only. Please be aware that:

• We have no control over the content, privacy practices, or security measures of third-party websites
• This Privacy Policy does not apply to any third-party websites or services
• We are not responsible for the privacy practices of any third-party website
• We encourage you to review the privacy policies of any third-party websites you visit

Third-party services commonly linked from our website include food delivery platforms, social media networks, and review sites. Each of these services has its own privacy policy governing how it collects and uses your personal information.

13. Changes to This Privacy Policy

We reserve the right to update or modify 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 Privacy Policy, we will:

• Update the "Last Updated" date at the top of this page
• Post a prominent notice on our website informing you of the changes
• Send an email notification to registered users where the changes are significant

Your continued use of our website and services after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

If you disagree with any changes to this Privacy Policy, you should discontinue use of our website and contact us to request deletion of your personal information.

14. How to File a Complaint with a Data Protection Authority

If you believe that your privacy rights have been violated and you are not satisfied with our response to your concerns, you have the right to file a complaint with the relevant regulatory authority.

14.1 Federal Trade Commission (FTC)

For complaints related to unfair or deceptive trade practices, including privacy violations, you may contact the Federal Trade Commission:

• Website: www.ftc.gov
• Online Complaint Portal: reportfraud.ftc.gov
• Phone: 1-877-382-4357
• Address: Federal Trade Commission, 600 Pennsylvania Avenue NW, Washington, DC 20580

14.2 California Residents — California Privacy Protection Agency (CPPA)

California residents may file complaints with the California Privacy Protection Agency:

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

14.3 State Attorney General Offices

Depending on your state of residence, you may also file a complaint with your state's Attorney General office, many of which have consumer protection divisions that handle privacy-related complaints.

15. Contact Us About Privacy

We value your privacy and are committed to resolving any concerns you may have about how we handle your personal information. If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please do not hesitate to contact us:

We are dedicated to addressing your privacy concerns promptly and effectively. Our privacy team will respond to all inquiries within 10 business days. For complex requests, we may require additional time, but we will keep you informed of our progress throughout the process.