Table of Contents
Your privacy is very important to us. This Privacy Statement discloses how Subway Franchisee Advertising Fund Trust, Ltd. ("SFAFT")and its affiliated companies and subsidiaries collects, protects, uses and shares Personal Information gathered about you. Our privacy practices are consistent with:
SThe FAF Group operates as the advertising part of the SUBWAY® Group’s advertising entities, which includes, but is not limited to: 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”.
SFAFT may share information, including Personal Information with its affiliates the SUBWAY® Group, which includes, but is not limited to: 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: Doctor’s Associates Inc. (“DAI”). DAI owns and licenses the SUBWAY® trademark and SUBWAY® Restaurant System to its affiliates, including, but not limited to, 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”) and Subway Systems India Private Limited (“SSIPL”), in order to develop SUBWAY® restaurants worldwide. 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. DAI owns and licenses the SUBWAY® trademark and SUBWAY® Restaurant System to its affiliates in order to develop SUBWAY® restaurants worldwide. FWH, DAI, SIBV, SSA, SFSC, SPCCV, SSB, SSFSA, SSIPL, and PTSSI are collectively referred to herein as the “SUBWAY® Group”.
SRV C.A. may share information, including Personal Information with Subway Real Estate, LLC (“SRE”) which assists franchisees of the SUBWAY® Group in negotiating real estate leases, and administering the leases and lease renewals for all restaurant premises that they sublease to franchisees, as well as its 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.
SFAFT BV 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. SFAFT 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 information may be used, and with whom the information may be shared.
In an effort to comply with the law, and our commitment to protect your Personal Information, we provide the following, which discloses our privacy practices. Please note that this Privacy Statement does not govern the privacy practices and procedures of independently owned and operated SUBWAY® stores. In addition, this Privacy Statement does not govern the Personal Information handling practices and procedures of SFAFT, FWH, DAI or our affiliates within the FAF Group and SUBWAY® Group. To read the full Privacy Statement and to find out more about SFAFT, FWH, and DAI’s privacy practices, please see the SUBWAY® Online Privacy Notice located at: http://www.subway.com/subwayroot/PrivacyNotice.aspx.
This Privacy Statement applies to all information gathered for and on behalf of SFAFT, whether in writing, verbally or electronically, through any website operated by or on behalf of SFAFT, including, but not limited to: www.subway.mobi and www.subwaykids.com, together with any and all future websites (the “Websites”) that are operated by or on behalf of SFAFT. By using the Websites, or participating in any program or service managed by SFAFT, you consent to the data practices described in this Privacy Statement. If you have questions about this Privacy Statement or the protection of your information, please contact SFAFT’s Privacy Officer at email@example.com.
BY SUBMITTING PERSONAL INFORMATION TO SFAFT, AND/OR BY ACCESSING AND USING THE WEBSITE, YOU AGREE TO SFAFT’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 SFAFT’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 SFAFT sharing the Personal Information that you have provided to SFAFT, as described herein. SFAFT 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. SFAFT may also share your Personal Information with companies that provide support services to SFAFT 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, SFAFT does not control these companies nor does SFAFT authorize these companies to use your Personal Information that SFAFT may share with them, for any reason other than the purpose for which SFAFT hired them. You agree that SFAFT 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 SFAFT’s operations and programs.
If SFAFT or a Recipient is required to provide notice of unauthorized access of certain security systems, you agree that SFAFT, or the Recipient, may do so when required or voluntarily by posting notice on the Website or sending notice to any email address SFAFT or the Recipient has for you, in the good faith discretion of SFAFT 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.
We use your Personal Information to facilitate the services you request. We have tailored our Privacy Statement to adequately advise 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.
SFAFT 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. SFAFT 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
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.
SFAFT will not collect customer Personal Information, unless the customer contacts SFAFT directly. In order to adequately address a customer’s concerns, your Personal Information may be shared with our affiliates within the FAF Group, the SUBWAY® Group, SUBWAY® Development Agents (“DA”) and SUBWAY® franchisees. SUBWAY® DA’s are independent contractors of the SUBWAY® Group. SUBWAY® DA’s assist with: franchise sales, site locations, servicing franchisee leasing needs, providing operational assistance, related administrative functions, and training to the franchisees in the DA’s geographical area. Failure to provide necessary information to the SUBWAY® Group, SUBWAY® DA’s, the FAF Group, and/or third party service providers may prevent us from fully addressing a customer’s concerns.
