Privacy Policy

This Privacy Policy describes how Zupas ("we," "us," or "our"), operating through the website new-zupas.click (the "Website"), collects, uses, discloses, and protects your personal information when you visit our Website, place orders, use our services, or otherwise interact with us. We are committed to safeguarding your privacy and handling your personal data in a transparent, lawful, and responsible manner in accordance with applicable United States federal and state privacy laws, including the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and the Federal Trade Commission (FTC) Act.

Please read this Privacy Policy carefully. By accessing or using our Website and services, you acknowledge that you have read, understood, and agree to the practices described herein. If you do not agree with this Privacy Policy, please discontinue use of our Website and services immediately.

1. Who We Are

Zupas is a food service business operating in the United States. We provide customers with access to fresh, high-quality food offerings through our online platform at new-zupas.click. For all privacy-related matters, you may contact us using the information provided in the Contact Us section at the bottom of this policy.

2. Information We Collect

We collect various categories of personal information when you interact with our Website or services. The types of information we collect are described below.

2.1 Personal Identification Information

When you register an account, place a food order, sign up for our newsletter, participate in promotions, or contact us, we may collect:

• Full name
• Email address
• Phone number
• Billing and delivery address
• Date of birth (where required for age verification)
• Username and password (for registered accounts)
• Payment card information (processed securely through third-party payment processors; we do not store full card details)
• Dietary preferences and food allergy information (if voluntarily provided)
• Any other information you choose to provide when completing forms or communicating with us

2.2 Order and Transaction Information

When you place a food order through our Website, we collect information related to that transaction, including:

• Items ordered and order history
• Order date, time, and frequency
• Delivery or pickup location details
• Special instructions or requests submitted with orders
• Payment method type (e.g., credit card, debit card)
• Transaction amounts and receipts

2.3 Usage Data and Website Interaction Information

As you navigate our Website, we automatically collect certain technical and behavioral information, including:

• IP address
• Browser type and version
• Operating system
• Pages visited and time spent on each page
• Clickstream data (links clicked, menus explored)
• Referring website or search engine
• Date and time of Website visits
• Search queries made within our Website
• Error logs and crash reports

2.4 Device Information

We may collect information about the devices you use to access our Website, including:

• Device type (desktop, laptop, tablet, smartphone)
• Device identifiers (such as mobile advertising ID or similar unique identifiers)
• Screen resolution and display settings
• Network connection type
• Geographic location data (approximate, based on IP address or GPS if you grant permission)

2.5 Cookie and Tracking Technology Data

We use cookies, web beacons, pixel tags, and similar tracking technologies to collect data about your browsing behavior on our Website. Please refer to Section 9 (Cookie Usage) for detailed information about the types of cookies we use and how to manage your preferences.

2.6 Communications Data

If you contact us via email, phone, our Website contact form, or through social media, we may retain records of those communications, including:

• The content of your messages and inquiries
• Your contact details as provided in the communication
• Our responses to you
• Date and time of communications

2.7 Information From Third Parties

We may receive information about you from third-party sources, including:

• Social media platforms (if you connect your account or share our content)
• Analytics providers and advertising partners
• Payment processors and fraud prevention services
• Publicly available sources

3. How We Use Your Information

We use the personal information we collect for the following purposes:

3.1 Providing and Managing Our Services

• Processing and fulfilling your food orders, including delivery or pickup coordination
• Creating and managing your account on our Website
• Processing payments and sending order confirmations and receipts
• Responding to your inquiries, complaints, and customer service requests
• Sending operational communications such as order updates, delivery notifications, and changes to our services
• Verifying your identity and preventing fraudulent transactions
• Saving your order preferences and dietary information to improve your experience

3.2 Analytics and Website Improvement

• Analyzing how users interact with our Website to understand preferences and improve user experience
• Monitoring Website performance and identifying technical issues
• Conducting internal research and development to enhance our food offerings and digital services
• Generating aggregated, anonymized statistical reports about Website usage

3.3 Marketing and Promotional Communications

• Sending you promotional emails, newsletters, special offers, and information about new menu items (with your consent where required by applicable law)
• Personalizing advertisements and marketing content based on your preferences and order history
• Conducting surveys, contests, and promotional campaigns
• Retargeting you with relevant advertisements on third-party platforms based on your Website activity

3.4 Legal Compliance and Safety

• Complying with applicable federal and state laws, regulations, and legal obligations
• Responding to lawful requests from government authorities, law enforcement, and courts
• Enforcing our Terms of Service and other legal agreements
• Protecting the rights, property, and safety of Zupas, our customers, and the public
• Detecting, investigating, and preventing fraud, security breaches, and other harmful activities

3.5 Business Operations

• Facilitating corporate transactions such as mergers, acquisitions, or asset sales
• Maintaining business records for accounting and auditing purposes
• Training staff and improving internal processes

4. Sharing Your Information With Third Parties

We do not sell your personal information to third parties for their own commercial use. However, we may share your information with the following categories of third parties in the circumstances described below.

