Firehouse Restaurant Group Privacy Policy

This Privacy Policy was last updated and is effective as of January 22, 2020.

We are Firehouse Subs of Canada, ULC and Firehouse Restaurant Group, Inc. (“Firehouse”).  Your privacy is important to us, which is why we have developed this Privacy Policy to explain our practices regarding the collection, use and disclosure of the personal information we obtain from users of the websites (including, www.firehousesubs.ca), webpages and mobile applications that we own or control (each a “Site” and collectively, the “Sites”.

WHEN YOU ACCESS THE SITES, YOU AGREE TO THIS PRIVACY POLICY AND CONSENT TO BE BOUND BY ITS TERMS. YOU CAN WITHDRAW YOUR CONSENT AT ANY TIME BY CONTACTING OUR PRIVACY OFFICE, AS DESCRIBED BELOW. IF YOU CHOOSE TO WITHDRAW YOUR CONSENT, WE MAY NOT BE ABLE TO PROVIDE YOU WITH THE SERVICES OR COMMUNICATIONS THAT ARE AVAILABLE FROM US. IN ADDITION, IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES WE MAY SUBSEQUENTLY MAKE, YOU SHOULD STOP ACCESSING THE SITES.

Firehouse is subject to the Personal Information Protection and Electronic Documents Act and applicable Canadian provincial privacy legislation. Privacy laws vary by jurisdiction. You acknowledge and agree that access to the Sites and the services that are available through the Sites are provided via the Internet and that your information, including personal information, may be transferred across national borders and stored or processed in accordance with the terms and conditions of this Privacy Policy.

Collecting Information

In general, we avoid collecting any personal information from a user of our Sites unless that user provides such information directly or such information is provided to us by someone else with the user’s consent. For example, you might be asked to voluntarily give your name, postal address, email address, or phone number to us when you place orders or purchase products through our Sites, provide feedback on our products, or fill out a franchise questionnaire. We may also collect and store statistics and other information about the online activities of our visitors on an aggregate basis.

How We Collect Information About You

We collect personal information from you on and through the Sites in three ways:

  1. We collect personal information that our customers or visitors to the Sites supply to us, including when you place an order with us, sign up for our newsletter, participate in a Promotion (as defined below) or submit an application or other information relating to becoming a franchisee.
  2. We collect information from emails and other contacts sent to us by you, other customers and users of the Sites.
  3. We collect information electronically on all customers and other users of the Sites through the use of cookies, as described in more detail below.

Types of Personal Information We May Collect on the Sites

1. Information Relating to Purchases:

Every time you use a Site to place an order or purchase goods or services, we may collect information about the restaurants you select and the details of the orders you place

To obtain services from the Sites, such as placing an order online or signing up for our newsletter, you may be required to provide us with your full legal name, email address, address (including city, province and postal code) and telephone number.  We may ask you to provide your date of birth and age in order to send you information about special birthday Promotions from time to time.  We do not collect your credit card information; if placing an order on one of our Sites, your credit card information will be collected directly by our payment gateway and payment processor, subject to their privacy policies.

To obtain certain services from the Sites such as placing orders with us, you may be required to choose a username and /or password and provide those to us.

For some of our Sites and services, you may be asked to submit personal information about other people. For example, if you place an order through a Site or otherwise make a purchase, you may want the order or item purchased to be sent directly to another person and you may be required to submit the recipient’s name, mailing address, email address and/or telephone number.  It is also possible that someone may provide us with your personal information in order for us to fulfil and/or deliver an order to you on their behalf. By providing us with the personal information of another person, you acknowledge, confirm and agree that you have received permission from such person to provide us with their personal information for our use and disclosure in accordance with the terms and conditions of this Privacy Policy.

2. Information Relating to Promotions:

We or our third-party merchants, vendors, service providers and contractors (each a “Third Party Promoter”) may offer users of the Sites special offers, contests or other promotions (each a “Promotion”). We will collect your express consent prior to sending you any commercial electronic messages, including in relation to Promotions, unless an exception to obtaining your opt-in consent applies under Canada’s Anti-Spam Legislation. You will have the opportunity to opt-out of receiving commercial electronic messages at any time. For clarity, by using and accessing our Sites you agree to receive transactional communications about your orders, account and other activities on the Sites.  

