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DAI Privacy Policy - Doctor’s Associates Inc.
Milford, Connecticut, USA  

Table of Contents

  1. Scope of This Privacy Statement
  2. Consent
  3. Consent to Share and Disclose Personal Information, Including International Data Transfers
  4. Consent to Electronic Notice If There is a Security Breach
  5. DAI’s Use of Your Personal Information and Type of Personal Information DAI May Collect
  6. Personal Information DAI Collects That You Provide to DAI
  7. Internet Users – Cookies, Internet Protocol (IP) Address, Aggregate Information
  8. Compliance with the Digital Advertising Alliance
  9. Interest-Based/Online Behavioral Advertising
  10. “Do Not Track”
  11. DAI’s Collection of Personal Information Regarding Children
  12. A Note to Parents/Guardians—Additional Information About Children’s Privacy
  13. DAI’s Collection and Use of Employee Personal Information
  14. Verifications of Employment
  15. Medical Information
  16. DAI’s Collection and Use of SUBWAY® Franchisee and Prospective Franchisee Personal Information
  17. DAI’s Collection and Use of Development Agent Personal Information
  18. Mobile Information
  19. Mobile Marketing Promotions and Advertising
  20. Forward-To-A-Friend and Refer-A-Friend
  21. Third Party Service Providers/Processors
  22. Opt-in/Opt-out of Email Updates
  23. DAI’s Sharing of Your Personal Information
  24. DAI’s Website Security
  25. Storage, Retention and Accuracy of Personal Information
  26. Access, Control, and Update Your Personal Information
  27. DAI’s Privacy Officer Contact Information
  28. Links to Non-DAI Websites and Third-Party Websites
  29. DAI’s Use of Social Media and Online Engagement
  30. Promotion, Sweepstakes, etc.
  31. Your California Privacy Rights
  32. U.S. – EU and the U.S. - Swiss Safe Harbor Compliance
  33. Residents of the European Union, European Economic Area, and Switzerland
  34. International Privacy Statements
  35. Changes to DAI’s Privacy Statement
  36. Terms and Conditions of DAI Website Use

1. Scope of This Privacy Statement - (Top)

Your privacy is very important to DAI. This Privacy Statement discloses how Doctor’s Associates Inc., (“DAI”) collects, protects, uses, and shares Personal Information gathered about you. DAI’s privacy practices are consistent with::

  • The Federal Trade Commission’s Fair Information Practice Principles (FIPPs).
  • The Organization for Economic Co-operation and Development (OECD) Privacy Principles.
  • The U.S.-EU and U.S.-Swiss Safe Harbor Frameworks Privacy Principles of: Notice, Choice, Onward Transfer (Transfers to Third Parties), Security, Data Integrity, Access, and Enforcement.
  • The Asia Pacific Economic Cooperation forum (APEC) Privacy Framework.
  • The Personal Information Protection and Electronic Documents Act ("PIPEDA"), the Ten Privacy Principles developed by the Canadian Standards Association and incorporated into the Canadian Federal privacy legislation, as well as Provincial Privacy Laws.
  • All applicable country, national, state, and local Data Protection and Security Laws (some country’s laws require country specific information in a Privacy Statement.

Franchise World Headquarters, LLC (“FWH”) operates and hosts the Website (the “Website”) located at: www.subway.com, whose servers are located in the United States of America (“USA”). FWH provides core business related services such as, but not limited to: sales, research and development, marketing franchises, franchisee training, retail technology, POS system support, store design, legal and accounting services, to the SUBWAY® franchising entities. FWH is licensed to use the SUBWAY® trademark. Doctor’s Associates Inc. (“DAI”), owns the trade name and service mark SUBWAY®, the recipes, formulas, food preparation procedures, business methods, business forms, and business policies. DAI is the franchisor of the SUBWAY® system for the USA and its territories (Puerto Rico (“PR”) and Guam), and does business as "SUBWAY", as well as, licenses the SUBWAY® trademark and SUBWAY® Restaurant System to its affiliates in order to develop SUBWAY® restaurants worldwide.

FWH and DAI may share information, including Personal Information with its affiliates, the SUBWAY® franchisors including, but not limited to: Subway International B.V. (“SIBV”) the franchisor of the SUBWAY® system for Europe (and the rest of the world, outside of the United States, Australia, Canada, Colombia, Brazil, South Africa, and India), Subway Systems Australia Pty Ltd (“SSA”), Subway Franchise Systems of Canada, Ltd. (“SFSC”), Subway Partners Colombia C.V. (“SPCCV”), Subway Systems do Brasil Ltda. (“SSB”), Sandwich and Salad Franchises of South Africa Pty Ltd. (“SSFSA”), and Subway Systems India Private Limited (“SSIPL”). PT Subway Systems Indonesia (“PTSSI”) is a service company which provides business related services exclusively to Indonesia’s SUBWAY® franchisees, for and on behalf of SIBV, the franchisor for Indonesia. FWH, DAI, SIBV, SSA, SFSC, SPCCV, SSB, SSFSA, SSIPL, and PTSSI are collectively referred to herein as the “SUBWAY® Group”.