4.1 Service Providers and Business Partners

We engage trusted third-party service providers who perform services on our behalf and require access to your information to do so, including:

• Payment Processors: To securely process credit card and other payment transactions
• Delivery Partners: To facilitate food delivery to your specified address
• Cloud Hosting and IT Providers: To host our Website, databases, and IT infrastructure
• Email Marketing Platforms: To manage and send promotional and transactional emails
• Analytics Providers: Such as Google Analytics, to help us understand Website usage patterns
• Customer Support Tools: To manage and respond to customer inquiries
• Fraud Prevention Services: To detect and prevent fraudulent activity

All service providers are contractually obligated to use your data only for the purposes we specify and to maintain appropriate security measures. They are not permitted to use your data for their own independent purposes.

4.2 Legal Requirements and Law Enforcement

We may disclose your personal information if required to do so by law or if we believe in good faith that such disclosure is necessary to:

• Comply with a legal obligation, subpoena, court order, or governmental request
• Enforce our Terms of Service or other agreements
• Protect and defend our rights or property
• Prevent or investigate possible wrongdoing in connection with our services
• Protect the personal safety of users of our services or the public
• Protect against legal liability

4.3 Business Transfers

In the event that Zupas undergoes a merger, acquisition, reorganization, bankruptcy, or sale of all or substantially all of its assets, your personal information may be transferred to the acquiring entity as part of that transaction. We will notify you via email and/or a prominent notice on our Website of any such change in ownership, and we will inform you of your choices regarding your personal information.

4.4 With Your Consent

We may share your personal information with other third parties when we have your explicit consent to do so. You will be notified at the time of data collection when we intend to share your data in ways not described in this Privacy Policy.

4.5 Aggregated and Anonymized Data

We may share aggregated, de-identified, or anonymized information that cannot reasonably be used to identify you with third parties for research, marketing, analytics, and other business purposes without restriction.

5. Data Security

We take the security of your personal information seriously and implement a variety of technical, administrative, and physical security measures to protect your data from unauthorized access, disclosure, alteration, and destruction.

5.1 Security Measures We Employ

• Encryption: We use Secure Socket Layer (SSL) / Transport Layer Security (TLS) encryption to protect data transmitted between your browser and our Website.
• Access Controls: Access to personal information is restricted to authorized personnel who need the data to perform their job functions. All employees are subject to confidentiality obligations.
• Payment Security: Payment card data is processed through PCI DSS-compliant third-party payment processors. We do not store your full payment card numbers on our servers.
• Firewalls and Intrusion Detection: We maintain network security tools including firewalls and intrusion detection systems to protect against unauthorized access.
• Regular Security Audits: We conduct periodic security assessments and vulnerability testing to identify and address potential security risks.
• Data Minimization: We collect only the personal information necessary for the purposes described in this Privacy Policy.

6. Your Privacy Rights

Depending on your state of residence within the United States, you may have certain rights with respect to your personal information. We honor these rights as described below.

6.1 Rights Under the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA)

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

• Right to Know: You have the right to request that we disclose what personal information we collect, use, disclose, and sell about you.
• Right to Delete: You have the right to request deletion of your personal information that we have collected, subject to certain exceptions.
• Right to Correct: You have the right to request correction of inaccurate personal information we maintain about you.
• Right to Opt-Out of Sale or Sharing: You have the right to opt out of the sale or sharing of your personal information. We do not sell your personal information; however, certain advertising practices may be considered "sharing" under the CPRA.
• Right to Limit Use of Sensitive Personal Information: You have the right to limit our use of sensitive personal information (such as precise geolocation data or financial information) to what is necessary to perform the services.
• Right to Non-Discrimination: We will not discriminate against you 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.
• Right to Data Portability: You may request a copy of your personal data in a portable, readily usable format.

6.2 General Privacy Rights for All Users

Regardless of your state of residence, we extend the following rights to all users of our Website:

• Right to Access: You may request a copy of the personal information we hold about you.
• Right to Correction: You may request that we correct any inaccurate or incomplete personal information we hold about you.
• Right to Deletion: You may request that we delete your personal information, subject to our legal obligations to retain certain data.
• Right to Withdraw Consent: Where our processing is based on your consent, you may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to Opt-Out of Marketing: You may opt out of receiving marketing communications from us at any time.

6.3 How to Exercise Your Rights

To exercise any of your privacy rights, please submit a request by:

• Sending an email to: [email protected]
• Visiting our Website at: new-zupas.click and using our Privacy Request form

We will verify your identity before processing your request to protect your security. We will respond to verified requests within 45 days of receipt, as required under California law, with the possibility of extending this period by an additional 45 days where reasonably necessary, provided we notify you of the extension.

