Table of Contents

1. Privacy Statement
2. Consent
3. Consent to Share and Disclose Information, Including International Data Transfers
4. Consent to Electronic Notice If There is a Security Breach
5. Type of information we may collect
6. Internet Users – Cookies, Internet Protocol (IP) Address, Aggregate Information
7. Compliance with the Digital Advertising Alliance
8. Interest-Based/Online Behavioral Advertising
9. Children and Data Collection
10. A Note to Parents/Guardians - Additional Information About Children’s Privacy
11. Our Use of Your Personal Information
12. Collection and Use of Customer Information
13. Collection and Use of SUBWAY® Franchisee and Prospective Franchisee Information
14. Collection and Use of Development Agent Information
15. Mobile Information
16. Marketing Promotions and Advertising
17. Forward-to-a-Friend and Refer-a-Friend
18. Opt-Out of Email and Mobile Updates
19. Sharing of Personal Information
20. Security
21. Phishing
22. Storage, Retention and Accuracy of Personal Information
23. Access, Control and Update Information About You
24. Contact Information
25. Links to Non-DAI Web Sites and Third Parties
26. Social Media and Online Engagement
27. Your California Privacy Rights
28. Safe Harbor Compliance
29. Members of the European Union
30. International Privacy Policies
31. Changes to our Privacy Policy
32. Terms and Conditions of Website Use

1. Privacy Statement - (Top)

Your privacy is very important to us. This Privacy Policy discloses how Doctor’s Associates Inc., (“DAI”) and its affiliated companies and subsidiaries collects, protects, uses and shares personal information gathered about. Our privacy practices are consistent with:

• The European Union Data Protection Directive and the U.S. Department of Commerce Safe Harbor Program Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.
• Fair information practices established by the Organization for Economic Co-operation and Development (OECD).
• The Asia Pacific Economic Cooperation forum (APEC) Privacy Framework..
• Applicable country, national, state and local data protection laws (some country’s laws require country specific information in a privacy policy.

DAI, the owner of the SUBWAY® Restaurant System is an affiliate of Franchise World Headquarters, LLC (“FWH”), which operates as a service-oriented company for and on behalf of the SUBWAY® System worldwide by providing core business related services for the following franchising entities: Subway International B.V. (“SIBV”), Subway Systems Australia Pty Ltd (“SSA”), Subway Franchise Systems of Canada, Ltd. (“SFSC”), Subway Partners Colombia C.V. (“SPCCV”), Subway Systems do Brasil Ltda. (“SSB”), Sandwich and Salad Franchises of South Africa Pty Ltd. (“SSFSA”), Subway Systems India Private Limited (“SSIPL”). DAI owns and licenses the SUBWAY® trademark and SUBWAY® Restaurant System to its affiliates in order to develop SUBWAY® restaurants.

DAI shares information, including Personal Information, with the SUBWAY® Group and the following SUBWAY® Group advertising entities:  Subway Franchisee Advertising Fund Trust, Ltd. (“SFAFT”) is a Connecticut statutory trust, with a business address at 325 Bic Drive, Milford, CT 06461. Subway Franchisee Advertising Fund Trust, B.V. (“SFAFT BV”) is a Netherlands limited liability company, with a business address at Prinsengracht 13, 1015 DK Amsterdam.  Subway Franchisee Advertising Fund of Australia Pty. Ltd. (“SFAFA”) is a company limited by shares, with a business address at Level 1, 42 Amelia Street, Fortitude Valley, Queensland, 4006, Australia. Subway Franchisee Advertising Fund of Canada, Inc./Le Fond De Publicité Des Franchisés Subway Du Canada Inc. (“SFAFC”) is a federal corporation, with a business address at Monarch Registries, 11210-107 Avenue NW, Main Floor, Ed Monton, AB T5H 0Y1.  The FAF Group administers national and local advertising funds and activity for SUBWAY® restaurants and SUBWAY® franchisees worldwide.  SFAFT, SFAFT BV, SFAFA, an SFAFC are collectively referred to herein as the “FAF Group”.

All Personal Information is collected in a fair and non-intrusive manner, with your voluntary consent. Personal Information is not accessible to anyone outside the specific function for which it is collected. DAI respects the privacy of our SUBWAY® customers and other visitors to our websites who may choose to provide personal information. We recognize the need for appropriate protections and management of personal information that you provide to us. This Privacy Policy will assist you to understand what types of information we may collect, how that information may be used, and with whom the information may be shared.

This This Privacy Policy explains DAI’s practices regarding the information collected online from users of the SUBWAY® Restaurant Systems website located at www.subway.com.

