THE SUBWAY® GROUP PRIVACY STATEMENT
Last Revised: September 9, 2023
This Privacy Statement describes how we collect, use, disclose, transfer, and store your information. It will also tell you about your rights with regard to your personal data.
HOW TO CONTACT US
The Subway® Group Privacy Office
c/o Franchise World Headquarters, LLC
325 Sub Way
Milford, CT, 06461
Telephone Number: (203) 877-4281 or
Toll Free: 1-800-888-4848
Email Address: firstname.lastname@example.org
If you are a user with a disability and need access to this Privacy Statement in an alternative format, please contact us at email@example.com.
Table of Contents
- ABOUT THIS STATEMENT
- PERSONAL INFORMATION WE COLLECT
- HOW WE COLLECT INFORMATION
- HOW WE USE YOUR PERSONAL INFORMATION
- SHARING YOUR INFORMATION
- COOKIES AND TARGETED ADVERTISING
- OPTING OUT
- YOUR RIGHTS AND CHOICES
- INTERNATIONAL TRANSFERS
- HOW LONG WE KEEP YOUR INFORMATION
- CHILDREN’S PRIVACY
- OUR SECURITY
- OUR GROUP COMPANIES
1. ABOUT THIS STATEMENT
What this statement applies to. This Privacy Statement applies to the personal information that the Subway® Group collects when you interact with the Subway® brand online and offline. This includes information collected through our websites, WiFi services or similar technology provided in Subway® restaurants, branded pages on third party platforms (i.e. social networking services), mobile applications, and through our direct marketing campaigns or other communications, as well as, when you purchase our products, request delivery and carry-out services, subscribe to our news and offers, enter into one of our promotions or contact customer support, apply for employment, or apply to become a franchisee (collectively, “Subway® Services”).
Changes to this statement. If we make any material changes to this statement, we will notify you by means of a notice on this site or by an email (sent to the email address specified in your account). Where we are required by applicable data protection laws, we will also seek your consent to any material changes that affect how we use your personal information. We encourage you to periodically review this page for the latest information on our privacy practices.
2. PERSONAL INFORMATION WE COLLECT
When you use Subway® Services, we may ask you to provide certain personal information. The personal information we collect from you depends on the nature of your interaction with us or the Subway® Services you use, but may include the following:
- Contact Information. We may collect personal and/or business contact information including your first name, last name, mailing address, delivery address, telephone number, email address, and other similar data.
- Payment Information. If you make a purchase online, you will be required to provide a credit/debit card number and related financial information (such as expiration date, security code and billing address), or other payment information (such as your Subway® Card), depending on the form of payment you choose.
- Account Information. We collect information such as your username and password when you create a Subway® account, access our online services, or buy our products. Account information may also include how you purchased or signed up for Subway® Services, your transactions, billing and support history for the Subway® Services you use and anything else related to the account you create. This includes information pertaining to your use of Subway® Cards and your participation in Subway® MVP Rewards, including all related transactions, both in-restaurant and online, whether that information is obtained directly from you or through a service provider we have engaged to help provide those programs.
- Usage Data. This is the personal information we collect about you when you are using Subway® Services, which may include information about the date and time of your logins and details of your use of third-party applications and advertising you receive.
- Marketing and Communications. We may also collect your preferences in receiving marketing from us and our partners.
- Security Credentials.We collect user IDs, passwords, email, and similar security information required for authentication and access to your Subway® accounts.
- Information through Social Media. You may be given the option to link to your Facebook or other social media accounts through Subway® Services. Your use of these features may result in the collection or sharing of information about you, depending on the feature. For example, these features may collect your IP address and information about pages you visit on our site, and may set a cookie to enable the feature to function properly. They may also allow social media services to provide us information about you, including your name, email address, and other contact information. The information we receive is dependent upon your privacy settings with the social media network. We encourage you to review the privacy policies and settings on the social media services you use to make sure you understand the information that is collected, used, and shared by those sites.
- Customer Service, Surveys & Promotions. There may be times you provide us additional personal information when you interact with our customer support channels online or by phone or mail; when you participate in our customer surveys or promotions; or to facilitate delivery of Subway® Services or to help us respond to your inquiries. Types of additional personal information may include voice recordings, photographs and videos.