The SUBWAY® Group, may share information, including Personal Information with the SUBWAY® Group’s real estate affiliate, Subway Real Estate, LLC (“SRE”) and its leasing affiliates, in assisting SUBWAY® franchisees by negotiating real estate leases, administering the leases and lease renewals, and subleasing all SUBWAY® restaurant premises to SUBWAY® franchisees worldwide, which includes, but is not limited to: Subway Real Estate Corp. (“SREC”), Subway Realty of the Netherlands B.V., Subway Realty of the Netherlands B.V. Merkezi Hollanda Istanbul Merkezi Subesi (branch), Subway Realty of the Netherlands B.V. Hong Kong (branch), Subway International B.V. – Taiwan Branch, Subway International Equipment Leasing B.V., Subway Realty Limited, (“SRL”) - UK, Subway of Ireland Limited, Subway Partners Realty N.V. - Curacao, Subway Realty de Venezuela, C.A., Subway Real Estate Limited – New Zealand, Subway Realty de Mexico, S.A. de C.V., Subway Real Estate of France S.A.R.L., Subway Vermietungs – und Servicegesellschaft mbH - Germany, Subway Vermietungs – und Servicegesellschaft mbH - Czech Republic, Subway Realty of Spain, S.L., Subway Realty of Italy S.r.l., Subway Subs of Sweden AB, Subway Realty do Brasil, Ltda,, and Subway Equipment Leasing, S.A. de C.V. – El Salvador. The above realty entities are collectively referred to herein as the “SUBWAY® Realty Group”.

The SUBWAY® Group may share information, including Personal Information with the SUBWAY® Group’s advertising affiliate, Stichting Admininistratiekantoor Subway Franchisee Advertising Fund Trust, which is a Netherlands Foundation (the “SFAFT Foundation”), located at: Prinsengracht 13, 1015 DK Amsterdam, The Netherlands. The SFAFT Foundation determines how the SUBWAY® franchisees advertising contributions should be allocated, and creates the spending policies and procedures with respect to the promotion of the SUBWAY® brand in all regional and local markets, for the benefit of the SUBWAY® franchisees, as well as the SFAFT Foundations affiliates, who operate as the advertising entities for the benefit of the SUBWAY® franchisees worldwide, 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. Subway Systems Singapore Pte. Ltd. (“SSSPL”), 67 Beach Road, #03-01 / 02 Bulkhaul House, Singapore 189688. Subway International De Mexico, S.A. de C.V., c/o Eugenia No. 13 Int 601, Col. Nápoles, C.P. 03810, Benito Juarez, Mexico D.F. Subway Franchisee Advertising Fund Trust B.V. Sucursal Argentina, c/o Marval, O”Farrell & Mairal, AV. Leandro N. Alem 928, C1001AAR Buenos Aires, Argentina. Subway Systems do Brasil Ltda. (Representative Office), c/o Gouveia E Silveira Advogados, Av. Nove de Julho 4954, São Pau7lo SP, 01406-200, Brazil. Subway Brand Management & Consultant (Shanghai) CO. LTD., 560 Zhangyang Rd, Room 1706, Shanghai 200122, China Subway Partners Colombia C.V., c/o Pamiagua & Tovar Abogados S.A., Calle 107 A No. 11 A-69, Bogota, D.C. Colombia. Subway Systems India Private Limited, Level 2 Elegance, Mathura Road, Jasola, New Delhi 110025 India. Subway International B.V. (Taiwan Branch), Polaris 1A International, 8F-3, No. 43, Aly. 6, Ln. 182, Sec 4, Chenggong Road, Neihu District, Taipei City 114 Taiwan. Subway Realty de Venezuela, C.A., c/o Monahan Mijares & Asociados, Avenida Las Acacias, Torr La Previsora, 10th Floor, Sabana Grande, Caracas 1050 Venezuela. The FAF Group administers national and local advertising funds and activity for SUBWAY® restaurants and SUBWAY® franchisees worldwide. The above advertising entities are collectively referred to herein as the “FAF Group”.