In an effort to comply with the law, and our commitment to protect your personal information, we provide the following, which discloses our policies. Please note that this Privacy Policy does not govern the privacy policies and procedures of independently owned and operated SUBWAY® stores. In addition, this privacy policy does not govern the personal information handling policies and procedures of FWH or our affiliates within the SUBWAY® Group. To find out more about the SUBWAY® Groups privacy practices, please see the SUBWAY® Online Privacy Notice located at: http://www.subway.com/subwayroot/PrivacyNotice.aspx.

2. Consent - (Top)

This Privacy Policy applies to all information gathered for and on behalf of DAI, whether in writing, verbally or electronically, through any website operated by or on behalf of DAI, including, but not limited to, www.subway.com, together with any and all future websites that are operated by or on behalf of DAI. By using www.subway.com, or participating in any program or service managed by DAI, you consent to the data collection and use practices described in this Privacy Policy. If you have questions about this Privacy Policy or the protection of your information, please contact the Privacy Officer at privacyofficer@subway.com.

BY SUBMITTING PERSONAL INFORMATION TO DAI, AND/OR BY ACCESSING AND USING THE WEBSITE, YOU AGREE THAT DAI MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS AS PERMITTED OR REQUIRED BY LAW.

3. Consent to Share and Disclose Information, Including International Data Transfers Data Transfers - (Top)

In addition to consenting to this Privacy Policy and the Terms and Conditions, including any relevant supplemental policies, you expressly consent to DAI sharing the information that you have provided, as described herein. DAI may share information with its subsidiaries, the SUBWAY® Group and the FAF Group. DAI may also share information with companies that provide support services to it, such as credit card processors, mailing houses, web hosts, technical support providers, fulfillment centers or other service providers or for enforcing or investigating transactions or business operations, because these companies may need information about you in order to perform their functions. These companies are not authorized to use the information DAI shares with them for any other purpose, but DAI does not control these companies. You agree that DAI and those with whom it shares information (the "Recipients") may disclose and transfer your information worldwide, including in and outside the United States, the European Economic Area, Canada, and other jurisdictions serviced by the SUBWAY® Group, for any purpose relating to DAI’s operations and programs.

4. Consent to Electronic Notice if there is a Security Breach - (Top)

If DAI or a Recipient is required to provide notice of unauthorized access of certain security systems, you agree that DAI, or the Recipient, may do so when required or voluntarily by posting notice on the Website or sending notice to any email address DAI or the Recipient has for you, in the good faith discretion of DAI or the Recipient. You agree that notice to you will count as notice to any other individual for whom you are acting and agree to provide the notice to any such individual.

5. Type of information we may collect - (Top)

Personal Information is defined as any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, by reference to a Social Security Number and/or Identification Number (hereinafter “SSN/I.N”) or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

Personal Information shall include but is not limited to: name, home address, home zip code, home telephone number, mobile phone number, email address, Social Security Number and/or Identification Number, financial information and employment related information such as may be found on resumes, applications, background verification information, or in employment references.

DAI takes measures to maintain the confidentiality of your SSN/I.N to protect your SSN/I.N from unlawful disclosure, and to limit access to your SSN/I.N. DAI will not make your SSN/I.N available to the general public, print your SSN/I.N on any card, require you to provide your SSN/I.N to access any products or services, transmit your SSN/I.N over the Internet unless the connection is secure or your SSN/I.N has been encrypted, or requires the transmittal of your SSN/I.N to access our Website without requiring additional authentication.

Non-personal information is information that is already a matter of public record or knowledge. Business contact information is considered non-personal information and not subjected to special protection and it can be routinely shared with anyone inside or outside of the business. Business contact information shall include but is not limited to: business name, business address, business telephone number, and is not considered personal information in certain jurisdictions.

Sensitive data is information that can include but is not limited to, an individual’s gender, racial or ethnic origins, politics, religion, trade union membership, veteran status, physical or mental health, disabilities, sex life, sexual orientation, or criminal (or alleged criminal) activities, proceedings or convictions. We will never collect Sensitive Personal Information except to comply with Affirmative Action data requirements.

Cookies - in addition to Personal Information, we use data collection devices such as "cookies" on certain web pages to help analyze our web page flow and measure promotional effectiveness. Cookies are pieces of information a website sends to an individual’s hard drive while they are viewing the website. Cookies allow the website to remember important information that will make your visit to the site more useful. We use cookies to help improve your future visits. If you do not wish to receive a cookie or if you wish to set your browser to warn you each time a cookie is being sent, or if you wish to turn off all cookies, use the options on your browser to assist you. The “Help” option on your browser may assist you in changing your cookie preferences. Please note that by turning cookies off, you will not have access to many features available on our website.

