Your privacy is very important to us. This Privacy Statement discloses how Franchise World Headquarters, LLC (“FWH”) collects, protects, uses, and shares Personal Information gathered about you. Our privacy practices are consistent with:
FWH operates as a service-oriented company for and on behalf of the SUBWAY® System by providing core business related services such as, but not limited to: sales, research and development, marketing franchises, franchisee training, retail technology, POS system support, store design, legal and accounting services, to the SUBWAY® franchising entities. FWH is licensed to use the SUBWAY® trademark. Doctor’s Associates Inc. (“DAI”), owns the trade name and service mark SUBWAY®, the recipes, formulas, food preparation procedures, business methods, business forms, and business policies. DAI is the franchisor of the SUBWAY® system for the United States, does business as "SUBWAY" and licenses the SUBWAY® trademark and SUBWAY® Restaurant System to its affiliates in order to develop SUBWAY® restaurants worldwide.
FWH and DAI’s affiliates include, but are not limited to: SUBWAY® system for Australia, Subway International B.V. (“SIBV”) the franchisor of the SUBWAY® system for Europe (and the rest of the world, outside of the United States, Australia, Canada, Colombia, Brazil, South Africa, and India), 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”), and Subway Systems India Private Limited (“SSIPL”). PT Subway Systems Indonesia (“PTSSI”) is a service company which provides business related services exclusively to Indonesia’s SUBWAY® franchisees, for and on behalf of SIBV, the franchisor for Indonesia. FWH, DAI, SIBV, SSA, SFSC, SPCCV, SSB, SSFSA, SSIPL, and PTSSI are collectively referred to herein as the “SUBWAY® Group”.
FWH may share information, including Personal Information with its affiliate, Subway Real Estate, LLC (“SRE”) which assists franchisees of the SUBWAY® Group in negotiating real estate leases, administering the leases and lease renewals for all restaurant premises that they sublease to franchisees, as well as SRE’s leasing affiliates worldwide, which includes, but is not limited to: Subway Real Estate Corp. (“SREC”), Subway Realty of the Netherlands B.V., Subway Realty Limited, (“SRL”), Subway of Ireland Limited, Subway Partners Realty N.V., Subway Realty de Venezuela, C.A., Subway Real Estate Limited, Subway Realty de Mexico, S.A. de C.V., Subway Real Estate of France S.A.R.L., Subway Vermietungs –und Servicegesellschaft mbH, Subway Realty of Spain, S.L., Subway Realty of Italy S.r.l., Subway Subs of Sweden AB, Subway International B.V. – Taiwan Branch, and Subway Realty do Brasil, Ltda.
FWH may share information, including Personal Information, with 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. Subway Franchisee Canadian Advertising Trust (“SFCAT”) with a business address at Monarch Registry 11210-107 Ave. NW, Main Floor, Edmonton, 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, SFAFC, and SFCAT, are collectively referred to herein as the “FAF Group”.
FWH may share information, including Personal Information, with our third party service providers including, but not limited to: Independent Purchasing Cooperative, Inc. (“IPC”), and its wholly owned subsidiary Value Pay Services LLC (“VPS”), European Independent Purchasing Cooperative (“EIPC”), Latin America and Caribbean Independent Purchasing Cooperative (“LACIPC”), Independent Purchasing Cooperative (Australasia) Limited (“IPCA”) and Middle East Independent Purchasing Cooperative (“MEIPC”), all of which are member owned and operated entities, composed of all SUBWAY® Franchisees located in the geographical areas as follows: United States of America and its territories and Canada (IPC), European Union (EIPC), Latin America and Caribbean (LACIPC), Australia (IPCA) and Middle East (MEIPC). EIPC, LACIPC, IPCA and MEIPC, are collectively referred to herein as the “Co-op 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. FWH respects the privacy of our SUBWAY® customers, our employees, job applicants, 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 Statement will assist you to understand what types of Personal Information we may collect, how that Personal Information may be used, and with whom the Personal Information may be shared with. This Privacy Statement explains FWH’s privacy practices and procedures regarding the Personal Information collected online from users of the SUBWAY® Restaurant Systems website located at: www.subway.com. DAI is the franchisor for the United States. To read the full Privacy Statement for DAI, and find out more about DAI’s privacy practices and procedures, please see DAI’s Privacy Statement located at: http://www.subway.com/subwayroot/PrivacyPolicy-DAI.aspx.
