Privacy Policy

1What Is Personal Information?

Personal information means information about an identifiable individual, which may include, but is not limited to, your name, home address, email address, telephone number, and payment card information. Personal information does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, or work email address.

Personal information also does not include information that has been anonymized or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other information.

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2How Does Panago Collect Information?

We collect information in a variety of ways, including:

• Directly from you. We shall collect your personal information when you interact with us including:
  • Each time you place an order with Panago (online, through the telephone or in person), we collect the personal information that is required to help process and fulfil your pizza order.
  • When you register for and use your account, including ordering Panago products and services accessible through our website, applications and other platforms (including through AI chatbots or virtual assistants).
  • When you inquire about or apply for a job with Panago or any of our affiliates.
  • When you sign up for marketing programs, promotions, loyalty programs or contests.
  • When you provide feedback or answer our surveys.
  • When you request assistance from us.
  • When you interact with us through our social media platforms, such as when you like an Instagram, Facebook, LinkedIn or TikTok post or when you comment on such social media channels controlled by us, we will receive some information about you to the extent that you have permitted the social network to share information about you with third parties
  • When you otherwise reach out to us (e.g., in-person, on social media, through email or via the phone).
• Information collected automatically.
  • When you use our digital services (website, mobile application or other digital tools like virtual assistants or AI-powered chatbots), we and our service providers may automatically collect certain technical and usage information, such as:
    • Internet Protocol address;
    • Information about the computer, tablet, smartphone or other device you use, including browser type, operating system and device type;
    • Device identifiers and general location inferred from an IP address;
    • Pages viewed, links selected, referring pages, and dates and times of visits;
    • Website and mobile application interactions, session information and performance data; and
    • Cookie identifiers and information collected through similar technologies.
• From third parties.We may receive your personal information from franchisees, affiliates, service providers, marketing partners, and referral sources. For instance, we may receive information about you from our franchisees, so that information you provide to one franchisee may be used by us to provide you services, develop more complete customer profiles for analytics, marketing research, to develop new products, understand our customers, and to communicate with you or provide you advertisements or other personalized content, in accordance with your permissions and applicable laws.We will handle that information in accordance with this privacy policy, applicable law, and any applicable restrictions imposed by the source. Where permitted by law, we may combine this information with the information we collect from you directly.

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3What Type of Information Does Panago Collect?

The categories of personal information we collect include: 

• Contact and identification information: your first and last name, mailing address, email address and telephone number. In some instances, we may collect your gender and date of birth.
• Account and profile information: your login, passwords and other information for authentication and account access, your purchase history, any payment card information associated with your account, and information about your interests, dietary restrictions and allergies, favorites and preferences.
• Order information: information about your current and past orders and food choices and any allergies, and dietary restrictions.
• Payment and transaction information: data necessary to process your payment if you make a purchase. We use a payment processor to collect payment card information including your payment instrument number (such as a credit or debit card number), and the security code associated with your payment instrument. We may also collect information about any coupon, promotion, offer or gift card used and loyalty or reward program details.
• Comments, chat and opinions: When you contact us directly (e.g., by email, phone, mail, in-app messages or by completing an online form or participating in online chat), we may collect your comments and opinions and may also utilize AI technologies to transcribe your comments and opinions. We may also store comments and opinions you express when responding to surveys, entering a contest or sweepstakes, submitting a query, complaint or compliment with our customer service team, or taking part in a promotion or competition.
• Location information: Where a feature requests access to precise device location, we will seek any permission required through the device or browser. Location information may be used to identify nearby stores or provide location-relevant content. You can generally control precise location access through your device or browser settings.
• Loyalty data: including points balance, usage history and other information associated with orders or other Panago services you request, including your interests, favorites and preferences.
• Derived Analytics and Insights: including analytical outputs generated from customer interactions or feedback (such as sentiment analysis or speech analytics) used to assess and improve customer experience.
• Audio and visual interaction information: including recordings and transcripts of customer service calls, audio or video feedback submitted by customers, and associated metadata.
• Applicant information: when you inquire about or apply for a job through our website or social media channels (e.g., LinkedIn), we collect information you submit in association with that inquiry or job opening, including your name, contact information, resume, cover letter, employment and educational history, transcripts, writing samples, and references.