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, the SUBWAY® Group, or our 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., SFAFT does not divulge User ID and Passwords to anyone internally or externally. Please note, when entering a Promotion or Sweepstake SFAFT 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 website or in an e-mail that is used to monitor the behavior of the user visiting the website 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. SFAFT may use your IP address to help diagnose problems with SFAFT’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. SFAFT 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 SFAFT administers, SFAFT will rely upon aggregate information, which is information that does not identify you, such as statistical and navigational information. With this aggregate information, SFAFT may undertake statistical and other summary analyses of the visitors' behaviors and characteristics. Although SFAFT 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 FAF 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 FAF 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/.
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.
This website is not targeted towards children under the age of thirteen (13). We do understand that children may try to contact us 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 SFAFT BV. SFAFT an affiliate of the SUBWAY® Group, whose servers are located in the United States, 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. SFAFT 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 SFAFT with Personal Information without the consent of a parent, we ask the parent of that child to contact the Privacy Officer immediately at: email@example.com. We will use all reasonable efforts to promptly delete the child's 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 SFAFT 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 SFAFT’s privacy practices, you may contact our Privacy Officer:
SFAFT Privacy Officer
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 the SUBWAY® Group may disclose your Personal Information to the SUBWAY® Group’s affiliates including, but not limited to: the FAF Group, SUBWAY® DA’s, and third party service providers as part of the SUBWAY® Group’s consideration to your inquiry and to help them conduct their franchise marketing efforts. Personal Information collected from prospective franchisees may 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. Personal Information on your online form will become part of an application for a franchise that you might later submit. The SUBWAY® Group require its affiliates within the FAF Group, SUBWAY® DA’s, and third party service providers to respect the SUBWAY® Group’s privacy practices and not use your Personal Information for purposes other than to carry out the SUBWAY® Group’s 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, which is based in the United States. Information on this server may be shared with:
SFAFT 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 and SFAFT. 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 SFAFT’s affiliate, the SUBWAY® Group, to disclose 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”.
13. Mobile Information - (Top)
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. SFAFT 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.
SFAFT 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. SFAFT 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 - 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 SFAFT and the user. Standard messaging rates will apply, unless noted otherwise. Under no circumstances will our website, SFAFT, 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 SFAFT 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 SFAFT at the time the message is sent, or by sending a text message that says "STOP", "END", "CANCEL", "REMOVE", "UNSUBSCRIBE" or "QUIT". SFAFT 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 SFAFT. If the user unsubscribes from one or all of SFAFT 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 - SFAFT 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 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.
You may have the opportunity to elect to receive email communications from SFAFT. SFAFT will only email you if you elect to receive them. If you elect to receive email communications, SFAFT 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 SFAFT, you can opt-out by clicking the unsubscribe link at the bottom of any SFAFT email, update the contact preferences for your account, or contact the Privacy Officer at: firstname.lastname@example.org.
SFAFT 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, SFAFT 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 SFAFT in connection with the business of SFAFT, 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 SFAFT 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 SFAFT 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 SFAFT or of any of the business assets or shares of SFAFT or a division thereof, in order for a customer to continue to receive the same products and services from the third party.
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 SFAFT, 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.
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 SFAFT, 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.
Phishing -Identity theft and the practice currently known as “phishing” are of great concern to SFAFT. 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: 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. SFAFT takes all reasonable steps to insure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading. SFAFT 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.
SFAFT may store your Personal Information in our affiliate, the SUBWAY® Groups, databases located in the United States and/or other countries outside of the European Economic Area (“EEA”). Additionally, some of our service providers may be located in the United States or other countries outside of the EEA and will be subject to the laws of the local jurisdiction. As a result, in certain circumstances, the United States and other foreign governments, courts, law enforcement agencies or regulatory agencies may be entitled to access the Personal Information collected and held by SFAFT.
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 us at: email@example.com to update your contact information. To protect your privacy, we will take reasonable steps to help verify your identity before granting access or making changes.