Web Beacon - Also called a Web bug or a pixel tag or a clear GIF. We use pixels tags or transparent GIF files, to help manage our online advertising and promotions. These tags collect anonymous (not personally identifiable) information about which advertisements and promotions bring users to our website. With both cookie and tag technology, the information that we collect and share is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address.

Web beacons are typically used by a third-party to monitor the activity of a site. A Web beacon can be detected by viewing the source code of a Web page and looking for any IMG tags that load from a different server than the rest of the site. Turning off the browser's cookies will prevent Web beacons from tracking the user's activity. The Web beacon will still account for an anonymous visit, but the user's unique information will not be recorded.

Internet Protocol (IP) Address - an Internet Protocol (IP) Address is associated with your computer's connection to the internet. DAI may use your IP address to help diagnose problems with DAI’s server, to administer the Website and to maintain contact with you as you navigate through the Website. Your computer's IP address also may be used to provide you with information based upon your navigation through the Website. DAI does not link IP addresses to any Personal Information.

Aggregate Information – is used to measure the visitors’ interest in, and use of, various areas of the Website and the various programs that DAI administers, DAI will rely upon aggregate information, which is information that does not identify you, such as statistical and navigational information. With this aggregate information, DAI may undertake statistical and other summary analyses of the visitors' behaviors and characteristics. Although DAI may share this aggregate information with third parties, none of this information will allow anyone to identify you, or to determine anything else personal about you.

7. Compliance with Digital Adverising Alliance - (Top)

The SUBWAY® Group uses the Evidon assurance platform to comply with the cross-industry Self-Regulatory Program for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA) (http://aboutads.info). As part of this service, The SUBWAY® Group’s online advertisements and Web sites are sometimes delivered with icons that help consumers understand how their data is being used and provide choice options to consumers that want more control. The list of our advertising partners may be updated from time to time. To opt-out of internet-based advertising by all DAA-participating companies, visit http://www.aboutads.info/choices/.

8. Interest-Based/Online Behavorial Advertising - (Top)

On some pages of our site we may allow third-party advertising partners to set web tracking tools (e.g., cookies and web beacons) to collect anonymous, non-personally identifiable information regarding your activities on those pages (e.g., your IP address, page(s) visited, time of day). We may also share such information we have collected with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering future targeted advertisements to you when you visit other (non-SUBWAY®) sites within their networks. This practice is commonly referred to as "interest-based advertising" or "online behavioral advertising." Pages of our website that collect information that may be used by such advertising partners for interest-based advertising purposes may be identified by a link to AdChoices on the page.

Opting out (site pages). If you do not want your browsing while on such pages to be used for interest-based advertising purposes, you may click on the AdChoices link to opt-out of such uses by the listed advertising partner(s). Even if you opt-out through this service, we may still collect non-personally identifiable information regarding your site activities and use it for non-interest-based advertising purposes as described in this privacy statement.

Opting out (advertisements). Advertisements on third-party sites that contain the AdChoices link and that link to this privacy policy may have been directed to you based on anonymous, non-personally identifiable information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners' use of this information for interest-based advertising purposes. Even if you opt-out through this service, we may still collect and use information from the advertisements for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

DAI adheres to the federal privacy protection standards as stated in the Children's Online Privacy Protection Act (“COPPA”). We care about the safety of children. We will not knowingly allow anyone under 13 to provide us any personally identifying information. Children under 13 years of age are required to obtain the express permission of a parent or guardian before submitting any Personal Information about themselves (such as their names, e-mail address, and phone number) over the Internet. If a child has provided us with personally-identifiable information without the consent of a parent or guardian, the parent or guardian of that child should contact the Privacy Officer immediately at privacyofficer@subway.com. We will use reasonable efforts to promptly delete the child's information from our servers.

At DAI, children’s privacy is important to us. Therefore, we take additional measures to help children protect their privacy while online including not asking them to disclose more personally identifiable information than is necessary for them to participate in an activity and encouraging them to use non-personally identifiable screen names rather than their real names.

DAI is dedicated to protecting your privacy and handling any personal information we obtain from you with care and respect. This Children's Privacy Statement is designed to answer your questions regarding our privacy policies and principles with respect to children under the age of 13. DAI recognizes the need to provide additional privacy protections when children visit our website at www.subway.com.