- Information You Provide about Others. You may decide to provide us with another person’s information (such as their name, email, address or phone number) so that we may recommend or send products or services to that person. Local law may require you to get the consent of that person to provide their information to the Subway® Group. We may in turn use the information you provide in accordance with this Privacy Statement.
- Device & Technical Data. We collect technical information when you visit our websites or use our mobile applications or other electronic services. This includes information such as you Internet Protocol (IP) address, your login data, the type of mobile device you use, your device operating system and browser type, time zone setting and location, language, device identifiers, the address of a referring website, the path you take through our websites, and other information about your session on our websites.
- There may be instances in which the personal information that you provide to us is considered “Sensitive Personal Information” under applicable privacy laws. Sensitive personal information we collect includes: Precise Geolocation and certain Payment and Account information that includes security codes, access codes, or passwords allowing access to an account.
If you apply for employment with the Subway® Group, we collect information as part of your application as well as the recruitment process. Personal information collected may include: Your Name, Personal Email, Physical Home Address, Personal Phone Number(s), Government Issued Id (Passport, Driver's License #, SSN), Date of Birth, Banking Information, Education, Criminal Background, Job Qualifications, Employment History, Financial Statements, Electronic Signature, Physical limitations & Special Needs, and References. We may also receive this information if you submit your application via a third-party site or through a recruiter or employment agency.
There may be instances in which the personal information that you provide to us is considered “Sensitive Personal Information” under applicable privacy laws. Sensitive personal information we collect includes: Racial or Ethnic Origin, Philosophical Beliefs, Nationality, Trade Union Membership, Sexual Orientation, Political Opinion, Health Information, Citizenship, Passport, Driver's License #, SSN, and other categories established by applicable law. To the extent you make Sensitive Personal Information available to Subway®, where required by law you consent to Subway® processing such information in accordance with this Privacy Statement.
All information, including personal information submitted by you as part of the application process, will become part of your employee file should you become an employee. Employees’ personal information is governed by separate policies and not by this Privacy Statement.
Franchisees & Business Developers
If you apply to become a Franchisee or a Business Developer with the Subway® Group, we may collect information as part of your application. Personal information collected may include, but is not limited to: Your Name, Date of Birth, Personal/Work Email, Physical Home Address, Personal Phone Number(s), Government Issued Id,(Passport, Driver's License #, SSN), Photographs & Videos, Marital Status, Educational Background, Voice Recordings, Financial & Banking, Litigation History, Criminal & Credit History, Job title, Job Qualifications, Employment History, Tax Records, Electronic Signature, and Military Veteran Status.
Some of the personal information that you provide may be considered “Sensitive Personal Information” under the privacy laws of some countries. Sensitive Personal information may include: Racial or Ethnic Origin, Philosophical Beliefs, Nationality, Trade Union Membership Sexual Orientation, Political Opinion, Health Information, Citizenship, Passport, Driver's License #, SSN, and other categories established by applicable law.
Please note all information, including personal information submitted by you as part of the application process, may become part of your franchise or business developer file.
3. HOW WE COLLECT INFORMATION
When you use Subway® Services, we may ask you to provide certain personal information to obtain our products or use our services. For example, we collect information if you place an order, create an account, or contact us. We also collect information from you if sign up for email communications, submit a job application, or otherwise submit your information to us. This could be in person, by phone, or online.
We Collect Information Automatically
When you visit or interact with Subway® Services as well as any third-party advertisers and/or service providers, we may use a variety of technologies that automatically or passively collect information about your online activity. We and our service providers use technologies such as cookies, web beacons, unique advertising identifiers, and mobile device identifiers to collect information about the use of our websites and mobile services. For more information, including the types of cookies found on Subway® websites and how to control cookies, please read the “Cookies & Targeted Advertising” section below.
We Receive Information from Third Parties
We may collect information about you from other companies and organizations, including our service providers, public databases, social media platforms, our marketing partners or various independent purchasing organizations established for the benefit of Subway® franchisees. This includes, for example, information from public databases or data aggregators that may include your demographic information, media consumption, previous purchases, shopping habits, loyalty program information or lifestyle preferences.