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4How Is This Information Used?

We use your personal information for the following purposes:

We also maintain a recent purchase history of the products and services you buy and from time to time we may analyze this information to better understand your needs and preferences. In addition, we may occasionally call you to ask for your feedback in an effort to ensure you are happy with the products and service you are receiving.

In addition to the above, we also use your personal information:

• to manage and assess our risks and operations;
• for investigations and disciplinary purposes;
• to protect us against error, fraud, theft and damage to our products or services, business operations and property;
• to maintain our business and operations;
• to detect, investigate and prevent fraud, misuse, security incidents and unlawful activity;
• to establish, exercise or defend legal claims and enforce agreements;
• to comply with legal, regulatory, tax, accounting and contractual obligations; and
• for other purposes that we identify at or before the time of collection, or that are otherwise permitted or required by law.

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5Potential Secondary Uses

Subject to applicable law, we may also use some of your personal information for the purpose of commercial prospecting, marketing or promotion of our products and services. Where we intend to use, or allow our franchisees to use, your personal information for the purposes of marketing or promoting our products and services, we will provide the opportunity to opt in or out of the use of your information for these purposes. You may also ask us not to use your personal information in this way at any time.

For instance, we may use your contact information and information about your relationship with us and your purchase history to help us decide which ads or offers to present to you (and when) and to identify other people with similar interests on the websites of companies who help us advertise. For example, we may share masked and hashed contact information with platforms like Meta, Google and LinkedIn to create custom audiences and exclusion lists. We do this to tailor what ads you may see, including ensuring you do not see ads for products or services you have already purchased or opted out of. We won’t do this if you have opted out of receiving marketing from us or have opted out of relationship-based ads with your social media or webmail sites If you would like to opt out of our use of your Personal Information for such marketing purposes, please contact our Privacy Officer using the information outlined below.

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6When We Disclose Your Information

We may disclose your personal information and other information in the manner and for the purposes that are described in the sections below.

• Our franchisees: Many Panago restaurants are independently owned and operated by third-party franchisees, who are wholly separate and independent organizations with their own privacy policies. We will disclose personal information to our franchisees, particularly when we collaborate in providing the services to you, such as, to process your order, provide loyalty program details or facilitate delivery and carry-out services that you may request through our websites, mobile applications or other digital channels. For example, we may need to disclose certain personal information with a franchisee to provide or facilitate your order or to ensure quality assurance for Panago. Please note that our franchisees operate independently and they will have their own privacy policies and data collection, retention policy and use practices that are not governed by this policy. Whether the franchisees independently collect your information or receive it from us as part of our business operations, the franchisees are independent data controllers, and solely responsible for how they use and protect that information. Franchisees are required to process your personal information in compliance with applicable data protection laws.
• Service providers: We may use service providers for website hosting, cloud storage, customer relationship management, marketing automation and audience engagement, payment processors, delivery marketplaces and voice assistant platforms. They may access personal information only as needed to perform authorized services and are expected to protect it appropriately.
• Business transactions: We may disclose personal information in connection with a proposed or completed merger, acquisition, financing, reorganization, sale of assets, insolvency proceeding or other business transactions. We will limit disclosure to what is reasonably necessary and use protections required by law.
• Legal and protective disclosures: We may disclose personal information where reasonably necessary to comply with law or legal process, respond to lawful requests from authorities, investigate fraud or unlawful activity, protect our services, enforce agreements, respond to an emergency or protect the rights, safety or property of Panago or another person.