You may designate an authorized agent to submit requests on your behalf. We may require verification of the agent's authority before processing such a request.

7. Cookie Usage

Our Website uses cookies and similar tracking technologies to enhance your browsing experience, analyze site traffic, and deliver personalized content and advertisements.

7.1 What Are Cookies?

Cookies are small text files that are placed on your device when you visit a website. They allow the website to remember your actions and preferences over time, so you do not have to re-enter information every time you return.

7.2 Types of Cookies We Use

7.3 Managing Your Cookie Preferences

You can manage or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our Website and your ability to use some of our services. Most browsers allow you to:

• View cookies stored on your device
• Delete all or specific cookies
• Block cookies from specific websites
• Block third-party cookies
• Accept or reject all cookies

For more detailed information about managing cookies, please visit www.allaboutcookies.org. For more details about the specific cookies we use, please refer to our separate Cookie Policy available on our Website.

8. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, resolve disputes, and enforce our agreements. The specific retention periods vary depending on the type of data and the purpose for which it is used.

After the applicable retention period, personal information is securely deleted, anonymized, or archived in accordance with our data disposal procedures.

9. Children's Privacy

Our Website and 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 accordance with the Children's Online Privacy Protection Act (COPPA), or from individuals under the age of 18 without verifiable parental consent.

If you are under 18 years of age, you are not permitted to use our Website or provide any personal information to us without the direct involvement 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 (or under 18 without verified parental consent), we will take immediate steps to delete that information from our records. If you believe we may have collected information from a minor in violation of this policy, please contact us immediately at [email protected].

10. International Data Transfers

Zupas is based in the United States and our data processing operations are primarily conducted within the United States. If you are accessing our Website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country or region.

In the event that we engage service providers or partners located in other countries, we ensure that appropriate safeguards are in place for any international transfer of personal data, consistent with applicable law. These safeguards may include contractual data protection clauses, participation in recognized data transfer frameworks, or other legally recognized transfer mechanisms.

By using our Website and providing your personal information, you acknowledge and consent to the transfer of your data to the United States and other countries as described in this Privacy Policy.

11. Third-Party Websites and Links

Our Website may contain links to third-party websites, social media platforms, or external services that are not owned or operated by Zupas. This Privacy Policy applies solely to our Website and services. We are not responsible for the privacy practices of any third-party websites, and we encourage you to review the privacy policies of any external sites you visit. The inclusion of a link to a third-party website does not imply our endorsement of that site or its privacy practices.

12. Do Not Track Signals

Some browsers include a "Do Not Track" (DNT) feature that signals to websites that you do not want your online activity tracked. Currently, there is no universally accepted standard for how websites should respond to DNT signals. As such, our Website does not currently alter its data collection and use practices in response to DNT browser signals. We will continue to monitor developments in this area and will update this policy accordingly if a standard is established.

California residents have the right under the California Shine the Light Law (Civil Code Section 1798.83) to opt out of the sharing of personal information with third parties for direct marketing purposes. If you are a California resident and wish to exercise this right, please contact us at [email protected].

13. FTC Compliance and Consumer Protection

We operate in compliance with the Federal Trade Commission (FTC) Act and FTC regulations governing unfair or deceptive acts and practices in commerce. Our privacy representations are accurate, complete, and not misleading. We do not engage in unfair data collection practices and we honor all privacy commitments made to our users. We implement reasonable security measures as required by FTC guidelines and applicable sector-specific regulations.

If you believe our privacy practices are inconsistent with the representations made in this Privacy Policy or that we have engaged in unfair or deceptive privacy practices, you may file a complaint with the Federal Trade Commission at:

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

If you reside in California and have concerns about our privacy practices that have not been resolved to your satisfaction, you may file a complaint with:

14.1 California Privacy Protection Agency (CPPA)

14.2 California Attorney General

For residents of other states, your state attorney general's office may also have jurisdiction over consumer privacy complaints. We encourage you to contact your state's consumer protection authority if you have unresolved privacy concerns.

15. 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, applicable laws, or business operations. When we make material changes to this Privacy Policy, we will:

• Post the updated Privacy Policy on this page with a revised "Last Updated" date
• Send an email notification to registered users where required by law
• Display a prominent notice on our Website homepage for a reasonable period following the update

Your continued use of our Website and services after we post any modifications to the Privacy Policy will constitute your acknowledgment of the modifications and your consent to abide by the updated policy. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

16. 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 using the details below. We are committed to resolving any privacy concerns you may have in a timely and transparent manner.

We will make every effort to respond to your privacy-related inquiries within 30 days of receiving your request. For requests submitted under the CCPA/CPRA, we will respond within the 45-day statutory period.