In an effort to comply with the law, and our commitment to protect your Personal Information, we provide the following, which discloses FWH’s privacy practices and procedures. Please note this Privacy Statement does not govern the privacy practices and procedures of independently owned and operated SUBWAY® restaurants. Nor does this Privacy Statement govern the Personal Information handling practices and and procedures of its affiliates, DAI, the SUBWAY® Group SFAFT, and the FAF Group. FWH encourages you to review its affiliates, DAI and SFAFT’s, respective Privacy Statements which discloses each company’s privacy practices and procedures. FWH encourages you to review its affiliates, DAI and SFAFT’s, respective Privacy Statements which discloses each company’s privacy practices and procedures. For your convenience, FWH has provided a link to DAI and SFAFT’s individual Privacy Statements below:
This Privacy Statement applies to all information gathered for and on behalf of FWH, whether in writing, verbally or electronically, through any website operated by or on behalf of FWH, including, but not limited to: www.subway.com, together with any and all future websites (the “Websites”) operated by or on behalf of FWH. By using the Websites, or participating in any program or service managed by FWH, you consent to the data practices described in this Privacy Statement.
BY SUBMITTING PERSONAL INFORMATION TO FWH, AND/OR BY ACCESSING AND USING THE WEBSITE, YOU AGREE TO FWH’S COLLECTION, USE, AND DISCLOSURE OF SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY STATEMENT AND THE TERMS AND CONDITIONS AS PERMITTED OR REQUIRED BY LAW.
If you have questions about this Privacy Statement or the protection of your Personal Information, please contact FWH’s Privacy Officer at firstname.lastname@example.org.
In addition to consenting to the website Privacy Statement, Terms and Conditions, as well as any relevant supplemental policies, you expressly consent to FWH sharing the Personal Information that you have provided to FWH, as described herein. FWH may share Personal Information with its affiliates and/or third-party service providers, including, but not limited to: the SUBWAY® Group, the FAF Group, the Co-op Group, and VPS. FWH may also share your Personal Information with companies that provide support services to FWH, such as, but not limited to: credit card processors, mailing houses, web hosts, technical support providers, fulfillment centers, enforcing and/or investigating business operations or transactions, because these companies may need information about you in order to perform their various functions. Please note, FWH does not control these companies nor does FWH authorize these companies to use your Personal Information that FWH may share with them, for any reason other than the purpose for which FWH hired them. You agree that FWH and those with whom it shares your Personal Information (the “Recipients”), may disclose and transfer your Personal Information worldwide, including in and outside of the United States and its territories, the European Economic Area, Canada and its provinces, and other geographical areas serviced by the SUBWAY® Group, for any purpose relating to FWH’s operations and programs.
4. Consent to Electronic Notice if there is a Security Breach - (Top)
If FWH or a Recipient is required to provide notice of unauthorized access of certain security systems, you agree that FWH, or the Recipient, may do so when required or voluntarily by posting notice on the Website or sending notice to any email address FWH or the Recipient has for you, in the good faith discretion of FWH 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. Our Use of Your Personal Information and Type of Personal Information We May Collect - (Top)
We use your Personal Information to facilitate the services you request. We have tailored our Privacy Statement to adequately advise you of the use of your Personal Information.
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 (full name or first initial and last name), maiden name, nickname, email address, home address, home postal code, home telephone number, mobile telephone number, date of birth, Social Security Number and/or Identification Number, photographic images (especially of face or other identifying characteristics, or other identifying characteristics such as eye, skin, and hair color, facial features, and personal marks such as tattoos, birthmarks, moles and scars) and video or voice recording, financial information, and employment related information, such as: Personal Information that may be found on resumes, applications, background verification information, or in employment references.