The SUBWAY® Group and its affiliates within the FAF Group, may share information, including Personal Information, with third-party service provider, Value Pay Services LLC (“VPS”) which is a wholly owned subsidiary of the Independent Purchasing Cooperative, Inc. (“IPC”). The IPC and its affiliates including, but not limited to: the 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”), are member owned and operated entities composed of all SUBWAY® franchisees located in the following geographical areas: the United States of America (“USA”) and its territories, Canada and its provinces, the European Economic Area (“EEA”) and Switzerland, Latin America and the Caribbean, Australia and New Zealand, and the Middle East. The IPC as all as its wholly owned subsidiary VPS, EIPC, LACIPC, IPCA, MEIPC, are collectively referred to herein as the “Co-op Group”.

The SUBWAY® Group and its affiliates within the FAF Group and/or the Co-op Group, may share information, including Personal Information with third-party service provider, Customer Portfolios LLC (“CP”), located in Boston, Massachusetts, USA, in order to send you specific information or materials regarding consumer facing programs, that you requested when you chose to opt-in and receive further information from either the SUBWAY® Group, the FAF Group, or the Co-op Group, either by email, SMS, fax, and/or physical mail, regarding the SUBWAY® brand including, but not limited to: subscription services, promotions, SUBWAY® news and/or newsletters, and various other offers.

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 our SUBWAY® customers, employees, job applicants, and other visitors to DAI’s websites who may choose to provide Personal Information. DAI recognizes the need for appropriate protections and management of Personal Information that you provide to DAI. This Privacy Statement will assist you to understand what types of Personal Information DAI may collect, how your Personal Information may be used, and with whom your Personal Information may be shared with. This Privacy Statement explains DAI’s privacy practices and procedures regarding the Personal Information collected from users of DAI’s websites located at: www.subway.com. DAI is the franchisor licensed to sell SUBWAY® restaurants in the USA and its Territories.

In an effort to comply with the law, and our commitment to protect your Personal Information, DAI provides the following, which discloses DAI’s privacy practices and procedures. Please note, this Privacy Statement does not govern the privacy practices and procedures of independently owned and operated SUBWAY® restaurants. Nor does this Privacy Statement govern the Personal Information handling practices and procedures of its affiliates within the SUBWAY® Group, the FAF Group, the SUBWAY® Realty Group, and/or the Co-op Group. DAI encourages you to review its affiliates respective Privacy Statements which discloses each company’s privacy practices and procedures. For your convenience, DAI has provided links to DAI, FWH, and SFAFT’s individual Privacy Statements, as well as, the SUBWAY® Privacy Notice which includes, but is not limited to, the SUBWAY® Group’s individual franchisor Privacy Statements located at:

DAI: http://www.subway.com/subwayroot/PrivacyPolicy-DAI.aspx
FWH: http://www.subway.com/subwayroot/PrivacyPolicy-FWH.aspx
SFAFT: http://www.subway.com/subwayroot/PrivacyPolicy-SFB.aspx
PRIVACY NOTICE: http://www.subway.com/subwayroot/privacyNotice.aspx

2. Consent - (Top)

This Privacy Statement applies to all Personal Information gathered for and on behalf of DAI, whether in writing, verbally, or electronically, through any website operated by or on behalf of DAI, including, but not limited to: www.subway.com, together with any and all future websites (the “websites”) operated by or on behalf of DAI. By using the websites, or participating in any program or service managed by or on behalf of DAI, you consent to the data practices described in this Privacy Statement.

BY SUBMITTING PERSONAL INFORMATION TO DAI , AND/OR BY ACCESSING AND USING THE WEBSITE, YOU AGREE TO DAI ’S COLLECTION, USE, AND DISCLOSURE OF SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY STATEMENT AND THE WEBSITE TERMS AND CONDITIONS AS PERMITTED OR REQUIRED BY LAW. YOU CONSENT TO RECEIVE REQUIRED NOTICES (IF ANY) AND YOU ATTEST THAT YOU ARE AT LEAST EIGHTEEN (18) YEARS OF AGE. IF YOU DO NOT CONSENT TO THE COLLECTION, STORAGE, USE, DISCLOSURE, TRANSFER, AND OTHER PROCESSING OF YOUR PERSONAL INFORMATION, PLEASE DO NOT ACCESS, BROWSE, OR USE THIS WEBSITE.

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

3. Consent to Share and Disclose Personal Information, Including International Data Transfers - (Top)

In addition to consenting to DAI’s Privacy Statement, Terms and Conditions, as well as any relevant supplemental policies, you expressly consent to DAI sharing the Personal Information that you have provided to DAI, as described herein. DAI 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. DAI may also share your Personal Information with companies that provide support services to DAI, 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, DAI does not control these companies nor does DAI authorize these companies to use your Personal Information that DAI may share with them, for any reason other than the purpose for which DAI hired them. You agree that DAI 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 DAI’s operations and programs.