The Children's Online Privacy Protection Act ("COPPA") requires that we inform parents and legal guardians about how we collect, use, and disclose personal information from children under 13 years of age; and that we obtain the consent of parents and guardians in order for children under 13 years of age to use certain features of our website. Also, when we use the term "parent", we mean to include legal guardians.

Children can participate in many of our features without providing personally identifiable information. However, to enable their participation in certain of our interactive features, we may ask children to provide us with personally identifiable information. The types of information we may request include first name as well as the child’s and parent’s email addresses. We use a child’s email address to respond to a specific request to participate in an activity (e.g., participate in a contest or sweepstakes, respond to their question, enable them to subscribe to a newsletter). We use parents’ e-mail addresses to obtain their consent or notify them of their child's online activities and enable the parent to unsubscribe the child from a newsletter or other similar activity.

We do not share children's personally identifiable information with outside third parties not bound by this Privacy Policy. Sometimes, we use agents or contractors to help us conduct a contest or sweepstakes, send prizes to winners, or provide customer service related to activities on the site. In these cases, we require the agent or contractor to keep the information confidential and to use it only for the specific services they are performing.

At any time parents can refuse to permit us to collect further personal information from their child and can request that any personal information we have collected be deleted from our records.

We will provide parents notice by e-mail of any material changes in the way we intend to collect, use, and/or share their child’s personal information. Please note that, at all times, parents should update their personal information to provide us a current email address.

If you would like to review any personally identifiable information that we have collected online from your child, have this information deleted, and/or request that there be no further collection or use of your child's information, or if you have questions about these information practices, you may contact our Privacy Officer. The Privacy Officer can be reached by telephone at: (203) 877-4281 or 1-800-888-4848; by Facsimile at: (203) 783-7479; by email at: privacyofficer@subway.com; or by mail at Franchise World Headquarters, LLC, 325 Bic Drive, Milford, CT, 06461, USA.

We use your Personal Information to facilitate the services you request. We have tailored our Privacy Policy to adequately inform you of the use of your Personal Information.

DAI will not collect customer Personal Information, unless the customer contacts DAI directly. In order to adequately address a customer’s concern, their Personal Information may be shared with our affiliate FWH and other affiliates within the SUBWAY® Group, the SUBWAY® Group’s area Development Agents and franchisees. The SUBWAY® Group Development Agents assist with franchise sales, site location, training, and provide operational assistance to franchisees. Failure to provide necessary information may prevent DAI from fully addressing any customer concerns.

If you choose to, you may submit via www.subway.com an electronic application seeking consideration as a prospective SUBWAY® franchisee. By submitting an electronic application, you agree that we may disclose your personal information to our affiliates within the SUBWAY® Group, their Development Agents, other SUBWAY® Group affiliates, and third party service providers as part of their consideration to your inquiry and to help them conduct their franchise marketing efforts. Information on your online form will become part of any application for a franchise that you might later submit. We require our affiliates within the SUBWAY® Group and their Development Agents to respect DAI’s privacy practices and not use your personal information for purposes other than to carry out our instructions.

By applying to become a SUBWAY® franchisee, a prospective franchisee consents to the collection, use, and disclosure of Personal Information in accordance with the following terms and conditions. We collect and use Personal Information in order to assist a prospective franchisee in applying to become a SUBWAY® restaurant franchisee and to assist our affiliates within the SUBWAY® Group in selecting franchisee candidates.

Personal Information collected from prospective franchisees include, but is not limited to: name, address, telephone number, facsimile number, email address, date of birth, citizenship, educational background, criminal background, bank account information for Electronic Funds Transfer, financial statement, litigation history, and taxpayer identification number. Failure to provide requested Personal Information may negatively impact a prospective franchisee’s ability to become a franchisee. Once a prospective SUBWAY® restaurant franchisee becomes a franchisee, they may then reference themselves by their Franchise Agreement Number. In order to better service franchisees, a franchisee’s Personal Information may be shared between DAI and its affiliates within the SUBWAY® Group, pursuant to the service contracts between them.

In order to effectively implement the SUBWAY® Gift Card Program, and to provide purchasing services to members, a franchisee’s Personal Information may be shared with an independent purchasing cooperative or other independent third party. The Personal Information shared with the independent purchasing cooperative shall include, but will not be limited to: name, address, credit card information, and other related information necessary for billing purposes, such as a mailing address for credit card validation, and bank account information, you provided to DAI to establish your pre-authorized account for the payment of royalties, advertising fees, and other charges. Subject to a franchisee’s agreement with the independent purchasing cooperative, the independent purchasing cooperative may bill a franchisee’s bank account for fees and other costs associated with the SUBWAY® Gift Card Program. If a franchisee does not wish to disclose this information, they must notify the Privacy Officer in writing as described in the section titled “Contact Information” below.

