LAST REVISED: 09-30-2014

SUBWAY® APP
PRIVACY STATEMENT

Milford, CT
USA

1. SUBWAY® App Privacy Statement Scope

Your Privacy is very important to us. This Privacy Statement applies only to the SUBWAY GROUP Mobile App (“App”) you are currently accessing. This Privacy Statement describes the type of Personal Information that may be collected directly from the SUBWAY® App. We will not share your Personal Information with anyone except as described in this Privacy Statement.

The SUBWAY GROUP values your privacy and wants to give you the opportunity to know what Personal Information is collected about you, that the Personal Information you provide the SUBWAY GROUP is protected, used, disclosed, and otherwise managed in conformance with applicable law. This Privacy Statement applies to the collection of Personal Information solely in connection with the SUBWAY® App.

Franchise World Headquarters, LLC ("FWH") is an affiliate of, and service provider to, Doctor’s Associates Inc. ("DAI"), the owner of the SUBWAY® Restaurant System. DAI owns and licenses the SUBWAY® trademark and SUBWAY® Restaurant System to its affiliates in order to develop SUBWAY® restaurants worldwide. 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 ("SFAFT") administers national and local advertising funds and activity for SUBWAY® restaurants and SUBWAY® franchisees worldwide. Independent Purchasing Cooperative, Inc. ("IPC") is a member owned and operated non-stock corporation in which the members are SUBWAY® franchisees, and Value Pay Services LLC ("VPS") is the IPC’s wholly owned subsidiary. Paydiant, Inc. is the owner of the SUBWAY® App payments platform and the third-party service provider of the payments platform. FWH, DAI, SFAFT, IPC, VPS, and Paydiant, Inc., are collectively referred to herein as the ("SUBWAY GROUP").

If you would like more information about how the various members of the SUBWAY GROUP collects, protects, uses, shares, and stores, Personal Information outside of the SUBWAY Mobile App, then we encourage you to review our respective website Privacy Statements, which discloses each companies full privacy practices and procedures. For your convenience, we have provided our individual Company website Privacy Statement links below:

FWH: http://www.subway.com/subwayroot/PrivacyPolicy-FWH.aspx
DAI: http://www.subway.com/subwayroot/PrivacyPolicy-DAI.aspx
SFAFT: http://www.subway.com/subwayroot/PrivacyPolicy-SFB.aspx
IPC: https://www.ipcoop.com/public/quick-facts.aspx
VPS: https://www.subwaycatering.com/About/Privacy.aspx
Paydiant, Inc.: http://www.paydiant.com/privacy.html

The SUBWAY® App Privacy Statement does not govern the privacy practices and procedures of independently owned SUBWAY® Restaurants. Nor, does the SUBWAY® App Privacy Statement govern the Personal Information handling practices and procedures of any SUBWAY GROUP affiliates. This Privacy Statement does not apply to Personal Information we may collect by any means other than your use of this SUBWAY® App (including offline) or from other sources.

The SUBWAY GROUP developed a mobile payments service (“Service”) to make it easier for you to make mobile payments and other related transactions. The Service allows you to make payments through certain credit and debit card products, such as, American Express, Discover Card, MasterCard, and Visa. The SUBWAY GROUP offers the Service through a payments platform, provided by Paydiant, Inc. You must register a "SUBWAY User Account" in order to use the Service. The SUBWAY GROUP respects your privacy and works hard to protect your Personal Information and we want you to understand how we may collect, use, share, store, and protect the Personal Information you provide us.

2. Consent to Share and Disclose Information, Including International Data Transfers

In addition to consenting to the SUBWAY® App Privacy Statement, Terms and Conditions, as well as any relevant supplemental policies, you expressly consent to the SUBWAY GROUP sharing the Personal Information that you have provided to the SUBWAY GROUP, as described herein. The SUBWAY GROUP may share Personal Information with its affiliates and/or third-party service providers. The SUBWAY GROUP may also share your Personal Information with companies that provide support services to SUBWAY GROUP, 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, the SUBWAY GROUP does not control these companies nor does the SUBWAY GROUP authorize these companies to use your Personal Information that the SUBWAY GROUP may share with them, for any reason other than the purpose for which the SUBWAY GROUP hired them. You agree that the SUBWAY GROUP 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 SUBWAY GROUP’s operations and programs.