4. Consent to Electronic Notice If There Is a Security Breach - (Top)

If DAI or a Recipient is required to provide notice of unauthorized access of certain security systems, you agree that DAI, or the Recipient, may do so when required or voluntarily by posting notice on the website or sending notice to any email address DAI or the Recipient has for you, in the good faith discretion of DAI or the Recipient. You agree that notice to you will count as notice to any other individual for whom you are acting and agree to provide the notice to any such individual.

5. DAI's Use of Your Personal Information and Type of Personal Information DAI May Collect - (Top)

We use your Personal Information to facilitate the services you request. We have tailored our Privacy Statement to adequately advise you of the use of your Personal Information.

Personal Information is defined as any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, by reference to a Social Security Number and/or Identification Number (hereinafter “SSN/I.N”) or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

Personal Information shall include, but is not limited to: name (full name or first initial and last name), maiden name, nickname, email address, home address, home zip code and/or 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, such as, but not limited to: eye, skin, and hair color, facial features, personal marks such as tattoos, birthmarks, moles and scars) video and/or voice recording, financial information, employment related information, such as, but not limited to: personal information that may be found on resumes, applications, background verification information, or in employment references.

DAI 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. DAI 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 PERSONAL INFORMATION

Sensitive Personal Information is information that can include but is not limited to, an individual’s gender, racial or ethnic origins, politics, religion, trade union membership, veteran status, physical or mental health, disabilities, sex life, sexual orientation, or criminal (or alleged criminal) activities, proceedings or convictions. DAI will never collect Sensitive Personal Information except to comply with Affirmative Action data requirements.

6. Personal Information DAI Collects That You Provide to DAI - (Top)

DAI will not collect customer Personal Information, unless the customer contacts DAI directly. In order to adequately address a customer’s concerns, your Personal Information may be shared with the appropriate DAI affiliates, such as, but not limited to: the SUBWAY® Group, the FAF Group, SUBWAY® Development Agents (“DA”) for your geographical area, and/or relevant SUBWAY® franchisees, as well as, third-party service providers.

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 Personal 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:

  • Consumer facing programs, including but not limited to: subscription services, email information, newsletters, and news and offers, are sent to you by our third-party service provider, Customer Portfolios, LLC, located in Boston, Massachusetts, USA.
  • User registration, such as access to: www.subway.com, member or non-public member pages.
  • Financial Transaction Information, such as, ordering from: http://shop.subway.com/, operated by Franchise Shipping Center Company, Inc. (“FSC”);
  • Placing a catering order or signing up for a SUBWAY® Card with our third-party service providers, IPC and/or VPS at: www.mysubwaycard.com,  Subway Express™, www.tellsubway.com, and www.subwaycatering.com, operated by VPS.
  • Various Contest, Promotions, Competitions, and Sweepstakes.
  • Surveys and/or Voting.

Upon entering your Personal Information regarding any of the above, the SUBWAY® Group and DAI’s third-party service providers, are contractually obligated to provide the same level of guarantees regarding the confidentiality and security of your Personal Information, as well as, to allow for oversight, monitoring, and auditing of the services being provided. DAI does not divulge User ID and Passwords to anyone internally or externally. Please note, when entering a Promotion, Sweepstakes, etc., DAI urges you to review the Promotion, Sweepstakes, etc., Official Rules as well as, the Privacy Statement specific to the Promotion, Sweepstakes, etc., that you entering.

From time to time, photos may be taken and used for marketing and/or promotional purposes which may include, but is not limited to: images of franchised restaurants, franchisees, SUBWAY® employees, employees of SUBWAY® franchisees, and/or SUBWAY® customers, from which individuals may be able to be identified. As a SUBWAY® employee, your photo may be used within DAI to identify you, including by being electronically attached to your email address.

7. Internet Users - Cookies, Internet Protocol (IP) Address, Aggregate Information - (Top)

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 website and services.

A few important things you should know about cookies are that:

  • DAI offers certain features that are available only through the use of cookies..
  • DAI uses cookies to better your website experience.
  • Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session.
  •  You may encounter cookies from third-parties on certain pages of the websites that DAI does not control. (For example, if you view a web page created by another user, there may be a cookie placed by that web page.)

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 DAI’s website if cookies are disabled.

Flash Cookies - If you use DAI’s website and it uses Macromedia Flash Player, a small Flash Cookie may be used. The purpose of using these cookies is to store your flash player preferences and enhance your browsing experience.

Flash Cookies are stored on your computer in a similar way that standard cookies store cookies on your computer, except they are stored in a different location. Due to this, it is not possible to block or manage Flash Cookies directly from your browser.