A franchisee and/or prospective franchisee’s information may be shared with the SUBWAY® DAI Development Agent in their area. A Development Agent is an independent contractor of DAI. The Development Agents assist with franchise sales, site location, service franchisee leasing needs, provide operational assistance and related administrative functions, training to the franchisee. Development Agents also make recommendations as to whether a prospective franchisee in their territory should be granted a franchise. The Development Agent may use this information to: address a franchisee’s concerns in a customer complaint, respond to a franchisee’s inquiries for franchise sales, franchisee Personal Information may be shared during store transfers, and any other inquiry which may require a response. Franchisee Personal Information may also be shared with Subway Franchisee Advertising Fund Trust (“SFAFT”) in order to provide advertising services to member stores.

Finally, upon becoming a SUBWAY® franchisee you consent to DAI disclosing former or past franchisee contact information including Personal Information in its Disclosure Document for one (1) year after leaving the system, as required by law, unless you advise otherwise. Contact our Privacy Officer in writing, either by email or regular mail received, of your desire to not have your details or contact information disclosed, corrected or changed when you sell or transfer your SUBWAY® store, or exit the SUBWAY® system (whether by termination or otherwise). To contact the Privacy Officer, please see the section provided below entitled “Contact Information”.

By applying via www.subway.com to become a SUBWAY® Development Agent, a Development Agent applicant consents to the collection, use, and disclosure of Personal Information in accordance with the following terms and conditions. We collect and use Personal Information in order to assist you in applying and evaluating you to become a SUBWAY® Development Agent. Personal Information is collected to assist our affiliates within the SUBWAY® Group in selecting Development Agent candidates and for the purpose of operating a development territory.

Personal Information collected includes, but is not limited to: name, home address, home telephone number, facsimile number, email address, date of birth, bank account information for Electronic Funds Transfer, financial statement, resume, taxpayer identification number and background checks. Failure to provide necessary information may negatively impact your ability to become a Development Agent.

Once a Development Agent candidate becomes a Development Agent, they may then reference themselves by their Development Agent Number. As a Development Agent within the SUBWAY® Group, certain business information with respect to stores within your territory may be shared in the aggregate amongst your DA community. Such business information may include, but is not limited to, 3 year DA Performance Report, Emerging Market Developing Activity Report, Developed Market Report, Subway Compared to other QSR Report, and the Weekly Same Store AUV and Units Report.

Mobile Information We Collect

You may use a referral feature (either on a web page, in an e-mail, from a banner ad or other communication) to inform a friend about a SFAFT web page or promotion. SFAFT may use any e-mail address provided when using this referral feature to send both an initial e-mail and a subsequent e-mail to recipients about the particular promotion, product, or service in which you indicated your "friend" may have an interest.

• Personally identifiable information (e.g. Name, email address) we collect consists only of what you share with us. For example, certain products may ask for this type of information so that we may contact you by phone or email at your request. You choose what, how, and when you want to share.

• If you use any location-enabled products, you may be sending us location information. DAI does not store or use this information other than to provide the service you requested. For example, a mobile product may use GPS data to find a nearby restaurant you requested. Location-enabled features are opt-in and you have control over your participation and can turn these services off at any time.

• Web-enabled mobile applications may use cookies or web beacons and other methods to customize your browsing experience. Please see DAI's web privacy policy for more information.
• Some mobile applications will utilize Google Analytics (or similar tool) to help us better serve our customers through improved products, services, and revisions to the mobile applications. This collected information will not identify you to DAI. It may, however, let us know anonymously, which services and features you are using the most within the application, as well as device type and hardware features, country and language of download.
• Use of 3rd party services such as social sharing sites (e.g., Facebook and Twitter) is governed by the privacy practices of those services. DAI does not capture or store your login information or other personally identifiable information for these services, however session info or cookies may be stored.

Mobile How We Use Collected Information

• We use the information to personalize your experience with the application and to improve your overall experience including the development of new products, services, and features. We also use the information to provide customer support, and when applicable, register and administer your account. Additionally, we may use the information you provide to contact you about updates to our service.
• Information you provide may be used to fulfill the service(s) or carry out the transaction(s) you have requested or authorized.

Mobile Information sharing

• DAI does not share any collected information with 3rd parties with the following exceptions:
• DAI may provide some personal data to third-party partners that are providing services essential to your mobile user experience
• All requests are sent through your mobile carrier's network and your carrier may have access to it. Consult your carrier's privacy policies for additional information.
• Certain mobile products and services and manufacturers allow you to interact and share your information with others. For example, you may want to Tweet or post to your Facebook page content from a DAI mobile application. Consult your mobile device manufacturer, or mobile product or application developer's privacy policies for additional information.