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7Retention

We retain your personal information in our customer database and we utilize security measures to keep your information safe. Any company that we partner with has an obligation to keep the information completely confidential and will not use or disclose your information for any purpose other than those identified in this policy.

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8De-identified, Aggregate or Anonymized Information

We may also de-identify, aggregate or anonymize information to identify trends, manage our business, develop statistical information, understand how we are performing, or develop relevant products, services or offers. Such information may also be shared with: (a) our affiliates and franchisees to understand and improve Panago’s products, services and offerings, and to develop better websites or applications in the future; and (b) third parties for other analytical purposes. At no time will such information personally identify, or be used to identify, any individual.

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9Website Tracking Tools and Cookies

When you visit our website, Panago may use cookies, pixels, tags, and similar tracking technologies to collect information about how you interact with our website. We use these tools to help operate and improve our website, understand website traffic and customer preferences, measure the effectiveness of our communications, and support analytics and marketing activities. These activities are carried out in accordance with applicable Canadian privacy laws, including requirements for meaningful consent where required. You may manage your cookie preferences through your browser settings, although disabling certain cookies may affect website functionality.

To learn more about cookies and other online tracking tools or to opt out of tailored advertising, please visit Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

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10Google Analytics

Our website uses Google Analytics, a web analytics service of Google LLC (“Google”), or comparable technology. Google Analytics uses “cookies”, which are text files stored on users’ computers, to analyze how they use the website. The information generated by the cookie about use of the websites (including IP address) is sent to a Google server in the U.S. and stored there.  This information is aggregated and logged and used to measure statistical information about usage of the site, including but not limited to the total number of visits, average time spent on the site, and pages viewed, both in real-time, and within a certain historical time frame. We use this aggregated information to measure the use of our site and to improve the content and usage of our site.

Additionally, Google may transfer this information to a third-party when required by law or in the case of a third-party processing information on Google’s behalf. Users can set their internet browser to prohibit the installation of cookies, although some features and functions of the website will then be unusable.

By using our website, users consent to the processing of user data collected by Google in the manner described and for the above-mentioned purpose. The consent for collection and storage of data can be withdrawn at any time in the future by clicking on the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

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11Google Ads

Google uses cookies, web beacons, and unique device identifiers to serve ads based on your past visits to our website. This helps us show you relevant ads on Google Search, YouTube, Gmail, and the Google Display Network. You can opt out of Google Marketing Platform’s use of cookies by visiting the Google Marketing Platform opt-out page or the Network Advertising Initiative opt-out page.

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12Links to Third Party Sites

Our website, mobile applications or other digital platforms may offer links to other sites not operated by Panago. If you visit one of these sites, you should review their privacy and other policies. Panago is not responsible for the policies and practices of others.

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13Cross-Border Transfers

Your personal information may be transferred or processed outside of Canada, including to jurisdictions where our service providers operate, such as the United States. Other jurisdictions may have different data protection rules than Canada. While your personal information is outside of Canada, it is subject to the laws of the country in which it is located. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. If you would like to learn more about how your personal information is transferred across borders or about the service providers we use and how they process your personal information including outside your jurisdiction, please contact our Privacy Officer using the contact details outlined in the “Contact Us” section below.

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14Opting Out of Communications

If you no longer want to receive marketing-related emails, phone calls or SMS messages from us, you may opt out of receiving emails by clicking the “unsubscribe” link at the bottom of any email you receive from us, replying STOP to any SMS message you may receive from us or ask our telemarketer to remove your phone number from our telemarketing lists. You may also opt out by contacting us directly using the contact information in the “Contact Us” section below.

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15Consent

We only collect information by lawful means. When we do so, we will collect, use or share your personal information with your consent for the purposes identified or as otherwise permitted or required by law. In compliance with our privacy obligations, we may obtain your permission based on implied consent (including through this privacy policy) or through other means (such as express consent). However, in some situations, the law allows us to collect, use or disclose personal information without your consent.