In order to manage or delete Flash Cookies, please visit Adobe's website, which provides full information by clicking here: https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

Web Beacon - Also called a web bug or a pixel tag or a clear GIF. DAI uses pixel tags or transparent GIF files, to help manage DAI’s online advertising and promotions. These tags collect anonymous (not personally identifiable) information about which advertisements and promotions bring users to DAI’s website. With both cookie and tag technology, the information that DAI collects and shares is anonymous and not Personal Information. 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 email that is used to monitor the behavior of the user visiting the website or sending the email. When the HTML code for the web beacon points to a website 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 website. 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 website. 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. DAI may use your IP address to help diagnose problems with DAI’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. DAI 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 DAI administers, DAI will rely upon aggregate information, which is information that does not identify you, such as statistical and navigational information. With this aggregate information, DAI may undertake statistical and other summary analyses of the visitors' behaviors and characteristics. Although DAI 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.

8. Compliance with the Digital Advertising Alliance - (Top)

The SUBWAY® Group uses the Evidon assurance platform to comply with the cross-industry Self-Regulatory Program for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA) (http:///aboutads.info). As part of this service, the SUBWAY® Group’s online advertisements and websites are sometimes delivered with icons that help consumers understand how their data is being used and provide choice options to consumers that want more control. The list of our advertising partners may be updated from time to time. To opt-out of internet-based advertising by all DAA-participating companies, please visit http://www.aboutads.info/choices/.

9. Interest-Based/Online Behavioral Advertising - (Top)

On some pages of our website we may allow third-party advertising partners to set web tracking tools (e.g., cookies and web beacons) to collect anonymous, Non-Personal 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®) websites 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.

Opt-out (website 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-Personal Information regarding your website activities and use it for non-interest-based advertising purposes as described in this privacy statement.

Opt-out (advertisements). Advertisements on third-party websites that contain the AdChoices link and that link to this Privacy Statement may have been directed to you based on anonymous, Non-Personal 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.

10. “Do Not Track” - (Top)

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. DAI is committed to providing you with meaningful choices about the information collected on our website for third-party purposes, and that is why DAI provides the DAA opt-out link above. However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. To find out more about "Do Not Track," you may wish to visit http://www.allaboutdnt.com.

11. DAI’s Collection of Personal Information Regarding Children - (Top)

This website is not targeted towards children under the age of thirteen (13). DAI does understand that children under the age of thirteen (13) may still try to contact DAI and in so doing may voluntarily provide Personal Information on DAI’s website located: www.subway.com. If you are a child under the age of thirteen (13) PLEASE, DO NOT submit any Personal Information about yourself on DAI’s website located: www.subway.com  WITHOUT FIRST GETTING PERMISSION FROM YOUR PARENT(S) OR GUARDIAN(S).

Children’s privacy is very important DAI. DAI’s servers are located in the USA and its territories, PR and Guam. DAI adheres to the Children's Online Privacy Protection Act (“COPPA”), a United States Federal Law. 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. DAI will not knowingly allow anyone under thirteen (13) years of age to provide us with any Personal Information about themselves (such as their names, email address, and phone number) over the Internet. If a child has provided DAI with Personal Information without the consent of a parent, we ask the parent of that child to contact DAI’s Privacy Officer immediately at: privacyofficer@subway.com. DAI will use all reasonable efforts to promptly delete the child's Personal Information from our servers. Please note, that when DAI uses the term "parent", we mean to include legal guardians.

12. A Note to Parents/Guardians—Additional Information about Children’s Privacy - (Top)

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 DAI 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, DAI may ask children to provide us with Personal Information. The types of Personal Information DAI may request includes: first name as well as the child’s and parent’s email addresses. DAI only uses 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). DAI only uses a parents’ email address to obtain their consent or notify them of their child's online activities and enable the parent to unsubscribe their child from a newsletter or other similar activity.

Sometimes, DAI uses third-party service providers to help DAI 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 DAI’s Privacy Statement. As such DAI’s third-party service providers are required to keep Personal Information confidential and to use it only for the specific services they are performing on DAI’s behalf.

At any time parents can refuse to permit DAI to collect further Personal Information from their child and can request that any Personal Information collected from their child can be deleted from DAI’s records. DAI will provide parents notice by email of any material changes in the way DAI intends to collect, use, and/or share their child’s Personal Information. Please note, parents should keep their email address which they provided to DAI current at all times.

