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:
- 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.
- We collect information from emails and other contacts sent to us by you, other customers and users of the Sites.
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.
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.
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
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.
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.
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.
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.
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.
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
Links to Other Websites
Your Questions and Concerns
**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. **