FWH 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. FWH 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.
WE DO NOT COLLECT SENSITIVE DATA
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.
WE DO NOT COLLECT SENSITIVE DATA
Sensitive Information 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.
FWH will not collect customer Personal Information, unless the customer contacts FWH directly. In order to adequately address a customer’s concern, your Personal Information may be shared with our affiliates within the SUBWAY® Group, third-party service providers, the appropriate SUBWAY® Group’s area Development Agent (“DA”), and franchisees.
Holders of SUBWAY® Loyalty Cards and SUBWAY® Gift Cards (collectively the “SUBWAY® Card”) may voluntarily register their cards through www.mysubwaycard.com. Our third party service provider collects Personal Information on a voluntary basis. This information is used as part of the Lost/Stolen Card Program. If you do not wish to receive promotional materials with your use of the SUBWAY® Card you may update your preferences at www.mysubwaycard.com. YOU MUST BE thirteen (13) YEARS OLD OR OLDER TO REGISTER A SUBWAY® CARD.
For Instance, you may choose to communicate with us in some of the following ways:
Upon entering your Personal Information regarding any of the above, other members of the SUBWAY® Group, and FWH’s third-party service providers, are contractually obligated to provide the same level of guarantees regarding the confidentiality and security of your Personal Information, as well as, to allow for oversight, monitoring, and auditing of the services being provided. FWH does not divulge User ID and Passwords to anyone internally or externally. Please note, when entering a Promotion or Sweepstake FWH urges you to review the Promotion or Sweepstake Official Rules and Privacy Statement specific to that Promotion or Sweepstakes.
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. A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer's hard disk so that the website can remember who you are. A cookie will typically contain the name of the domain from which the cookie has come, the 'lifetime' of the cookie, and a value, usually a randomly generated unique number. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site and services.
A few important things you should know about cookies are that:
Disabling/enabling cookies - You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our site if cookies are disabled.
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.
Used in combination with cookies, a Web beacon is an often-transparent graphic image, usually no larger than 1 pixel x 1 pixel, which is placed on a Web site or in an e-mail that is used to monitor the behavior of the user visiting the Web site or sending the e-mail. When the HTML code for the Web beacon points to a site to retrieve the image, at the same time it can pass along information such as the IP address of the computer that retrieved the image, the time the Web beacon was viewed and for how long, the type of browser that retrieved the image and previously set cookie values.
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. FWH may use your IP address to help diagnose problems with FWH’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. FWH 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 FWH administers, FWH will rely upon aggregate information, which is information that does not identify you, such as statistical and navigational information. With this aggregate information, FWH may undertake statistical and other summary analyses of the visitors' behaviors and characteristics. Although FWH 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.
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, please visit http://www.aboutads.info/choices/.
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 Statement 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.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the DAA opt-out link above. However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. To find out more about "Do Not Track," you may wish to visit http://www.allaboutdnt.com.
This website is not targeted towards children under the age of thirteen (13). We do understand that children may try to contact FWH and in so doing may voluntarily provide Personal Information on this website. If you are a child under the age of thirteen (13) PLEASE, DO NOT submit any Personal Information about yourself on this website WITHOUT GETTING PERMISSION FROM YOUR PARENT(S) OR GUARDIAN(S) FIRST.