Independent purchasing organizations provide a variety of support functions to Subway® franchisees in each region. Support functions may include, but are not limited to, administering rewards, loyalty, and gift card programs, in which we may work with the independent purchasing organization in joint marketing efforts in relation to those programs. The Independent purchasing organizations we work with are Independent Purchasing Cooperative, Inc. (United States, its territories, and Canada), Independent Purchasing Company (Australasia) Ltd. (Asia, Australia, and New Zealand), Latin American and Caribbean Independent Purchasing Company (Latin America and Caribbean), Independent Purchasing Company Europe Limited (Europe) and Middle East Independent Purchasing Company Ltd. (MEIPC) (Middle East).
We Collect Information that is Publicly Available
For example, we may collect public information about your when you interact with us through social media. By collecting additional information about you, we can correct inaccurate information, enhance the security of your transactions, and give you product recommendations and special offers that are more likely to interest you.
We Combine Information
We may combine the information we receive about you, including information you provide directly to us and information we automatically collect through Subway® Services, as well as information collected across other computers or devices that you may use, from other online or offline sources, and from third parties. If we combine your personal information and non-personal information, we will treat the combined information as personal information in accordance with this Privacy Statement.
4. HOW WE USE YOUR PERSONAL INFORMATION
To provide our services and contract with you, including to:
- carry out your requests, fulfill orders, and process payments for our products and services;
- establish and manage your accounts;
- communicate with you about your orders, purchases or accounts with us, or changes to our terms & conditions or Privacy Statement, including handling any requests, questions or comments you may have;
- communicate about, and administer your participation in, special events, programs, webinars, surveys, contests, sweepstakes, and other offers or promotions;
- provide Subway® Card services to you;
- enabling your participation in the Subway® MVP Rewards program;
- provide online services to you, which includes our websites and/or mobile applications;
- provide customer support, including processing any concerns about our services;
- verify your identity, such as on service calls, login credentials, convention registration;
- enforce our contracts with you and fulfill the performance of a contract; and
- for legitimate human resources and business management reasons
To market to you, improve our services, and the following legitimate business interests, including to:
- tell you about our products and services, competitions, offers, promotions or special events that we believe may interest you when you are part of a Subway® loyalty program;
- personalize your experience in our restaurants and on our online services;
- verify your identity or communicate with you about your activities with respect to Subway® Services;
- operate, evaluate, and improve our business, including developing new products and services, managing our communications, conducting consumer and operations research, assessing the effectiveness of our sales, marketing and advertising, analyzing and enhancing our products and services, performing accounting, auditing, billing, reconciliation and collection activities;
- administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data;
- to respond to and process applications from potential franchisees and business developers and potential employees;
- use analytics and profiling technology to personalize your experience; deliver content (including advertising) tailored to your interests and let you know how to use Subway® Services (see “COOKIES AND TARGETED ADVERTISING” below for more information);
- link or combine with information we receive from others to help understand your needs, use for interest-based or targeted advertising or re-targeting on your computers or other devices;
- ensure the security of our networks and systems, including to help diagnose technical and service issues, troubleshoot issues, bugs or defects related to your account or activities;
- identify and evaluate candidates for potential employment, as well as for future roles that may become available;
- conduct criminal and credit background checks (e.g., OFAC searches) as permitted or required by law;
To comply with applicable law, including to:
- protect against, identify, and prevent fraud and other criminal activities, claims and liabilities;
- comply with legal obligations and our policies;
- establish or defend a legal claim; and
- monitor and report compliance issues.
For the public interest:
- we may use your personal information if we reasonably believe that there is an inherent security or product issue that we must either disclose to you or the authorities and the use of your information will prevent or potentially minimize the danger to you or others.
With your consent (where required by applicable law), we may use the information we collect for the following purposes:
- to process Sensitive Personal Information (where required by applicable law)
- to send you emails or text messages about the products and services, competitions, offers, promotions or special events we believe may interest you;
- to send you emails or text messages about the products and services of our business partners;
- provide location-based services;
We may use the information we collect about you in other ways, which we will tell you about at the time we collect it and for which we will seek your consent if required by law.
