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Your
privacy is very important to us. This
Privacy Policy discloses how Doctor’s Associates Inc. (“DAI”) and its
affiliates collect, protect, use and share personal information gathered about
you, in conformance with the applicable law. All personal information is collected in a fair and
non-intrusive manner, with your voluntary consent. Personal Information is not
accessible to anyone outside the specific function for which it is collected. DAI respects the privacy of
employees and job applicants, franchisees, development agents, Subway®
customers and other visitors to our websites who may choose to provide personal
information. We recognize the need for appropriate protection and management
of personal information that you provide to us. This Privacy Policy will
assist you to understand what types of information we may collect, how that
information may be used, and with whom the information may be shared.
In
an effort to comply with the law, and our commitment to protect your personal information,
we provide the following, which discloses our policies. Please note that this
Privacy Policy does not govern the privacy policies and procedures of DAI’s
independently owned and operated SUBWAY® stores.
What type of information do we collect?
Personal
Information is 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 an
identification number 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: identifying information such
as name, home address, home telephone number, e-mail address, Social Security
number, financial information and employment-related information such as may be
found on resumes, applications, background verification information, or in
employment references.
DAI
takes measures to maintain the confidentiality of your Social Security Number,
to protect your Social Security Number from unlawful disclosure, and to limit
access to your Social Security Number. DAI will not make your Social Security Number
available to the general public, print your Social Secuity Number on any card,
require you to provide your Social Security Number to access any products or
services, transmit your Social Security Number over the Internet unless the
connection is secure or your Social Security Number has been encrypted, or
require the transmittal of your Social Security Number to access our Website
without requiring additional authentication.
We
will not collect Sensitive Personal Information, except to comply with
Affirmative Action data requirements. Sensitive Personal Information can
include but is not limited to: information pertaining to gender, disabilities
and veteran status.
Cookies – Internet Users
In
addition to Personal Information, we use data collection devices such as "cookies"
on certain web pages to help analyze our web page flow and measure promotional
effectiveness. Cookies are pieces of information a website sends to an
individual’s hard drive while they are viewing the website. Cookies allow the
website to remember important information that will make your visit to the site
more useful. We use cookies to help improve your future visits. If you do not
wish to receive a cookie or if you wish to set your browser to warn you each
time a cookie is being sent, or if you wish to turn off all cookies, use the
options on your browser to assist you. The “Help” option on your browser may
assist you in changing your cookie preferences. Please note that by turning
cookies off, you will not have access to many features available on our
website.
Children and Data Collection
We
care about the safety of children. We will not knowingly allow anyone under 13
to provide us any personally identifying information. Children under 13 years
of age are required to obtain the express permission of a parent or guardian
before submitting any Personal Information about themselves (such as their
names, e-mail addresses, and phone numbers) over the Internet.
Our Use of Your Information
We
use your Personal Information to facilitate the services you request. We have
tailored our Privacy Policy to adequately inform you of the use of your
Personal Information.
Collection and Use of Employee Personal Information
DAI
also collects Personal Information from its employees and applicants (human
resource data) in connection with administration of its Human Resources
programs and functions. These programs and functions include, but are not
limited to: job applications and hiring programs, compensation and benefit
programs, performance appraisals, training, access to DAI facilities and
computer networks, employee profiles, internal intranet employee directories,
Human Resource recordkeeping, Affirmative Action data, and other employment
related purposes.
It is the policy of DAI to keep all past and present employee
information private from disclosure to third parties. There are certain
business related exceptions and they are:
- To comply with county,
state or federal agency requests;
- Inquiries from third
parties with a signed authorization from the employee to release the
information, except in situations where limited verbal verifications are
acceptable (see below);
- Third parties with
which DAI has contractual agreements to assist in administration of company
sponsored benefits.
Verifications of Employment
Prospective employers, state agencies, financial
institutions, and residential property managers routinely contact DAI
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.
Medical Information
DAI
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.
Collection and Use of Customer Information
DAI
will not collect customer Personal Information, unless the customer contacts DAI
directly. In order to adequately address a customer’s concern, their Personal
Information may be shared with the area Development Agent and franchisee.
Development Agents assist with franchise sales, site location, training, and
provide operational assistance to franchisees. Failure to provide necessary
information may prevent DAI from fully addressing any customer concerns.
If
you are a participant in the Online SUBWAY® Store, we ask for contact
information, name, shipping address, phone number, and e-mail address. In the
future, we may use this information to contact you regarding products or
promotions, as well as other products and services, which may be of interest to
you. At any time you may “opt out” of future contacts by un-subscribing from
our database or contacting the Privacy Officer.
A
customer participating in Subway Express™ through the
www.subway.com website will be asked to provide
Personal Information. Our third party service provider collects and processes
customer information to expedite orders placed on Subway Express™. The Personal
Information collected shall include, but will not be limited to: name, e-mail
address, and telephone number. Our third party service provider forwards this
information to franchisees in order to fulfill the services offered through
Subway Express™.