Children’s privacy is very important FWH. FWH’s servers are located in the United States. FWH adheres to the United States Children's Online Privacy Protection Act (“COPPA”). The Federal Trade Commission (“FTC”) has the authority to issue regulations and enforce COPPA, which applies to websites and online services operated for commercial purposes that are directed at, and are collecting Personal Information from children under thirteen (13) years of age. COPPA explains what a website operator must include in their Privacy Statement, what responsibilities a website operator has to protect children's privacy and safety online, including restrictions on marketing to those under thirteen (13) years of age, it also requires that we inform parents and/or legal guardians how we collect, use, and disclose Personal Information from children under thirteen (13) years of age, as well as, how to obtain verifiable consent from a parent in order for children to use certain features of on a website. FWH will not knowingly allow anyone under thirteen (13) years of age to provide us with any Personal Information about themselves (such as their names, e-mail address, and phone number) over the Internet. If a child has provided FWH with Personal Information without the consent of a parent, we ask the parent of that child to contact FWH’s Privacy Officer immediately at: email@example.com. We will use all reasonable efforts to promptly delete the child's Personal Information from our servers. Please note, that when we use the term "parent", we mean to include legal guardians.
In the United States, websites that are collecting Personal Information from children under the age of thirteen (13) are required to comply with Federal Trade Commission (“FTC”) Children's Online Privacy Protection Act (“COPPA”). COPPA requires that FWH inform parents and legal guardians about how we collect, use, and disclose Personal Information from children under thirteen (13) years of age; and that we obtain the consent of parents and guardians in order for children under thirteen (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 Personal Information. However, to enable their participation in certain interactive features, we may ask children to provide us with Personal 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.
Sometimes, we use third party service providers to help us conduct contests or sweepstakes, send prizes to winners, or provide customer service related to activities on the website. These third party service providers are contractually obligated to adhere to this Privacy Statement. As such these third party service providers are required to keep Personal Information confidential and to use it only for the specific services they are performing on our behalf.
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 Personal Information that we have collected online from your child, have the Personal Information deleted, and/or request that there be no further collection or use of your child's Personal Information, or if you have questions about FWH’s privacy practices, you may contact our Privacy Officer:
FWH Privacy Officer
Personal Information collected from employees and applicants is limited to administration of Human Resources programs and functions, which include, but are not limited to: job applications and hiring programs, compensation and benefit programs, performance appraisals, training, access to FWH and its affiliates facilities and computer networks, employee profiles, internal intranet employee directories, Human Resource recordkeeping, and other employment related purposes.
It is the policy of FWH to keep all past and present employee information private from disclosure to third parties, accept for where there are certain business related exceptions, such as:
Please note that this Privacy Statement does not apply to SUBWAY® restaurant employment applications submitted through the website, which may be shared with independently-owned and operated franchises who are seeking employees in their market area.
Prospective employers, state agencies, financial institutions, and residential property managers routinely contact FWH requesting information on a former or current employee's work history and salary. All such requests of this type shall be referred to and completed on a confidential basis by the Human Resources Department or Payroll Department.
For written verification of employment requests, information will be provided on the form only when it is accompanied by an employee's signed authorization to release information. The form will be returned directly to the requesting party and filed as part of the Human Resources or Payroll Department’s confidential records.
FWH is compliant with federal HIPAA regulations and only utilizes information related to the company sponsored healthcare plan on a "need to know" basis for administration of the healthcare plan.
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, the FAF Group, SUBWAY® DA’s, and third party service providers as part of their consideration to your inquiry and to help them conduct their franchise marketing efforts. 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. Information on your online form will become part of an application for a franchise that you might later submit. We require our affiliates within the SUBWAY® Group and SUBWAY® DA’s to respect FWH’s privacy practices and not use your Personal Information for purposes other than to carry out our instructions.
Any potential franchisee Personal Information sent to www.subway.com is stored on a server located in the United States. The server is managed by FWH, based in the United States. Information on this server may be shared with:
FWH and its affiliates will retain your Personal Information only for as long as necessary to fulfil the purpose(s) for which it was collected and to comply with applicable laws. Your consent to such purpose(s) remains valid after termination of our relationship with you.
Website - www.subway.com is hosted on a web server located in the United States of America. The content of www.subway.com, including updates to the consumer content, is managed by FWH. When you click on the links for Contact Us, Request a Brochure, Own a Franchise, and Submit a Site, where you fill out and submit a form which goes directly to SUBWAY® Headquarters database, located in Milford, Connecticut, USA. The domain name subway.com is owned by Doctor's Associates Inc.