We do not use or disclose sensitive personal information, as defined by California law, for inferring characteristics or for purposes other than those permitted by law.
5. SHARING YOUR INFORMATION
Within the Subway® Group
The Subway® Group may share your information amongst our entities in order to administer our rewards and loyalty programs, process orders and requests, and expand and promote our product and service offerings. Members of the Subway® Group who receive your personal information are not authorized to use or share the information, except as set out in this Privacy Statement.
With Third Parties
Subway® Franchisees and Business Developers. If you choose to contact us or submit a survey about your experience in a Subway® franchisee’s restaurant, we may share your information with the Subway® franchisee in order for them to address your request, compliment or complaint. We may also share your information with the Business Developer who oversees the operations of the restaurant. Business Developers are independent contractors of the Subway® franchisor who are responsible for the growth of the franchise in a specific territory.
Independent Purchasing Organizations. Depending on your region, we may share your personal information with the applicable independent purchasing organization in your market and their subsidiaries in connection with online purchases, registration of gift cards and the administration of rewards and loyalty programs.
Service Providers. We may share your personal information with vendors who provide services to us, such as business, professional or technical support functions. This includes, but is not limited to: service providers that host or operate Subway® Services; payment processors; food delivery companies; data processing or other information technology services; research and analytics vendors, customer experience management services and vendors that assist with personalizing individual customer experiences. We do not allow these vendors to use or share this information for any purpose other than to provide services on our behalf.
Advertising Partners. We may share information, excluding mobile originator and opt-in consent data, with third parties to provide marketing and advertisement purposes, including to provide cross-contextual behavioral advertising on our websites. In our California Privacy Notice (below) we outline which categories of information are shared for cross-contextual behavioral advertising on our websites.
Sweepstakes, Contests, and Promotions. If you choose to enter into one of our sweepstakes, contests, or other promotions, we may disclose your information to third parties or the public in connection with the administration of such promotion, as required by law, as otherwise permitted by the Promotion’s official rules, or otherwise in accordance with this Privacy Statement.
Business Transfers. Your Personal Information is considered a company asset and may be disclosed or transferred to a third party in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding) of the Subway® Group or a division thereof, in order for you to continue to receive the same products and services from, or to continue the same or similar relationship with, the third party.
Legal Disclosures. We may disclose your information if we believe that the disclosure is required by law, a subpoena or other legal process, if we believe that the disclosure is necessary to enforce our agreements or policies, or if we believe that the disclosure will help us protect the rights, property or safety of the Subway® Group or our guests or partners.
When You Consent. We may share your information with other companies if you give us permission or direct us to share the information.
6. COOKIES AND TARGETED ADVERTISING
We also use analytics and tracking tools, such as Google Analytics, Adobe Marketing Cloud, Facebook Customer Audience and others, to help us track, segment and analyze usage of the Subway® Services, and to help us or those vendors serve more targeted advertising to you on the Subway® Services and across the Internet. Those tools may use technology such as cookies, web beacons, pixel tags, log files, or other technologies to collect and store certain information, such as Usage Data, Device & Technical Data, and Geolocation Data. We also participate in the Adobe Marketing Cloud Device Co-op to better understand how you use our website and apps across the various devices you use, and to deliver tailored promotions. Go to https://cross-device-privacy.adobe.com to learn more about how Adobe does this. You may opt-out of having your activity on our website made available to Google Analytics by installing the Google Analytics browser add-on, available at: https://tools.google.com/dlpage/gaoptout.
Do Not Track: Some browsers have “do not track” features that allow you to tell a website not to track you. We do not currently respond to those signals unless noted in this policy.
7. OPTING OUT
Your browser may give you the ability to control cookies or other tracking tools. How you do so depends on the type of tool. Certain browsers can be set to reject browser cookies. If you block cookies, certain features on our sites may not work.