If you participate in any advertising or marketing promotions the information that you provide will be handled in accordance with the Privacy Policy specific to said promotion which cannot and does not apply to this Privacy Policy.

You may use a referral feature (either on a web page, in an e-mail, from a banner ad or other communication) to inform a friend about a Southwest web page or promotion. DAI may use any e-mail address provided when using this referral feature to send both an initial e-mail and a subsequent e-mail to recipients about the particular promotion, product, or service in which you indicated your "friend" may have an interest.

You may have the opportunity to elect to receive email and mobile communications from FWH. FWH will only email you or send you mobile alerts if you elect to receive them. If you elect to receive email and mobile communications, FWH will send you occasional updates about new additions to the Website as well as special offers and promotions of which you can take advantage. If at any time you decide you would rather not receive these types of communications from FWH, you can opt-out by clicking the unsubscribe link at the bottom of any FWH email, update the contact preferences for your account, for mobile marketing, you may opt-out by following the instructions provided in the text messages you receive, or contact the Privacy Officer at privacyofficer@subway.com.

We may share Personal Information with our service providers, consultants and affiliates for our internal business purposes. Except as described in this Privacy Policy, DAI will not share Personal Information with a third party, unless a customer requests, consents to such disclosure, or disclosure is required or authorized by law. DAI reserves the right to disclose Personal Information to a third party if a law, regulation, search warrant, subpoena, or court order legally requires or authorizes us to do so. DAI also reserves the right to disclose and/or transfer Personal Information to a third party in the event of a proposed or actual purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, or financing of all or any portion of DAI or of any of the business or assets or shares of DAI or a division thereof in order for a customer to continue to receive the same products and services from the third party.

As described above, DAI, its affiliates within the SUBWAY® Group, third party service providers, and SUBWAY® Development Agents may share and exchange Personal Information in order to process franchisee applications, administer the SUBWAY® franchise system, and protect the integrity of the SUBWAY® franchise system and trademarks. Personal Information may be provided to a courier or freight forwarder to fulfill an order, which may have been requested from us.

SUBWAY® Development Agents and other service providers are prohibited from using Personal Information for any purpose other than to provide assistance to DAI and its affiliates within the SUBWAY® Group. Development Agents are required to protect Personal Information disclosed by us and to comply with the general privacy principles described in this Privacy Policy.

We endeavor to protect your Personal Information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our control. These measures include safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use and modification.

We safeguard your Personal Information on the Internet by using industry-standard practices. Although "guaranteed security" does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with our Privacy Policy and all applicable laws and regulations. We maintain physical, electronic and procedural safeguards as appropriate to safeguard your Personal Information.

Currently, our website utilizes a variety of different security measures designed to protect Personal Information of users both inside and outside SIBV, including the use of encryption mechanisms (e.g., Secure Socket Layers or SSLs), password protection, and other security measures to help prevent unauthorized access to your personally identifiable information. This helps maintain the confidentiality, privacy, and integrity of your transactions, and helps to protect your confidential information - such as credit card numbers, online forms, and financial data from loss, misuse, interception and hacking.

Identity theft and the practice currently known as “phishing” are of great concern to Virgin America. Accordingly, safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, Social Security Number or National Identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.

DAI and its affiliates the SUBWAY® Group, insures that Personal Information is safeguarded against loss, access, use, modification, disclosure or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your Personal Information. 

DAI will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purpose(s) remains valid after termination of our relationship with you

We take all reasonable steps to insure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading.

We want to be sure that we keep only the most accurate and up-to-date Personal Information in our records. Therefore, whenever you believe that your Personal Information needs to be updated, you can email us at privacyofficer@subway.com to update your contact information. You may choose at any time to remove your name, telephone numbers, and postal and email addresses from the lists we use to send notices or updates and elect not to receive correspondence from us by sending us an email at privacyofficer@subway.com.

To protect your privacy, we will take reasonable steps to help verify your identity before granting access or making changes.

You may contact the Privacy Officer to access, correct or delete your Personal Information. If necessary, the Privacy Officer will contact another employee to assist in completing your requested task.

At this time, SFAFT has three Social Media Accounts, Facebook.com/subway, Twitter.com/subwayfreshbuzz (we also own and in the near future will be migrating our Twitter Account to twitter.com/subway), and Youtube.com/subway.