Finally, upon becoming a SUBWAY® franchisee you consent to FWH 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 FWH’s Privacy Officer at: firstname.lastname@example.org, in writing, either by email or regular mail, 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). Please see the section provided below entitled “FWH Privacy Officer Contact Information” to find the physical address for FWH’s Privacy Officer.
By applying to become a SUBWAY® DA via www.subway.com an 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® DA. Personal Information is collected to assist FWH and its affiliates within the SUBWAY® Group in selecting DA 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. Once a DA candidate becomes a DA, they may then reference themselves by their DA Number. Failure to provide necessary information may negatively impact your ability to become a DA.
Finally, as a DA 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: three (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.
You may submit Personal Information via your cell phone, smartphone, and tablet. If you use any location-enabled products, you may be sending us location information. FWH 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.
FWH uses a variety of new technologies and social media options to communicate and interact with consumers. These websites and mobile applications include popular social networking and media sites, such as, Twitter and Facebook. If you post updates to or receive updates from www.twitter.com, www.facebook.com, and other social networking websites, during the Promotion Period via SMS from your wireless phone, your wireless-service provider may charge you for each text message you send and receive. You must consult your wireless service provider regarding its pricing plans, as rates may vary. Use of third party social networking websites, such as, Twitter and Facebook, are governed by the privacy practices of those websites. FWH does not capture or store your login information or any other personally identifiable information for Twitter, Facebook, and other social networks, however, session information or cookies may be stored on your wireless phone, by their websites.
Mobile Information We Collect
Mobile Information sharing
If you participate in any advertising or marketing promotions the information that you provide will be handled in accordance with the Privacy Statement specific to said promotion which cannot and does not apply to this Privacy Statement.
Wireless Promotional Opportunities - FWH may provide users and viewers with the opportunity to register for special promotions via mobile text messaging and other wireless devices. Users are required to provide their consent to receive such information from FWH, either by registering on our website or via your wireless device. Promotional opportunities may be provided by the SUBWAY® Group, the FAF Group, and/or FWH’s third party service providers. The Information requested as part of the online registration process may include, but is not limited to, a user's telephone number or a wireless email address (only if specifically requested), and your mobile carrier's name. Please note that most wireless transmissions are not secured and there is a greater risk of an unknown third party's interception of messages or a user's Personal Information when using a wireless communications device.
Users that register for wireless services acknowledge, understand and agree that they may be charged by the user's wireless carrier for all messages between FWH and the user. Standard messaging rates will apply, unless noted otherwise. Under no circumstances will our website, FWH, the SUBWAY® Group, or its affiliates be held responsible for any wireless email or text messaging charges incurred by a user or by a person that has access to a user's wireless device, telephone number, or email address.
Termination of Wireless Services by User - Users may revoke their consent to receive mobile messages for marketing promotions from FWH and/or its affiliates by the following procedure:
A user may cancel one or more services via his/her wireless device at any time by using the unsubscribe mechanism provided by FWH at the time the message is sent, or by sending a text message that says "STOP", "END", "CANCEL", "REMOVE", "UNSUBSCRIBE" or "QUIT". FWH will terminate the user's registration for the most recent wireless service sent to the user. Any of these words followed by the word "ALL" in the user's termination request will cancel all of the user's registered wireless services with FWH. If the user unsubscribes from one or all of FWH service(s) via his or her wireless device, the service(s) will be terminated immediately and will cancel the user's previous opt-in.
Use of Information - FWH will not use a wireless telephone number, wireless or conventional internet email address, or other Information submitted for its wireless marketing promotions for any other purpose than to provide the services requested, unless we provide to you advance notice of any other use. We will not share any Personal Information with third party service providers unless you opt-in for such disclosure.
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 FWH web page or promotion. FWH 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 communications from FWH. FWH will only email you if you elect to receive them. If you elect to receive email 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, or contact FWH’s Privacy Officer at email@example.com.