You are under no obligation to respond to or to participate in any Promotion but, if you do, you may be required to provide us or our Third Party Promoter with additional personal information (such as your date of birth and whether you or anyone in your household is employed by the Third Party-Promoter) to verify your eligibility for participation in the Promotion. For a given Promotion, the information you provide may be governed by the Third-Party Promoter’s privacy policy rather than our Privacy Policy, so we recommend that you read any official rules or guidelines for each Promotion carefully. 

3. Personal Information We Collect Indirectly

As a general rule, we collect personal information directly from you. In most other circumstances where the personal information that we collect about you is held by a third-party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions). From time to time, we may utilize the services of third-parties and may also receive personal information collected by third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us. For example, we may receive personal information from our Third-Party Promoters in connection with the services that they provide to us.

All of the information we collect about you may be combined with the information that we receive from other sources, which helps us tailor our communications to you and maximize your customer experience with us and on the Sites.

The Reasons We Collect Personal Information

We only collect the necessary personal information to provide with the products and services available through our Sites and which enables use to manage, maintain and develop our operations. For example, we collect personal information to:

  • establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products or services that have been requested;
  • enable you to register, access and maintain an account with us;
  • allow you to participate in, subscribe to or otherwise receive products or services from us;
  • be able to review the products and services that we provide to you so that we may: (i) understand your requirements for our products and services; and (ii) work to improve our products and services;
  • be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);
  • be able to process orders for your purchase of products or services through the Sites;
  • understand your preferences and tailor offers, products and services to you based on these preferences;
  • to send information to you about promotions, products or services of ours or our marketing partners that we believe may be of interest to you;
  • evaluate your suitability as a potential franchisee, where you have applied to or franchise program;
  • protect us against error, fraud, theft and damage to our goods and property;
  • conduct analysis and evaluations to understand usage and trends in order to improve the Sites, our products, services and marketing communications;
  • enable us to comply with applicable laws or regulatory processes; and
  • any other reasonable purpose to which you consent.

By consenting to our collection of your personal information through your access and/or use of the Sites you allow us to fulfill the purposes for which we collect your personal information. When we collect your information for research and development purposes, we ensure that any information used for our analysis and reports will be de-identified and aggregated in a manner that will not identify you. We may share aggregated de-identified information for general business analysis. For example, we may disclose the number of visitors to the Sites with third parties.

We will collect your express consent to our contacting you with any commercial electronic messages. You will have the opportunity to opt-out of receiving such electronic messages at any time.

Sharing and Disclosure of Information

We may disclose your personal information collected through your use of the Sites to: (a) our affiliates, franchisees and our respective employees, contractors, consultants, service providers (such as our email service provider) and other parties who require such information to assist us with managing our relationship with you; (b) third-parties to provide you with information or materials you specifically request, including Third Party Promoters in connection with a Promotion; and (c) as otherwise specifically permitted in this Privacy Policy. 

In addition, when an order is placed through the Site for pick-up at a FIREHOUSE SUBS® Restaurant, some of your personal information (such as a first or last name along with a truncated phone number and/or order number) may be displayed on an order slip or receipt to help identify the order for pickup and this slip or receipt may be attached or otherwise associated with the order in an area in a restaurant that is accessible to other restaurant patrons. 

Personal information may also be disclosed or transferred to another party during the course of, or upon the completion of, a change of ownership of, or grant of security interest in, all or a part of Firehouse or its affiliates through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

We may also use and disclose your personal information collected through your use of the Sites to unrelated third parties:

  • to conform to legal requirements or to respond to a subpoena, search warrant or other legal process received by us;
  • to enforce our Terms and Conditions or to protect our rights;
  • to protect the safety of others, including other users of the Sites; or
  • for any additional purposes for which we have obtained your consent to disclose your personal information. 

Since we may share your personal information with third parties, as described in this Privacy Policy, your personal information may be collected, used, processed, stored or disclosed outside of your jurisdiction of residence, including in Canada and the United States. As such, your personal information may potentially be accessible to law enforcement and national security authorities of another jurisdiction where local laws provide for a different level of protection for personal information. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security agencies in those other countries may be entitled to access your personal information.

If you would like further information about our policies and practices regarding the third parties (including our service providers) with whom we disclose your personal information and how these third parties collect, use, disclose and store personal information, please contact our Privacy Office using the contact details below. By providing your personal information to us, you consent to our disclosure of this information to our service providers (and other third parties) as described in this Privacy Policy, including those that may be located outside of your jurisdiction of residence.