To manage your cookie preferences, please click on Cookie & Ad Settings
Additionally, the Self-Regulatory Program for Online Behavioral Advertising provides consumers with the ability to manage certain choices online here and provides a tool for managing mobile choices here. European users should use the following link.
Please note, options you make are browser and device specific.
You may opt-out of marketing communications by following the opt-out instructions in the marketing emails we send you or you can also contact us by using the contact details provided under the “How to Contact Us” section above. Depending on the Subway® Services you use, you may also have the ability to change your communication preferences in the profile section of the online services that you use or in your device settings.
If you do opt out of receiving marketing emails from us, we may still send communications to you about your transactions, any accounts you have with us, and any contests, competitions, prize draws or sweepstakes you have entered. Opting out of one form of communication does not mean you’ve opted out of other forms as well. For example, if you opt out of receiving marketing emails, you may still receive marketing text messages if you’ve opted in to receiving them. Please note that if you are receiving communications from a Subway® franchise, then you will need to opt out from them directly.
Where our mobile applications allow for the delivery of “push notifications”, you can also opt out of receiving these notifications by going into your mobile phone settings and toggling the “Notifications” switch within our mobile application to “off”.
Rewards and Loyalty Programs
U.S., Canada, United Kingdom, Finland. Participation in the Subway® MVP Rewards program is voluntary; you may end your participation in the Subway® loyalty program by using the contact details provided under the “How to Contact Us” section above, in which case any data gathered through the program will be deleted except what we are legally required to keep and subject to the remainder of this Privacy Statement. Please note that data originating through other non-program interactions may remain with us.
Other regions. If you would like to opt out of a loyalty program in a region not listed above, please contact the independent purchasing organization that is responsible for administering the program in the region in which you registered. For a list of all the independent purchasing organizations and their regions, please see the “Information Received from Third Parties” section above.
App Tracking Preferences
Opt Out By Deletion. You may use the standard uninstall, application, and data management processes available through your mobile device. Once you have uninstalled the app, all the information that is stored in the app is deleted, including any preferences you previously set for location permissions and whether you have allowed us to send you push notifications. Once the app is uninstalled and preferences are deleted, push notifications from the app will stop. You may also refrain from using application features that collect specific types of data. If you are an Apple user, our app also allows you to request deletion of all account data from us.
Location Opt Out. You may be able to adjust the settings of your device so that information about your physical location is not shared with our app or other apps by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings. Please note your location may be derived from your WiFi, Bluetooth, and other device settings. See your device settings for more information.
8. YOUR RIGHTS AND CHOICES
Access Your Personal Information. You can request access to your personal information. This enables you to receive a copy of the personal information we hold about you as well as details about how we are processing it.
Modify or Update Your Personal Information. We aim to ensure that personal information in our possession is accurate, current and complete. If you believe that the personal information about you is incorrect, incomplete or outdated, you may request the revision or correction of that information.
Erasure of Your Personal Information. You may ask us to delete or remove personal information we hold about you, subject to certain exceptions.
Please note that if you are a Subway® MVP Rewards member, requesting deletion may require the deletion of your account which, upon completion, cannot be undone.
Object to Processing Your Personal Information. You may have the right to object to us processing your information in certain circumstances.
Right to Opt-out of Sale/Sharing/Targeted Advertising.
Some states require that we tell you if we sell personal information to third parties for monetary or other valuable consideration, if we share personal information for cross-context behavioral advertising, or use your personal information for targeted advertising. We do not sell personal information in exchange for money; however, we do engage in targeted advertising, and some of our advertising practices on our websites may be classified as sales or sharing under certain state laws. We do not sell personal information of minors under the age of 16 for monetary or other valuable consideration. In certain jurisdictions, you have the right to opt-out of the sale or sharing of your personal information. You may submit a request by clicking Do Not Sell or Share My Personal Information in the footer of our website and following the instructions. Some browsers also allow you to tell websites not to share your information for cross-contextual behavioral advertising. To learn how to configure this setting, view here. Selections are browser and device specific. To opt out of cross-contextual behavioral advertising, you can also manage your selections Cookie & Ad Settings in the footer.