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. Information you may be asked to provide could include but is not limited
to: date of birth, card number, and e-mail address. Your purchase history may
also be linked to this information. This information is used as part of the
Lost/Stolen Card Program and to provide you with targeted offers from us or
from selected third parties, i.e. suppliers of products offered through the
SUBWAY® system. 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.
Information is also collected in aggregate that is not considered Personal
Information, concerning the food items purchased and the demographics of the
purchasers. This information may be shared with DAI and its affiliates to
improve our product marketing and advertising. YOU MUST BE 13 YEARS OLD OR
OLDER TO REGISTER A SUBWAY® CARD.
Collection and Use of Franchisee and Prospective Franchisee Information
By
applying to become a SUBWAY® franchisee, a prospective franchisee consents to
the collection, use, and disclosure of Personal Information in accordance with
the following terms and conditions. We collect and use Personal Information in
order to assist a prospective franchisee in applying to become a SUBWAY®
restaurant franchisee and to assist DAI in selecting franchisee candidates.
Personal
Information collected from prospective franchisees include, but is not limited
to: name, address, telephone number, facsimile number, email address, date of
birth, citizenship, educational background, criminal background, bank account
information for Electronic Funds Transfer, financial statement, litigation
history, and taxpayer identification number. Failure to provide requested
Personal Information may negatively impact a prospective franchisee’s ability
to become a franchisee. Once a prospective franchisee becomes a franchisee,
they may then reference themselves by their Franchise Agreement Number. In
order to better service franchisees, a franchisee’s Personal Information may be
shared between DAI and its affiliates, pursuant to the service contracts
between them.
In
order to effectively implement the SUBWAY® Gift Card Program, and to provide purchasing
services to members, a franchisee’s Personal Information
may be shared with an independent purchasing cooperative or other independent
third party. The Personal Information shared with the independent purchasing
cooperative shall include, but will not be limited to: name, address, and bank
account information you provided to DAI to establish your pre-authorized
account for the payment of royalties, advertising fees, and other charges. Subject
to a franchisee’s agreement with the independent purchasing cooperative, the
independent purchasing cooperative may bill a franchisee’s bank account for
fees and other costs associated with the SUBWAY® Gift Card Program. If a
franchisee does not wish to disclose this information, they must notify the
Privacy Officer in writing as described in the section titled “Contact
Information” below.
A
franchisee and prospective franchisee’s information may be shared with the
Development Agent in their area. A Development Agent is an independent
contractor of DAI or one of its affiliates. Development Agents assist with
franchise sales, site location, training, and provide operational assistance.
Development Agents also make recommendations as to whether a prospective
franchisee in their territory should be granted a franchise. The Development
Agent may use this information to: address a franchisee’s concerns in a
customer complaint, respond to a franchisee’s inquires for franchise sales, and
any other inquiry which may require a response.
A
franchisee’s information may be shared with our third party service provider in
order to implement Subway Express™ through the
www.subway.com website. Franchisees may provide
information to the third party service provider directly or DAI may supplement
additional franchisee information to our third party service provider.
DAI
will also share Personal Information in order to service franchisee leasing
needs and related administrative functions. Franchisee Personal Information may
be shared during store transfers. Finally, franchisee Personal Information may
be shared with Subway Franchisee Advertising Fund Trust (“SFAFT”) in order to
provide advertising services to member stores.
Finally, upon becoming a SUBWAY® franchisee you
consent to DAI disclosing former or past franchisee contact information
including Personal Information in its Disclosure Document for one (1) year
after leaving the system, as required by law, unless you advise. 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”.
Collection and Use of Development Agent Information
By
applying to become a SUBWAY® Development Agent, a Development Agent applicant
consents to the collection, use, and disclosure of Personal Information in
accordance with the following terms and conditions. We collect and use
information in order to assist you in applying, and evaluating you to become a
Development Agent. Personal Information is collected to assist DAI and its
affiliates in selecting Development Agent candidates and for the purpose of
operating a development territory.
Personal
Information collected includes, but is not limited to: name, home address, home
telephone number, facsimile number, email address, date of birth, bank account
information for Electronic Funds Transfer, financial statement, resume,
taxpayer identification number and background checks. Once a Development Agent
candidate becomes a Development Agent, they may then reference themselves by
their Development Agent Number.
Failure
to provide necessary information may negatively impact your ability to become a
Development Agent.
Sharing of Personal Information
We
may share Personal Information with our service providers, consultants and
affiliates for our internal business purposes. Except as described in this
Privacy Policy, DAI will not share Personal Information with a third party,
unless a customer requests, consents to such disclosure, or disclosure is
required or authorized by law. DAI reserves the right to disclose Personal
Information to a third party if a law, regulation, search warrant, subpoena, or
court order legally requires or authorizes us to do so. DAI also reserves the
right to disclose and/or transfer Personal Information to a third party in the
event of a proposed or actual purchase, sale, lease, merger, amalgamation or
any other type of acquisition, disposal, or financing of all or any portion of DAI
or of any of the business or assets or shares of DAI or a division thereof in
order for a franchisee or Development Agent to continue to receive the same
products and services from the third party.