BY SUBMITTING PERSONAL INFORMATION TO THE SUBWAY GROUP, AND/OR BY ACCESSING AND USING THE SUBWAY® APP, YOU AGREE TO THE SUBWAY GROUP’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.

3. Consent to Electronic Notice If There Is a Security Breach

If the SUBWAY GROUP or a Recipient is required to provide notice of unauthorized access of certain security systems, you agree that the SUBWAY GROUP, or the Recipient, may do so when required or voluntarily by posting notice in the SUBWAY® App or sending notice to any email address the SUBWAY GROUP or the Recipient has for you, in the good faith discretion of the SUBWAY GROUP 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.

If you have questions about this Privacy Statement or the protection of your Personal Information, please contact the Privacy Officer at privacyofficer@subway.com.

4. Information We Collect

When you register for, or use the SUBWAY® App, we collect the following information:

User Provided Information

The SUBWAY® App obtains the information you provide when you download and register the SUBWAY® App. When you register, we may collect your first and last name, location, mobile telephone number, email address, user name, password and other registration information, as well as other related information such as:

Automatically Collected Information

We use technologies to receive and store certain types of information whenever you interact with the SUBWAY® App.

The SUBWAY® App may collect precise information about the location of your mobile device or access device in order for us to use your location information to provide requested location services. You may at any time opt-out from further allowing us to have access to your location data by adjusting the permissions in your mobile device or access device. For more information, please see the section below entitled "What Are Your Choices"?

The SUBWAY® App may also collect certain information automatically such as the type of mobile device or access device you use, your mobile device or access device unique device ID, the IP address of your mobile device or access device, your mobile or access device operating system, the type of Internet browsers you use, and information about the way you use the SUBWAY® App.

Cookies

It is important for us to track how the SUBWAY® App is used and we (or our service providers) may place "cookies" on your mobile device or access device. Cookies are small data files that identify you when you use our Services. You have the option to decline our cookies by using your browsers settings tools, but this may interfere with the use of the SUBWAY® App and Services.

Log File Information

Log file information is automatically reported by your mobile device or access device each time you access the SUBWAY® App. When you register a SUBWAY User Account the SUBWAY® App may automatically record certain information whenever you use the SUBWAY® App. The log files may include information such as your user request, Internet Protocol ("IP") address, browser type, number of times you access the SUBWAY® App, other such information.

We use cookies and log file information to:

Any information that can be used to identify a person is “Personal Information.” This does not include information that has been aggregated or made anonymous. All information is securely stored on servers located in the United States.

5. Our Use of Your Personal Information

The SUBWAY GROUP uses your Personal Information to provide you the features and functionality of the SUBWAY® App, and we may share it with our trusted third parties, to ensure that you have a safe, high-performance experience when using the SUBWAY® App. When you use the SUBWAY® App, including making a payment, contacting customer service, requesting technical support, as well as any other interactions you may have with the SUBWAY GROUP, we will use the information you have provided to assist you. Knowing this information allows us to verify your identity, communicate with you and enforce our agreements with you. We strive to provide you with the best possible experience by ensuring compliance with federal and state laws and our own policies, including but not limited to: preventing fraudulent transactions, monitoring against theft, and protecting users of the SUBWAY® App. We may also use this information to measure how our members use the SUBWAY® App and improve and enhance our offerings to you.

The SUBWAY GROUP may use your Personal Information for product and service fulfillment purposes such as managing purchases, orders, payments or requests for information. We may also use your Personal Information to allow you to find a store nearest to your location, check prices, scan a QR code or update your Personal Information.

6. How is Your Information Shared?

The SUBWAY GROUP will share your information with third parties only in the ways that are described in this Privacy Statement.

The SUBWAY GROUP will not rent or sell your Personal Information to others. The SUBWAY GROUP may share your Personal Information with third parties for the purposes of providing services to you such as those described herein. If we do this, such third parties' use of your Personal Information will be bound by terms at least as restrictive as this Privacy Statement. We may store Personal Information in locations outside the direct control of the SUBWAY GROUP (for instance, on servers or databases co-located with hosting providers).