If you have any questions or concerns, please contact SFAFT’s Privacy Officer at:
SFAFT Privacy Officer
The SUBWAY® Group may use a variety of new technologies and Social Media options to communicate and interact with SUBWAY® 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® 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.
Facebook: On the https://www.facebook.com/subway Facebook page, the SUBWAY® Group 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 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 staff does not collect, use or disclose any information about visitors who comment or 'like' the SUBWAY® 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 employees, members of the SUBWAY® Communications and Web Teams, and other designated staff who require this information to perform their duties. The Facebook Privacy Statement is available at: http://www.facebook.com/about/privacy/.
Twitter: The SUBWAY® Group uses Twitter to send short messages (up to 140 characters) or 'Tweets' to share information about SUBWAY® Restaurants with visitors and respond to comments and inquiries sent via our Twitter account: @SUBWAY. While visitors may read the SUBWAY® Group Twitter feeds without subscribing to them, visitors who want to subscribe to (or follow) the SUBWAY® Group 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 Personal Information is visible by changing your privacy settings at the Twitter.com website. The SUBWAY® Group 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 Personal Information about people who follow SUBWAY® on Twitter. The Twitter Privacy Statement is available at: http://twitter.com/privacy.
YouTube: The SUBWAY® Group posts videos on YouTube to make them available to all SUBWAY® visitors. You do not need to register with either YouTube or Google (YouTube owner) to watch SUBWAY® 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 SUBWAY® videos, YouTube may associate information about your site use with your YouTube account. If you log on to YouTube and comment on any SUBWAY® videos, 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 SUBWAY® videos posted on YouTube, your site use will not be associated with you or a YouTube account. The YouTube Privacy Statement is available at: http://www.youtube.com/t/privacy.
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.
SFAFT 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. SFAFT 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:
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 Statement.
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.
As part of SFAFT’s participation in the Safe Harbor Frameworks, SFAFT has agreed to dispute resolution by the EU and/or Swiss Data Protection Authorities (“EU/Swiss DPA’s”) to serve as an independent recourse mechanism (“IRM”) for dispute resolution arising from collection, use, and retention of Personal Information transferred from EU member countries or Switzerland to SFAFT. In choosing the EU/Swiss DPA’s to serve as an IRM for dispute resolution, SFAFT has paid the necessary annual fee to the United States Council for International Business (“USCIB”) who acts as a trusted third party on behalf of the EU/Swiss DPA’s with regards to disputes relating to SFAFT’s compliance with the Safe Harbor Frameworks. If you have any questions, concerns, or complaints regarding our compliance with the Safe Harbor Frameworks, please contact SFAFT’s Privacy Officer at: firstname.lastname@example.org. You may also contact c the Federal Trade Commission website located at: http://export.gov/safeharbor/eg_main_018273.asp or by email at: Safe Harbor Team Inbox E-mail: email@example.com
SFAFT uses a self-assessment approach to assure compliance with this Privacy Statement and periodically verifies that this Privacy Statement is accurate, prominently displayed, accessible, 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 SFAFT’s compliance with the Safe Harbor Frameworks, please contact our designated Privacy Officer at: firstname.lastname@example.org, who oversees SFAFT’s compliance with Data Protection Laws, which may be required by various state, federal, and international laws regarding any and all websites operated by and on behalf of SFAFT. If a complaint or dispute cannot be resolved through our internal process, SFAFT agrees to dispute resolution by the EU and/or Swiss Data Protection Authorities to serve as an independent recourse mechanism (IRM) for dispute resolution.
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.
SFAFT will update this Privacy Statement occasionally. When SFAFT posts changes to this Privacy Statement, we will also revise the "LAST REVIEWED" date on this Privacy Statement. If there are material changes to this Privacy Statement, SFAFT will notify you by email, or by means of a notice on our home page. SFAFT encourages you to review this Privacy Statement periodically to be informed of how SFAFT is protecting your Personal Information and to be aware of any changes to our Privacy Statement. Your continued use of the website after the posting of any amended Privacy Statement shall constitute your agreement to be bound by any such changes. This Privacy Statement is incorporated into any Terms and Conditions governing the various websites and any programs or services operated or managed on or behalf of SFAFT. Any changes to this Privacy Statement are effective immediately after being posted by SFAFT.
The Terms and Conditions located at: 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: 11/12/13
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