We also reserve the right to change the manner of our use and disclosure in accordance with the “Changes in Our Privacy Policy” section below.  

Your Consent is Important to Us

It is important to us that we collect, use or disclose your personal information only when we have your consent to do so. Your consent may be implied, deemed (using an opt-out mechanism) or express. We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavour to advise you of that purpose before such use or disclosure.

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Office using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Office. If you withdraw or vary your consent, we may not be able to provide you with the communications and/or services you request through our Sites. For example, if you would like to receive our communications, but are not willing to provide your email address, we will not be able to fulfil your request.

Unless you advise us otherwise, through the access and use of our Sites, services and communications, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

Protection of Your Personal Information

We will endeavour to maintain commercially reasonable physical, technical and procedural safeguards that are appropriate based on the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction.

The security of your personal information is important to us. Please advise our Privacy Office immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

Access to Your Personal Information

You can ask to access the personal information that we have received from or possess about you. If you want to review, verify, delete or correct your personal information, please contact our Privacy Office.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. If you require assistance in preparing your request, please contact our Privacy Office.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.

Retention of Personal Information

We don’t keep your personal information forever. We keep your personal information as long as is reasonably necessary for us to complete our dealings with you, or as may be required or permitted by law, whichever is longer.

Children’s Privacy and Age Limitations for the Sites

The Sites are intended for use by persons aged 16 or older, and by your use of this Website you affirm that you are at least 16 years of age.  We do not knowingly collect personally identifiable information from children under the age of 16. If we discover or are made aware that we have received personally identifiable information from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 16, we will delete such information from our systems.  If you are a parent or guardian of a child under the age of 16 and believe he or she has disclosed personally identifiable information to us, please contact us as provided below.  In any such event, a parent or guardian of a child under the age of 16 may review and request deletion of such child's personally identifiable information as well as prohibit the use thereof. 

Use of Cookies

As with many websites and applications, the Site uses “cookies” – small strings of data placed on users' personal computer hard drives during the exchange of data that happens when your browser points to one of our websites. Among other things:

  • Cookies enable a site or application to identify a user's browser as a previous visitor by means of a unique string of numbers assigned on a previous visit;
  • Cookies assist us in collecting information on the pages of our Sites that you access or visit, and in recording any preferences you indicate for use on our Sites;
  • If you are browsing one of our Sites, a cookie identifies your browser and Site user ID and internet protocol number of your computer or other access device (but not your personal identity); and
  • If you place orders with us or use our loyalty program, we use cookies to assist in storing your preferences and recording other session information (a "session" is a single visit by you to one of our Sites).

By visiting our Sites you acknowledge, understand and agree that you are giving us your consent to track your activities through the use of cookies and other tracking technologies provided by our third-party service providers.

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Office. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples; therefore, where the word "including" is used, it shall mean "including without limitation".

This Privacy Policy does not create or confer upon any individual any rights, or impose upon the Firehouse Parties any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada's federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada's federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

Links to Other Websites

The Sites may contain links to other websites, applications and online services that are not maintained by us but rather by third parties that may not follow the same privacy policies as applicable to the Sites. These links are provided for your convenience only and you assume all risk for clicking these links to other websites, applications and online services. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites.  These other websites, applications and online services may use cookies, collect data and use the data in ways that are different from the way in which we use the information collected through the Sites. When linking to another website, application or online service, you should read the applicable privacy policy. Our Privacy Policy only governs information collected on or through our Sites.

Changes in Our Privacy Policy

We reserve the right to modify this Privacy Policy at any time, and any modifications made will be effective immediately upon posting, so you should check this page for any changes.  We will post at the top of this Privacy Policy the date that modifications were last made, which should alert you to any changes since your last visit to the Sites.  Your continued use of the Sites after an update or an amendment to this Privacy Policy means that you consent to the collection, use and disclosure of your personal information as described in the revised Privacy Policy. 

Your Questions and Concerns

If you have questions or concerns regarding this Privacy Policy or our privacy practices, please contact our Privacy Office by sending us an email (writing “Privacy Policy” in the subject line) at privacy@firehousesubs.com; write to us at 12735 Gran Bay Parkway, Suite 150, Jacksonville, Florida, 32258; or call us at (904) 886-8300. We will use reasonable efforts to promptly look investigate any concern.

**If you choose to communicate with us via email, please be aware that email is not a 100% secure medium for sending any personal or confidential information to us. **