25. Links to Non-DAI Web Sites and Third Parties - (Top)

Please note that www.subway.com may contain links to other web sites for your convenience and information. DAI does not control those sites or their privacy practices, which may differ from www.subway.com. DAI’s privacy policy cannot and does not apply to external websites. We do not endorse or make any representations about third party web sites. The personal data you choose to give to unrelated third parties is not covered by the DAI privacy policy. We encourage you to review the privacy policy of any company or website before submitting your Personal Information. Some third parties may choose to share their personal data with DAI; that sharing is governed by that third party company’s privacy policy.

DAI and the SUBWAY® Group, uses a variety of new technologies and social media options to communicate and interact with consumers. These sites and applications include popular social networking and media sites, open source software communities and more. To better engage the public in ongoing dialog, the SUBWAY® Group uses several third-party platforms including, but not limited to, Facebook, Twitter, and YouTube. Third-Party Websites and Applications (TPWA) are Web-based technologies that are not exclusively operated or controlled by the SUBWAY® Group. When interacting with the the SUBWAY® Group’s presence on those websites, you may reveal certain personal information to the SUBWAY® Group or to third parties. Except when used by the SUBWAY® Group’s employee’s for the purpose of responding to a specific message or request, the SUBWAY® Group will not use, share, or retain your personal information.

At this time, the SUBWAY® Group has three Social Media Accounts, Facebook.com/subway, Twitter.com/subwayfreshbuzz (we also own and in the near future will be migrating our Twitter Account to twitter.com/subway), and Youtube.com/subway.

Facebook: On the Facebook.com/subway Facebook page, the SUBWAY® Group’s staff posts news and other items of interest to individuals. If you have a Facebook account or 'Like' Facebook.com/subway Facebook page, you can post comments or click on the 'like' option for individual entries. If you comment or click on the 'like' button, personally identifying information will be visible to the SUBWAY® Group’s staff and other Facebook site visitors. The amount of visible personal information will depend on your own Facebook privacy settings. You can completely avoid displaying any personally identifiable information by not creating an account, not posting comments and not clicking on the 'like' options in Facebook. The SUBWAY® Group’s staff does not collect, use or disclose any information about visitors who comment or 'like' the SUBWAY® Group’s Facebook site. Facebook collects and reports on non-personally identifiable information about activities on Facebook pages. This information is password protected and only available to the SUBWAY® Group’s employees, members of the SUBWAY® Communications and Web Teams, and other designated staff who require this information to perform their duties. The Facebook privacy policy is available at: http://www.facebook.com/policy.php.

Twitter: The SUBWAY® Group uses Twitter to send short messages (up to 140 characters) or 'Tweets' to share information about SUBWAY® Restauraunts with visitors and respond to comments and inquiries sent via Twitter to the SUBWAY® Group. While visitors may read the SUBWAY® Group’s Twitter feeds without subscribing to them, visitors who want to subscribe to (or follow) The SUBWAY® Group’s Twitter feeds must create a Twitter account at www.twitter.com. To create an account, you must provide some personal information, such as name, user name, password and email address. Visitors have the option to provide additional personal information including a short biography, location or a picture. Most information you provide for a Twitter account is available to the public, but you can modify how much of your information is visible by changing your privacy settings at the Twitter.com Web site. The SUBWAY® Group’s staff members monitor the number of subscribers and respond to comments and queries via Twitter, but the staff never takes possession of the personal information belonging to Twitter followers. The SUBWAY® Group does not collect, maintain, disclose or share any information about people who follow The SUBWAY® Group on Twitter. The Twitter privacy policy is available at: http://twitter.com/privacy . 

YouTube: The SUBWAY® Group posts videos on YouTube to make them available to all SUBWAY® Group visitors. You do not need to register with either YouTube or Google (YouTube owner) to watch The SUBWAY® Group’s videos. When visitors watch videos, YouTube may record non-personally identifiable information about its site usage, such as channels used, videos watched, and data transfer details to improve its services. If you log on to the YouTube site before watching The SUBWAY® Group’s videos, YouTube may associate information about your site use with your YouTube account. If you log on to YouTube and comment on a SUBWAY® Group’s video, any personal information you included when registering for your account will be visible to visitors who click on the comment. If you do not log in before watching the SUBWAY® Group’s videos posted on YouTube, your site use will not be associated with you or a YouTube account. The YouTube privacy policy is available at: http://www.youtube.com/t/privacy. http://www.youtube.com/t/privacy. 