Data Portability. You may request the transfer of your personal information to you or a third party. We will provide to you, or a third party you have chosen, your information in a structured, commonly used, machine-readable format.
Right to Appeal. If Subway® rejects your request, you may have the right to appeal that rejection within a reasonable time period. To do so, you can contact us as described in the “How to Contact Us” section above .
Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable law.
How to Exercise Your Rights. You may exercise any of these rights, by submitting a request using our webform here and following the instructions. You may also call our toll-free number at 800-888-4848. In the request, please specify which right you are seeking to exercise and the scope of the request. We may require specific information from you to help us verify your identity and process your request, including your name, email address, and country of residency. If we are unable to verify your identity, we may deny your requests.
- Please note that Subway® restaurants are franchised and are independently owned and operated. Their processing of personal information is subject to their own privacy policies. If you wish to exercise any of these rights with respect to the processing of information by a Subway® restaurant, please visit your local franchise-owned and operated store location to make your requests. We will work with the franchise owner to address your request to the extent required by applicable law.
If you are not satisfied with our response, and are in the European Union or United Kingdom, you may have a right to lodge a complaint with your local supervisory authority.
9. INTERNATIONAL TRANSFERS
For our customers whose use of Subway® Services results in the transfer of personal information from the European Economic Area (EEA), United Kingdom, Switzerland, or other jurisdictions with adequacy provisions to non-adequacy country, we rely on one or more of the following legal mechanisms: Standard Contractual Clauses, and consent of the individual.
10. HOW LONG WE KEEP YOUR INFORMATION
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of the personal information; the purposes for which we use the personal information; whether we can achieve the purposes through other means; and the applicable legal requirements.
11. CHILDREN’S PRIVACY
If you are a parent or legal guardian and believe we may have collected information about your child, please contact us as described in the “How to Contact Us” section above.
If we learn that we have inadvertently collected the personal information of a child under 13, or equivalent minimum age depending on the jurisdiction, we will take steps to delete the information as soon as possible.
12. OUR SECURITY
13. OUR GROUP COMPANIES
Doctor's Associates LLC
Franchise World Headquarters, LLC
FWH Technologies, LLC
SJ Marketing G.K.
Subway Brand Management & Consultant (Shanghai) Co., Ltd.
Subway Franchise Systems of Canada, ULC
Subway Franchisee Advertising Fund Trust B.V. Sucursal Argentina
Subway Franchisee Advertising Fund of Australia Pty. Ltd.
Subway Franchisee Advertising Fund of Canada Inc.
Subway Franchisee Advertising Fund Trust B.V.
Subway Franchisee Advertising Fund Trust Ltd.
Subway Franchisee Canadian Advertising Trust
Subway International B.V. - South Korea Branch
Subway International B.V. - Taiwan Branch
Subway International B.V.
Subway International B.V. Sucursal Argentina
Subway International B.V. Sucursal El Salvador
Subway International B.V. Philippines Branch
Subway International de Mexico, S. de R.L. de C.V.
Subway IP LLC
Subway Japan G.K.
Subway Japan Restaurants G.K.
Subway MyWay of Canada, ULC
Subway MyWay, LLC
Subway Partners Colombia C.V.
Subway Payment Services, LLC
Subway Payment Services Canada, ULC
Subway Realty Limited
Subway Realty of France EURL.
Subway Realty of Spain, S.L.U.
Subway Subs of Canada, ULC
Subway Systems Australia Pty. Ltd.
Subway Systems Colombia S.A.S.
Subway Restaurant Management (Shanghai) Co. Ltd.
Subway Systems Middle East FZ-LLC
Subway Systems Singapore Pte. Ltd.
Subway Vermietungs-und Servicegesellschaft mbH
Subway Vermietungs-und Servicgesellschaft G.m.b.H. -organizační složka (Czech Republic)
Thank you for reading our Privacy Statement. If you have any questions about this Statement or about how we process personal information, please contact us by using the contact details provided under “How to Contact Us”, which is located at the top of this document.
If we are unable to resolve your concerns, you have the right to contact a data privacy supervisory authority in the country where you live or work, or where you consider that the data protection rules have been breached or seek a remedy through the courts.
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