If you would like to review any Personal Information that DAI has collected online from your child, have your child’s Personal Information deleted, if you have questions about DAI’s privacy practices and procedures, and/or would like to request that there be no further collection or use of your child's Personal Information, please contact DAI’s Privacy Officer at:

DAI Privacy Officer
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

13. Collection and Use of Employee Personal Information - (Top)

If you submit an application for employment with DAI, DAI may need to obtain Personal Information about you from third-parties in order to supplement, update, verify your information, and/or to process your application for consideration as a DAI employee. Applicable law may require that you authorize a third-party to share your Personal Information with DAI before we can acquire it. Failure to provide any requested information may negatively impact consideration of your employment application. By applying to become an employee of DAI you consent to our collection, use, and disclosure of your Personal Information in this manner.

Personal Information collected from employees and applicants is limited to administration of Human Resources programs and functions, which include, but are not limited to: job applications and hiring programs, compensation and benefit programs, performance appraisals, training, access to DAI and its affiliates facilities and computer networks, employee profiles, internal intranet employee directories, Human Resource recordkeeping, and other employment related purposes.

It is the policy of DAI to keep all past and present employee information private from disclosure to third parties, accept for where there are certain business related exceptions, such as:

  1. To comply with all county, state or federal agency requests;
  2. 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);
  3. Third-parties with which DAI has contractual agreements to assist in administration of company sponsored benefits.

Please note that this Privacy Statement does not apply to SUBWAY® restaurant employment applications submitted through the SUBWAY® website, which may be shared with independently-owned and operated franchisees who are seeking employees in their market area.

14. Verifications of Employment - (Top)

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.

15. Medical Information - (Top)

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.

16. DAI’s Collection and Use of SUBWAY® Franchisee and Prospective SUBWAY® Franchisee Personal Information - (Top)

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 DAI may disclose your Personal Information to our affiliates within the SUBWAY® Group, the FAF Group relevant SUBWAY® DA’s, as well as, certain third-party service providers as part of the SUBWAY® Group’s consideration of your franchise inquiry, in order 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. All information, including Personal Information submitted by you on the Application for Additional Franchise Information form will become part of your franchise file should you choose to proceed and submit a franchise application. DAI requires our affiliates, as well as, DAI’s third-party service providers which may include companies that provide support services to DAI, such as, but not limited to: agents, consultants, contractors, marketing agencies, credit card processors, mailing houses, web hosts, technical support providers, and fulfillment centers, to respect DAI’s privacy practices and procedures and not use your Personal Information for any purpose other than to carry out DAI’s instructions.

Any potential franchisees Personal Information sent via: www.subway.com is stored on a server located in the USA. The server is owned and managed by DAI, based in the USA. Any information, including Personal Information stored on this server may be shared with:

  • DAI, the owner and licensor of the SUBWAY® system and the franchisor for the USA and its territories, PR and Guam. DAI is based in Milford, Connecticut.
  • DAI, which operates as a service-oriented company for and on behalf of the SUBWAY® System worldwide by providing core business related services, based in Milford, Connecticut, USA.
  • Subway Real Estate, LLC (“SRE”), based in Milford, Connecticut, USA, as well as its leasing affiliates for your geographical area.
  • Relevant DA’s for your geographical area.

DAI 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 all applicable laws. Your consent to such purpose(s) remains valid after termination of DAI’s relationship with you.

Websites - www.subway.com is hosted on a web server provided and managed by DAI, based in the USA. The content of: www.subway.com, including updates to the consumer content, is managed by DAI, based in Milford, Connecticut, USA. When you click on the links for Contact Us, Request a Brochure, Own a Franchise, and Submit a Site, you may be asked to fill out and submit a form which automatically redirects you to the official SUBWAY® website: www.subway.com, whose database is located in the USA. The domain name subway.com is owned by Doctor's Associates Inc.

SUBWAY® restaurants are owned and operated by franchisees, who are independent businessmen and women. Some franchisees may also operate websites and/or provide mobile device applications. These franchisee websites and/or apps are not operated by DAI, nor its affiliates within the SUBWAY® Group and/or the FAF Group, and are
not subject to DAI’s Privacy Statement. Please review the Privacy Statement of each franchisee website and/or mobile app to determine the privacy practices and procedures of their website.

Lastly, SUBWAY® restaurants are owned and operated by independent franchisees that are neither owned nor controlled by DAI or any other member of the SUBWAY® Group. Each SUBWAY® franchisee may collect Personal Information from their SUBWAY® customers and may use the Personal Information for their own purposes. DAI
does not control the use of this Personal Information, nor, does DAI have access to the Personal Information collected and held by SUBWAY® franchisees and/or their associates. SUBWAY® franchisees may also use email campaigns and other methods of electronic and/or direct mail solicitation without DAI’s consent or prior knowledge. The SUBWAY® franchisee is solely responsible for the content the email and/or direct mail campaigns, as well as, the methods of identifying and contacting you either by email or your physical mailing address.