As
described above, DAI, its affiliates, third party service providers and
Development Agents may share and exchange Personal Information in order to process
franchisee and Development Agent applications, administer the SUBWAY® franchise
system, implement the SUBWAY® Gift Card program, implement Subway Express™ and protect the integrity of the
SUBWAY® franchise system and trademarks. Personal Information may be provided
to a courier or freight forwarder in order to fulfill an order, which may have
been requested from us.
Our
Development Agents and other service providers are prohibited from using
Personal Information for any purpose other than to provide assistance.
Development Agents are required to protect Personal Information disclosed by us
and to comply with the general privacy principles described in this Privacy
Policy.
Storage, Retention and Accuracy of Personal Information
DAI
insures that Personal Information is safeguarded against loss, access, use,
modification, disclosure or other misuse. All reasonable steps are taken to
prevent unauthorized use or disclosure of your Personal Information.
DAI
will retain your Personal Information only for as long as necessary to fulfill
the purpose(s) for which it was collected and to comply with applicable laws,
and your consent to such purpose(s) remains valid after termination of our
relationship with you.
We
take all reasonable steps to insure that your Personal Information is accurate,
up-to-date, complete, relevant and not misleading.
DAI may store your Personal Information in its databases located
in the United States and/or other countries outside of the United States. Additionally, some of our service providers may reside in the United States or other countries outside of the United States 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 DAI.
Contact Information
You
may contact the Privacy Officer to access, correct or delete your Personal
Information. If necessary, the Privacy Officer will contact another employee to
assist in completing your requested task.
If
you have any questions or complaints, please contact the Privacy Officer. The
Privacy Officer can be reached by telephone at: (203) 877-4281 or
1-800-888-4848; by Facsimile at: (203) 876-6690; by email at:
privacyofficer@subway.com;
or by mail at Doctor’s Associates Inc., 325 Bic Drive, Milford, CT, 06461, USA.
We will address your concern and attempt to resolve any problem. Download
Privacy
Information Request Form here.
Links to Non-DAI Web Sites and Third Parties
Please
note that DAI or SUBWAY® web sites may contain links to other web sites for
your convenience and information. DAI does not control those sites or their
privacy practices, which may differ from
www.subway.com.
DAI’s privacy policy cannot and does not apply to external Web areas. We do
not endorse or make any representations about third party web sites. The
personal data you choose to give to unrelated third parties is not covered by
the DAI privacy policy. We encourage you to review the privacy policy of any
company or website before submitting your Personal Information. Some third
parties may choose to share their personal data with DAI; that sharing is
governed by that third party company’s privacy policy.
Safe Harbor Compliance
DAI
is in compliance with the U.S. Department of Commerce Safe Harbor requirements
regarding the transfer of personal information from European Union member
countries to the United States. DAI has been Self-Certified in accordance with the EU
Directive on Personal Data Protection. The principles of Safe Harbor compliance are notice, choice,
onward transfer, security, data integrity, access and enforcement. Additional
information about 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.
Members of the European Union
If
you are a resident of a Member State of the European Union and have any concerns
or complaints, please first address these issues to the Privacy Officer. Doctor’s
Associates Inc. is located in the United States, as are the servers that make
our websites available. All matters relating to privacy issues and websites are
governed by the laws of the United States and the State of Connecticut. If the
Privacy Officer does not satisfactorily address a complaint within thirty (30)
days, any dispute, controversy or claim shall be settled by an arbitration
administered by an arbitration agency, such as the American Arbitration
Association (“AAA”). All arbitrations will be conducted in English. Judgment
rendered by the arbitrator may be entered in any court having jurisdiction. The
costs of the arbitration will be borne equally by the parties. Connecticut, U.S.A. shall be the site of all hearings, and such hearings shall be before a
single arbitrator. You may also submit complaints to the Federal Trade
Commission at
http://www.ftc.gov/ftc/complaint.htm
or via telephone at (202)382-4537.
International Privacy
Policies
To view your country’s
Privacy Policy please go to www.subway.com.
At the top of the page, please click on AROUND THE WORLD, then click on
your country. Go to the very bottom of your country’s page and click PRIVACY
POLICY to view your country’s specific Privacy Policy.
Changes to our Privacy
Policy
We reserve the right to modify this
privacy statement at any time, so please review it frequently. If we make
material changes to this policy, we will notify you in this Privacy Policy, by
email, or by means of a notice on our home page.
REVISED: DAI
10/27/08
DAI Privacy Policy
International
Privacy Policies
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