Processing payment transactions requires that we share your Personal Information with third-party service providers who provide us with a range of essential operational services, including but not limited to:

The SUBWAY GROUP may share your Personal Information with law enforcement authorities or government representatives when we believe that such action or disclosure is necessary to:

7. What Are Your Choices?

If you no longer want the SUBWAY® App to collect and use Personal Information about you, there are multiple opt-out options for users of the SUBWAY® App.

Opt-out of all information collection by uninstalling the SUBWAY® App: You can stop all collection of Personal Information by the SUBWAY® App easily by uninstalling the SUBWAY® App. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile marketplace or network.

Opt-out of Location Function: You may at any time opt-out from further allowing us to have access to your location data by adjusting the permissions in your mobile device.

Decline to Submit Information: You may, of course, decline to submit Personal Information through the SUBWAY® App, in which case the SUBWAY GROUP may not be able to provide certain services to you.

You may update or correct your account information at any time by logging into your account. You can review and correct the information about you that the SUBWAY GROUP keeps on file by contacting us as described below.

8. Data Retention Policy, Managing Your Information

The SUBWAY GROUP will retain User-Provided Personal Information for as long as you use the SUBWAY® App. If you would like the SUBWAY GROUP to delete your Personal Information that you have provided via the SUBWAY® App, please contact the Privacy Officer at: privacyofficer@subway.com Please note that some or all of yourPersonal Information may be required in order for the SUBWAY® App to function properly, and we may be required to retain certain information by law.

9.The SUBWAY® App is not targeted towards children under the age of thirteen (13). If you are a child under the age of thirteen (13) PLEASE, DO NOT download the SUBWAY® App.

Children’s privacy is very important to the SUBWAY GROUP. The SUBWAY GROUP’s servers are located in the United States. The SUBWAY GROUP 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. The SUBWAY GROUP 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 the SUBWAY GROUP with Personal Information without the consent of a parent, we ask the parent of that child to contact the Privacy Officer immediately at: privacyofficer@subway.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.

10. Security

Our safeguards and procedures have been implemented in accordance with the United States Federal and State laws and regulations to maintain the physical and electronic security of your Personal Information while using our Service and software. Our security measures include,but are not limited to: firewalls, system-wide data encryption, physical and electronic access controls, and strict rules regarding the access and use of data on our system.The SUBWAY GROUP is concerned about safeguarding the confidentiality of your information. We provide physical, electronic and procedural safeguards to protect Personal Information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our SUBWAY® App. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

In the event that Personal Information is compromised as a result of a breach of security, the SUBWAY GROUP will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in this Privacy Statement, or as otherwise required by applicable law.

11. Contact Information

If you have any questions or concerns regarding the SUBWAY® App, please contact:

The SUBWAY GROUP Privacy Officer
c/o: Franchise World Headquarters, LLC
325 Bic Drive
Milford, CT, 06461
USA
Telephone Number: (203) 877-4281 or Toll Free: 1-800-888-4848
Facsimile: (203) 783-7479
Email Address: privacyofficer@subway.com

We will address your concern and attempt to resolve any problem

12. Changes to Our Privacy Statement

The SUBWAY GROUP will update this Privacy Statement occasionally. When the SUBWAY GROUP posts changes to this Privacy Statement, we will also revise the "LAST REVIEWED" date on the SUBWAY® App's Privacy Statement. If there are any material changes to this Privacy Statement, the SUBWAY GROUP will notify you by email, or by means of a notice on the SUBWAY® App. The SUBWAY GROUP encourages you to review this Privacy Statement periodically to be informed of how the SUBWAY GROUP is protecting your Personal Information and to be aware of any changes to the Privacy Statement. Your continued use of the SUBWAY® App 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 SUBWAY® App and any programs or services operated or managed on or behalf of the SUBWAY GROUP. Any changes to this Privacy Statement are effective immediately after being posted by the SUBWAY GROUP.

13. Terms and Conditions of Website Use

The Terms and Conditions govern your use of the SUBWAY® App and 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.