17. DAI’s Collection and Use of SUBWAY® Development Agent Personal Information - (Top)

By applying to become a SUBWAY® DA via DAI’s website: www.subway.com, an applicant consents to the collection, use, and disclosure, of Personal Information in accordance with DAI’s Privacy Statement. DAI may collect your Personal Information on its website and use your Personal Information in order to assist you in applying, and evaluating you to become a SUBWAY® DA. Personal Information is collected to assist DAI and its affiliates within the SUBWAY® Group in selecting DA candidates and for the purpose of operating a development territory.

Personal Information collected may include, but is not limited to: name, home address, home telephone number, facsimile number, email address, date of birth, bank account information for Electronic Funds Transfer, financial statement, resume, taxpayer identification number and background checks. Once a DA candidate becomes a DA, they may then reference themselves by their DA Number. Failure to provide necessary information may negatively impact your ability to become a DA.

SUBWAY® DA’s and/or company territory offices may have the opportunity to set up and host their own website, which may provide best practices, resources and information to local franchisees and prospective franchisee prospects, as well as their own staff. The SUBWAY® DA’s and/or company territory office websites are owned and operated by the individual SUBWAY® DA’s and/or company territory offices, not by DAI, the SUBWAY® Group, and/or the FAF Group. DAI encourages you to review the individual SUBWAY® DA’s and/or company territory offices respective website Privacy Statement which discloses their full privacy practices and procedures. Please note, DAI’s Privacy Statement does not govern the Personal Information handling practices and procedures of individual SUBWAY® DA’s and/or company territory offices individual websites.

Finally, as a DA within the SUBWAY® Group certain business information with respect to stores within your territory may be shared in the aggregate amongst your DA community. Such business information may include, but is not limited to: 13 (thirteen) week Worldwide DA Development Activity Rankings, Store Level Key Initiatives Report, DA Stats Report, three (3) year DA Performance Report, Financial Strength Change Report, Monthly CPC Growth, 52 (Fifty-two) Week Worldwide DA Development Activity Rankings, Worldwide Profitability Report, Store Level Operations Overview, Emerging Market Developing Activity Report, Developed Market Report, Subway Compared to other QSR Report, and the Weekly Same Store AUV and Units Report.

18. 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. DAI 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.

DAI 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 websites, 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. DAI does not capture or store your login information or any other Personal 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

  • Web-enabled mobile applications may use cookies or web beacons and other methods to customize your browsing experience. Please see DAI's website Privacy Statement for more information.
  • Some mobile applications will utilize Google Analytics (or similar tool) to help us better serve our customers through improved products, services, and revisions to the mobile applications. This collected information will not identify you to DAI. It may, however, let us know anonymously, which services and features you are using the most within the application, as well as device type and hardware features, country and language of download.
  • Use of third-party services such as social sharing websites (e.g., Facebook and Twitter) is governed by the privacy practices of those services. DAI does not capture or store your login information or other Personal Information for these services, however session info or cookies may be stored.

Mobile Information Sharing

  • DAI does not share any collected information with third-parties with the following exceptions:
  • DAI may provide some personal data to third-party partners that are providing services essential to your mobile user experience.
  • All requests are sent through your mobile carrier's network and your carrier may have access to it. Consult your carrier's privacy policies for additional information.
  • Certain mobile products and services and manufacturers allow you to interact and share your information with others. For example, you may want to Tweet or post to your Facebook page content from a DAI mobile application. Consult your mobile device manufacturer, or mobile product or application developer's privacy policies for additional information.

19. Mobile Marketing Promotions and Advertising - (Top)

If you participate in any advertising or marketing promotions the Personal Information that you provide DAI will be handled in accordance with the Privacy Statement specific to said promotion which cannot and does not apply to DAI’s website Privacy Statement.

Wireless Promotional Opportunities - DAI may provide users and viewers with the opportunity to register for special promotions via mobile text messaging and other wireless devices. Users are required to provide their consent to receive such information from DAI, either by registering on DAI’s website or via your wireless device. Promotional opportunities may be provided by the SUBWAY® Group, the FAF Group, and/or DAI’s third-party service providers. The Personal 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 DAI and the user. Standard messaging rates will apply, unless noted otherwise. Under no circumstances will our website, DAI, 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 DAI 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 DAI at the time the message is sent, or by sending a text message that says "STOP", "END", "CANCEL", "REMOVE", "UNSUBSCRIBE" or "QUIT". DAI 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 DAI. If the user unsubscribes from one or all of DAI 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 - DAI 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.

