Privacy Policy

Last Updated: June 28th, 2019

Introduction

Protecting your private information is our priority. This Privacy Policy has been compiled to better serve you and to be completely transparent about how we collect, use, protect, or otherwise handle your private information.

Our website address is https://delucasdeli.com and the organization name is Deluca's Italian Deli with a mailing address of 1800 Avenue of the Stars Century City, CA 90067. Deluca's Italian Deli (“us”, “we”, or “our”) operates the https://delucasdeli.com website (the “Site”). This Statement of Privacy applies to https://delucasdeli.com and Deluca's Italian Deli and governs data collection and usage.

The Deluca's Italian Deli website is an informational website with pictures of our food and information about our menu and available products. By using the https://delucasdeli.com website, you consent to the data practices described in this statement.

Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use, accessible from https://delucasdeli.com/terms/.

  • Site: Site is the https://delucasdeli.com website operated by Deluca's Italian Deli of which this Privacy Policy applies.
  • Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
  • Usage Data: Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, while you are visiting a page on https://delucasdeli.com, we may collect data on which pages you visited and which links you clicked on).
  • Cookies: Cookies are small pieces of data stored on your device (computer or mobile device).
  • Data Controller: Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. What does that really mean? For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data, meaning Deluca's Italian Deli determines why and how your personal information will be processed.
  • Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively and to more accurately and more easily provide our product or service to you. In an effort to give you control over your personal information, [site_name] provides a list of those Service Providers and how your information is being used under the Storage and Transfer of Your Data section.
  • Data Subject (or User): Data Subject is any living individual who is using our Site and is the subject of Personal Data. The Data Subject is you and is often called the “user” or “consumer”.

Collecting Your Personal Information

We collect several different types of information from you for the purposes of providing and improving our product or service to you, analyzing website functionality, or to diagnose and track errors or glitches. Below are the types of data we collect:

Storing and Transferring Your Data

Deluca's Italian Deli will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Deluca's Italian Deli will not retain your credit or debit card information on https://delucasdeli.com or any other online service. Only the approved service providers under the General Information section will retain access to your credit or debit card details. Deluca's Italian Deli will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer time periods.

Your information, including Personal Data, may be transferred to (and maintained on) computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. If you are located outside of the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Deluca's Italian Deli will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Deluca's Italian Deli does not sell, rent or lease its customer lists or its users’ Personal Data to third parties.

Deluca's Italian Deli may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Deluca's Italian Deli, and they are required to maintain the confidentiality of your information.

The next few tabs contain a list of places where Deluca's Italian Deli keeps your personal information and the way your data is transferred between them.

Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Site. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Site available to Google Analytics by installing the Google Analytics opt-out browser add- on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

We may use third-party Service Providers to show advertisements to you to help support and maintain our Site.

Google AdSense and DoubleClick Cookie: Google, as a third party vendor, uses cookies to serve ads on our Site. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Site or other websites on the Internet.

You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: https://www.google.com/ads/preferences/

Facebook: Facebook re-marketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance.

You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA: https://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada: https://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe: https://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

Google Web Fonts: For uniform representation of fonts, this website uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.

For this purpose your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our Site. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.

If your browser does not support web fonts, a standard font is used by your computer. Further information about handling user data, can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy at https://www.google.com/policies/privacy/.

Under certain circumstances, Deluca's Italian Deli may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Deluca's Italian Deli may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary:

  • To conform to the edicts of the law or comply with legal process served on Deluca's Italian Deli or the site.
  • To protect and defend the rights or property of Deluca's Italian Deli.
  • To act under exigent circumstances to protect the personal safety of users of Deluca's Italian Deli, or the public.
  • To protect against legal liability.

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. As a result, you acknowledge that:

  • There are security and privacy limitations inherent to the Internet which are beyond our control.
  • Security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.

Deluca's Italian Deli makes every reasonable effort to secure your Personal Data from unauthorized access, use, or disclosure. Deluca's Italian Deli uses the following methods for this purpose:

SSL Protocol: When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.

We may provide paid products and/or services within the Site. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

Clover: Their Privacy Policy can be viewed at https://www.clover.com/privacy-policy

This procedure outlines the processes to be followed in the event that https://delucasdeli.com experiences a data breach or suspects that a data breach has occurred. A data breach involves the loss of, unauthorized access to, or unauthorized disclosure of, personal information.