SUBWAY® Franchisees may sponsor their own Facebook Pages, Twitter Accounts, and Youtube Accounts. The privacy policies for the SUBWAY® Franchisees Social Media pages are located on the individual SUBWAY® Franchisees websites. This privacy policy does not govern the personal information handling policies and procedures of individual SUBWAY® Franchisees Social Media pages and their individual websites.

Under California’s “Shine the Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to that customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. To request the above information, please email the Privacy Officer at privacyofficer@subway.com or write to us at:

DAI Privacy Officer
In Care of
Franchise World Headquarters LLC
325 Bic Drive
Milford, CT 06461
Attention: California Disclosure Information

We will respond to such written requests within 30 days following receipt at the mailing address above. We reserve the right not to respond to requests submitted other than to the address specified above or otherwise exempted by law. Please note that we are required only to respond to each customer once per calendar year.

DAI is in compliance with the U.S. Department of Commerce Safe Harbor requirements regarding the transfer of personal information from the European Economic Area (“EEA”) or Switzerland to the United States. DAI has been Self-Certified under the Safe Harbor privacy frameworks as set forth by the U.S. Department of Commerce, European Commission and Switzerland regarding the collection, storage, use, transfer and other processing of personal data transferred from the European Economic Area or Switzerland to the U.S., in accordance with the EU Directive on Personal Data Protection. The principles of Safe Harbor compliance are:

• Notice - Individuals must be informed that their data is being collected and about how it will be used;
• Choice - Individuals must have the ability to opt out of the collection and forward transfer of the data to third parties;
• Onward Transfer - Transfers of data to third parties may only occur to other organizations that follow adequate data protection principles;
• Security - Reasonable efforts must be made to prevent loss of collected information;
• Data Integrity - Data must be relevant and reliable for the purpose for which it was collected;
• Access - Individuals must be able to access information held about them, and correct or delete it if it is inaccurate;
• Enforcement - There must be effective means of enforcing these rules.

We may transfer the personal information we collect about you to countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Policy. Further information regarding the Safe Harbor principles and certification process can be found at www.export.gov/safeharbor. In addition, the U.S. Department of Commerce maintains a list of all compliant organizations, which can be accessed at http://web.ita.doc.gov/safeharbor/shlist.nsf/webPages/safe+harbor+list.

If you are a resident of the European Economic Area (“EEA”) or Switzerland and have any concerns or complaints, please first address these issues to the Privacy Officer. Doctor’s Associates Inc. is located in the United States, as are the servers that make our websites available. All matters relating to privacy issues and websites are governed by the laws of the United States and the State of Connecticut. If the Privacy Officer does not satisfactorily address a complaint within thirty (30) days, any dispute, controversy or claim shall be settled by an arbitration administered by an arbitration agency, such as the American Arbitration Association (“AAA”). All arbitrations will be conducted in English. Judgment rendered by the arbitrator may be entered in any court having jurisdiction. The costs of the arbitration will be borne equally by the parties. Connecticut, U.S.A. shall be the site of all hearings, and such hearings shall be before a single arbitrator. You may also submit complaints to the Federal Trade Commission at http://www.ftc.gov/ftc/complaint.htm or via telephone at (202)382-4537.

DAI, an affiliate of the SUBWAY® Group, encourages you to view your country’s Privacy Policy at www.subway.com. To view your country’s Privacy Policy please go to www.subway.com. At the top of the page, please click on AROUND THE WORLD, and then click on your country. Go to the very bottom of your country’s page and click PRIVACY POLICY to view your country’s specific Privacy Policy.

DAI will update this Privacy Policy occasionally. When DAI posts changes to this Privacy Policy, we will also revise the "Last Updated" date below on DAI’s Privacy Policy. If there are material changes to this Privacy Policy, DAI will notify you by email, or by means of a notice on our home page. DAI encourages you to review this Privacy Policy periodically to be informed of how DAI is protecting your information and to be aware of any changes to the Privacy Policy. Your continued use of the site after the posting of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. This Privacy Policy is incorporated into any Terms and Conditions governing the various websites and any programs or services operated or managed on or behalf of DAI. Any changes to this Privacy Policy are effective immediately after being posted by DAI.

The Terms and Conditions governing your use of this Website located at: http://www.subway.com/subwayroot/legalDisclaimer.aspx contains important provisions disclaiming and excluding the liability of DAI and the SUBWAY® Group regarding your use of our Website and provisions determining the applicable law and exclusive jurisdiction for the resolution of any disputes regarding your use of this Website. Each of these provisions applies to any disputes that may arise in relation to this privacy policy and the collection, use and disclosure of your personal information, and are of the same force and effect as if they had been reproduced directly in this Privacy Policy.

LAST UPDATED: 03/30/12