FWH does not sell Personal Information to third parties. We may share Personal Information with our service providers, consultants and affiliates for our internal business purposes. Except as described in this Privacy Statement, FWH 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. We may share your Personal Information with agents, affiliates or service providers who act for or on behalf of FWH in connection with the business of FWH, or for further processing the data in accordance with the purpose(s) for which the data was originally collected, e.g., third party maintenance of secure listing databases. We require our agents, affiliates and service providers to agree in writing to maintain the confidentiality and security of Personal Information they maintain on behalf of FWH and not to use it for any purpose other than the purpose for which we retained them. We also require any third parties we retain to protect Personal Information disclosed by us in accordance with all applicable privacy requirements and the general privacy principles described in this Privacy Statement.
The Personal Information you provide FWH is considered a company asset and may be disclosed and/or transferred 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 FWH or of any of the business assets or shares of FWH or a division thereof, in order for a customer to continue to receive the same products and services from the third party.
Phishing- Identity theft and the practice currently known as “phishing” are of great concern to FWH. 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.
Although we make every effort to preserve user privacy, we reserve the right to disclose Personal Information to a third party in certain limited circumstances, specifically: to comply with a law, regulation, search warrant, subpoena, judicial proceeding, a court order, or as otherwise may be required by law, to enforce our policies or contracts, to collect amounts owed to us, to protect users of our sites from fraudulent or abusive use, during emergencies when safety is at risk, as determined by FWH, or otherwise where necessary for the establishment, exercise or defense of legal claims. In addition, from time to time, server logs may be reviewed for security purposes; for example, to detect unauthorized activity on the web site. In such cases, server log data, containing IP addresses, would be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities. As described above, FWH, its affiliates within the SUBWAY® Group, third party service providers, and SUBWAY® DA’s 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® DA’s and other service providers are prohibited from using Personal Information for any purpose other than to provide assistance to FWH and its affiliates within the SUBWAY® Group. SUBWAY® DA’s are required to protect Personal Information disclosed by us and to comply with the general privacy principles described in this Privacy Statement.
We endeavor to protect your Personal Information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our control. 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 Statement and all applicable laws and regulations.
Currently, our website utilizes a variety of different security measures designed to protect Personal Information by users both inside and outside FWH, 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 Personal 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.
Phishing- Identity theft and the practice currently known as “phishing” are of great concern to FWH. 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 at: http://www.consumer.ftc.gov/articles/0003-phishing.
All reasonable steps are taken to safeguard your Personal Information against loss, unauthorized access, use, modification, disclosure, or any other misuse. FWH takes all reasonable steps to insure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading. FWH 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. Your consent to such purpose(s) remains valid after termination of our relationship with you.
FWH may store your Personal Information in its databases located outside of the United States. Additionally, some of our service providers may be located in the United States and its territories, Canada and its provinces, the European Economic Area (“EEA”), or other countries outside of the United States and may be subject to the laws of the local jurisdiction. As a result, in certain circumstances, the United States and its territories, Canada and its provinces, the EEA, and other foreign governments, courts, law enforcement agencies or regulatory agencies may be entitled to access the Personal Information collected and held by FWH.
You may contact the Privacy Officer to access, correct or delete your Personal Information. If necessary, the Privacy Officer will contact another individual to assist in completing your requested task. We want to be sure that we keep only the most accurate and up-to-date Personal Information in our records. You can email FWH’s Privacy Officer at: firstname.lastname@example.org, to update your contact information. To protect your privacy, we will take all reasonable steps to help verify your identity before granting access or making any changes.
If you have any questions or concerns, please contact FWH’s Privacy Officer at:
FWH and the SUBWAY® Group, use 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 SUBWAY® Group 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 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.
SUBWAY® Franchisees may have the opportunity to sponsor their own Facebook Pages, Twitter Accounts, and Youtube Accounts. Please note, the Privacy Policies of the individual SUBWAY® Franchisees social media pages are located on the individual SUBWAY® Franchisees websites. This Privacy Statement does not govern the Personal Information handling practices and procedures of individual SUBWAY® Franchisees social media pages and their individual websites.