You can withdraw your consent from the collection, use or disclosure of your information at any time. However, in some cases withdrawing consent will mean that we can no longer provide you with certain services or perform certain tasks where the information is required to do so.

You may withdraw your consent to the collection, use or disclosure of your or your child’s personal information at any time by contacting the Privacy Officer (see ‘Contact Us’ section below) and, subject to any legal constraints, we will comply with your request. However, in some circumstances, if you withdraw your consent, we may no longer be able to allow you to participate in events or continue to receive our services.

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16Minors

Panago’s website, mobile application or other digital channels are for use by adult persons who are the age of majority in the province or territory of their residence or otherwise have legal capacity to enter into a binding agreement. They are intended for a general audience and are not directed primarily at minors. We do not knowingly collect personal information from minors who cannot legally provide valid consent without the involvement of a parent or guardian, except where permitted by law. If you believe a child has provided personal information without appropriate consent, please contact us immediately using the ‘Contact Us’ section below, and we will delete their personal information.

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17Accuracy

We take reasonable steps to ensure that personal information under our control is accurate, complete and up to date as necessary for the purposes for which it is used. You are responsible for providing accurate information and notifying us when it changes.

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18Accessing or Correcting Your Information

You can ask to access or correct the personal information that we have about you. If you want to review, verify, or correct your personal information, please contact our Privacy Officer (see ‘Contact Us’ below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by emailing it to you). If you require assistance in preparing your request, please contact our Privacy Officer.

If you believe that personal information we hold about you is incorrect, incomplete, or inaccurate, then you may request us to amend it. We will consider whether the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it, together with your requested amendment. If we correct your personal information, we will, so far as is reasonably practicable, inform every other person to whom we have disclosed that information of the correction.

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.

Your right to access the personal information that we hold about you is not absolute. There are situations where applicable law allows or requires us to refuse to provide some or all of the personal information that we hold about you. For example, in some cases the information you request access to may contain details about other individuals, or there may be legal, security, or commercial proprietary reasons why information is withheld. In addition, your personal information may have been destroyed, erased, or made anonymous in accordance with our record retention practices. In the event that we cannot grant your data subject request, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

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19Security Safeguards

We use physical, organizational and technological safeguards appropriate to the sensitivity, amount, format and storage of personal information. Depending on the context, these may include access controls and role-based permissions, authentication requirements, encryption in transit and, where appropriate, at rest, physical security at our premises, privacy training and confidentiality obligations for our staff, due diligence and contractual requirements for our service providers, system monitoring and logging, vulnerability management, incident-response procedures and secure destruction practices.

Payment information. Card payments are processed by third-party payment processors that maintain PCI DSS compliance. We do not store full payment card numbers or card security codes on our systems. Where you choose to save a payment method to your account, it is stored in tokenized form by our payment processor.

Your role. If you create an account, you are responsible for keeping your login credentials confidential and for activity under your account. Please use a unique password, do not share it, and contact us promptly if you believe your account has been accessed without authorization. Please avoid sending sensitive personal information to us by unencrypted email or a social media message.

Security incidents. We maintain procedures to identify, investigate and respond to security incidents. Where a breach of security safeguards involving your personal information creates a real risk of significant harm to you, we will notify you and the applicable privacy regulator as required by law, and we will maintain records of breaches as required.

No method of transmission or storage is completely secure. While we take reasonable steps to protect personal information, we cannot guarantee absolute security.

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20Contact Us

If you have any questions or concerns about our Privacy Policy or if you wish to access your data subject rights, please contact our Privacy Officer in one of the following ways:

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21Updates

This Privacy Policy is subject to change, so we suggest that you return to the website on a periodic basis and carefully read the information provided. Your continued use of the Panago websites, mobile application, other digital channels or services signifies your agreement to our collection, use, retention and disclosure of your personal information as described in this privacy policy.

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