Alert: When a privacy data breach is known to have occurred, or is suspected, a site admin of https://delucasdeli.com who becomes aware of this must alert the DPO (Data Protection Officer) or Privacy Officer within 24 hours. The information included in this alert consists of:

  • Time and date of breach.
    Description of breach and type of Personal Data involved.
  • Cause of the breach, if known, as well as how it was discovered.
  • Which systems are affected?
  • Whether actions have been taken to correct or remedy the breach, or suspected breach.

Determining the Potential Impact: Once the Privacy Officer or Deluca's Italian Deli is notified, the officer must determine whether or not a breach has actually occurred and make an assessment on the severity of the breach, or potential breach. Details of the report are as follows:

  • Is Personal Data involved?
  • Is the Personal Data of a sensitive nature?
  • Has there been unauthorized access to personal information, unauthorized disclosure of personal information, or loss of personal information?
  • Determining the severity of the breach through type and extent of Personal Data involved.
  • Determining whether multiple individuals have been affected, whether the information is protected by any security measures (password protection, SSL encryption, etc.).
  • Determining the person or groups who now have access and whether they pose a real risk of serious harm (physical, emotional, economic, or financial harm to reputation) to the affected individuals.
  • Determining if there are Federal or State laws that may have been implicated by the breach, or suspected breach.

Data Breach Response Team

The DPO or Privacy Officer must issue internal notifications to the site admins and Deluca's Italian Deli officers to make aware of the breach, or potential breach, and the plan for managing and correcting the issue. The Data Breach Response Team will consist of:

  • DPO or Privacy Officer
  • Human Resources Manager (or CEO if no Human Resources Manager is appointed)
  • Marketing Director
  • Information Technology Manager or Webmaster

The DPO or Privacy Officer must submit a report to all Data Breach Response Team members consisting of initial Alert, Determined Impact, and Resolution Plan. The following steps will be taken:

  • Contain the breach (if it has not already been contained) through retrieving the lost Personal Data, completely blocking unauthorized access, securing physical areas (server locations), and/or shutting down the affected systems.
  • Collecting and documenting all available evidence of the breach.
  • Reporting the breach to the governing agency: the FTC in the United States.
  • Remove any improperly posted information from the web: If the data breach involved Personal Data which became posted on https://delucasdeli.com the Response Team must remove it and search other websites to make sure they do not have a saved copy of the Personal Data.
  • In the case the Personal Data is posted on other websites, the DPO or Privacy Officer will contact those sites and ask them to remove it.
  • All service providers of https://delucasdeli.com will be investigated and/or contacted to determine if they were the source of the breach. The Response Team will verify that the service providers have taken every step to remedy the vulnerability and ensure another breach does not occur.

Notifications and Contact Information

The Marketing Director must issue the following public and private notifications:

  • Through the use of a site-wide banner on https://delucasdeli.com, notify any resident of California whose unencrypted Personal Data was, or is reasonably believed to have been, acquired by an unauthorized person, according to the California S.B. 1386 bill.
  • Notify local law enforcement of the potential risk for identity theft.
  • Communicate the details of the breach, what Personal Data may have been affected, what steps Deluca's Italian Deli is taking or has taken to correct the breach, and recommendations to the user regarding changing their password on https://delucasdeli.com (if they have one) and any other suggestions to help prevent further Personal Data Breaches.

General Data Protection Regulation (GDPR) Policies

If you are from the European Economic Area (EEA), Deluca's Italian Deli’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. Deluca's Italian Deli may process your Personal Data because:

  • We need to process a sale or transaction with you.
  • You have given us permission to do so.
  • The processing is in our legitimate interests and it’s not overridden by your rights.
  • For payment processing purposes.
  • To comply with the law.

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Deluca's Italian Deli aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where Deluca's Italian Deli relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Holiday Closure

In order to give our beloved staff a chance to celebrate the holidays with their family and friends, Delucas Deli will be closed from Monday, Dec 23rd to Sun Dec 29th.
 
We will resume the normal operations on Monday, December 30th.
 
Thank you for your understanding and your continued patronage.