A California resident who has provided Personal Information to a business with whom he/she has established a business relationship for personal, family, or household purposes ("California customer") is entitled to request information about whether the business has disclosed Personal Information to any third parties for the third parties' direct marketing purposes. In general, if the business has made such a disclosure of Personal Information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom Personal Information was disclosed in the preceding calendar year, as well as a list of the categories of Personal Information that were disclosed. However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its Privacy Statement) a policy of not disclosing customer's Personal Information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this policy. Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of Personal Information and providing a cost free means to exercise that right.
FWH, 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. FWH has been Self-Certified under the Safe Harbor privacy frameworks as set forth by the U.S. Department of Commerce, European Commission and Federal Data Protection and Information Commissioner of 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 Directive 95/46/EC of the European Parliament, and the Swiss Federal Act on Data Protection (FADP) effective July 1993, modified January 2008. Organizations that Self-Certify under Safe Harbor must comply with the U.S. – EU and the U.S. - Swiss “Safe Harbor” Frameworks Privacy Principles which are:
Further information regarding the “Safe Harbor” Frameworks privacy principles and certification process can be found at: www.export.gov/safeharbor.
In addition, the U.S. Department of Commerce maintains lists of compliant organizations (i.e., the U.S.-EU Safe Harbor List and the U.S.-Swiss Safe Harbor List), which can be accessed at: http://safeharbor.export.gov/list.aspx and https://safeharbor.export.gov/swisslist.aspx.
FWH uses a self-assessment approach to assure compliance with this Privacy Statement and periodically verifies that this Privacy Statement is accurate, easily accessible, prominently displayed, abides by, and contains the information intended to be covered by the Safe Harbor Frameworks, as stated above.
If you are a resident of the European Economic Area (“EEA”) or Switzerland and have any questions, concerns, or complaints, regarding FWH’s use or disclosure of your Personal Information, and compliance with the Safe Harbor Frameworks, please contact FWH’s designated Privacy Officer at: email@example.com. FWH’s Privacy Officer will investigate and attempt to resolve any complaints or disputes regarding the use and disclosure of your Personal Information, in compliance with any applicable Data Protection Laws, which may be required by various local, state, federal, or international laws, regarding any and all websites operated by and on behalf of FWH.
If a complaint or dispute cannot be resolved through FWH’s internal process, FWH has agreed to participate in the dispute resolution procedures established by the EU Data Protection Authorities (DPAs) to resolve disputes pursuant to the U.S. – EU Safe Harbor Privacy Principles in respect to Personal Information received from the EEA. FWH has also agreed to cooperate and comply with any advice given by the Information Commissioner of Switzerland in the investigation and resolution of complaints brought under the U.S. – Swiss Safe Harbor Privacy Principles. The EU DPAs’ panel may be contacted at:
firstname.lastname@example.org and the EU DPAs’ may be contacted directly via the information provided at: http://ec.europa.eu/justice/data-protection/bodies/authorities/eu/index_en.htm. The contact information for the Swiss FDPIC can be found at: http://www.edoeb.admin.ch/kontakt/index.html?lang=en.
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 FWH’s Privacy Officer, as provided in the above section entitled “FWH Privacy Officer Contact Information”.
FWH encourages you to view your country’s Privacy Statement at www.subway.com. To view your country’s Privacy Statement please go to: http://www.subway.com/subwayroot/exploreourworld.aspx. At the top of the page, please click on CHANGE, which brings you the EXPLORE OUR WORLD page. To choose your Country click on the Country name, then go to the very bottom of the Country’s page and click the PRIVACY STATEMENT link to view the website Privacy Statement specific to your Country.http://www.subway.com/subwayroot/legalDisclaimer.aspx, govern your use of the SUBWAY® Groups website: www.subway.com. The provisions therein apply to any disputes that may arise in relation to this Privacy Statement 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 Statement.
LAST UPDATED: 04/02/14
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