20. Forward-To-A-Friend and Refer-A-Friend - (Top)

You may use a referral feature (either on a web page, in an email, from a banner ad, or other communication) to inform a friend about a DAI web page or promotion. DAI may use any email address provided when using this referral feature to send both an initial email and a subsequent email to recipients about the particular promotion, product, or service in which you indicated your "friend" may have an interest.

21. Third-Party Service Providers/Processors - (Top)

DAI may use the services of third-party processors, such as market researchers, fulfillment houses, email service providers, and mail houses that process mail and communications for DAI, its affiliates within the SUBWAY® Group and/or the FAF Group. These third-parties are contractually prohibited from using Personal Information for any purpose other than for the purpose DAI specifies.

22. Opt-in/Opt-out of Email Updates - (Top)

You may have the opportunity to Opt-in (which requires your express consent) and receive email communications from DAI, in order for you to receive specifically requested information or materials, such as, but not limited to: a coupon, newsletter, informational materials, marketing communications, or other special promotions or offers, from DAI, its affiliates within the FAF Group and/or the SUBWAY® Group. DAI's third-party service provider Customer Portfolios, LLC (“CP”), located in Boston, Massachusetts, United States of America (USA), manages the database of SUBWAY® customers which have expressly consented to receive specifically requested information or materials, on behalf of DAI. DAI will only email you if you opt-in to receive specific information or materials. If you opt-in to receive email communications from DAI, we may send you occasional updates about new additions to DAI's website, as well as, special offers and promotions of which you may take advantage. If at any time you decide you would rather not receive these types of email communications from DAI, you can opt-out by clicking the unsubscribe link at the bottom of any DAI email, update your contact preferences for your account, or contact DAI’s Privacy Officer at: privacyofficer@subway.com.

23. DAI’s Sharing of Your Personal Information - (Top)

DAI does not sell Personal Information to third parties. DAI may share Personal Information with our service providers, consultants and affiliates for our internal business purposes. Except as described in this Privacy Statement, 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 may share your Personal Information with agents, affiliates or service providers who act for or on behalf of DAI in connection with the business of DAI, 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. DAI requires our agents, affiliates and service providers to agree in writing to maintain the confidentiality and security of Personal Information they maintain on behalf of DAI and not to use it for any purpose other than the purpose for which DAI retained them. DAI may also require any third-parties we retain to protect Personal Information disclosed by DAI in accordance with all applicable privacy requirements and the general privacy principles described in DAI’s Privacy Statement.

The Personal Information you provide DAI 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 DAI or of any of the business assets or shares of DAI or a division thereof, in order for a customer to continue to receive the same products and services from the third-party.

Although DAI makes every effort to preserve user privacy, DAI reserves 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 DAI policies or contracts, to collect amounts owed to DAI, to protect users of DAI’s websites from fraudulent or abusive use, during emergencies when safety is at risk, as determined by DAI, 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 website. In such cases, server log data, containing IP addresses, would be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

As described above, DAI, its affiliates within the SUBWAY® Group, third-party service providers, and SUBWAY® DA’s may share and exchange Personal Information in order to process franchisee applications, administer the SUBWAY® franchise system, and protect the integrity of the SUBWAY® franchise system and trademarks. Personal Information may be provided to a courier or freight forwarder to fulfill an order, which may have been requested from DAI.

DAI’s affiliates and third-party service providers, are prohibited from using Personal Information, provided by you to DAI, for any purpose other than to provide assistance to DAI. DAI’s affiliates and third-party service providers are required by DAI to protect any Personal Information provided by you to DAI and disclosed to DAI’s affiliates and third-party service providers as well as, to comply with the general privacy principles described in this Privacy Statement.

24. DAI’s Website Security - (Top)

DAI endeavors to protect your Personal Information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our control. DAI safeguards your Personal Information on the Internet by using industry-standard practices. Although "guaranteed security" does not exist either on or off the Internet, DAI makes commercially reasonable efforts to make the collection and security of such information consistent with our Privacy Statement and all applicable laws and regulations.

Currently, DAI’s website utilizes a variety of different security measures designed to protect Personal Information by users both inside and outside DAI, including the use of encryption mechanisms (e.g., Secure Socket Layers or SSLs), password protection, and other security measures to help prevent unauthorized access to your Personal Information. This helps maintain the confidentiality, privacy, and integrity of your transactions, and helps to protect your confidential information - such as credit card numbers, online forms and financial data, from loss, misuse, interception and hacking.

Phishing- Identity theft and the practice currently known as “phishing” are of great concern to DAI. 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 email or telephone communication. For more information about phishing, please visit the Federal Trade Commission’s website at: http://www.consumer.ftc.gov/articles/0003-phishing.

25. Storage, Retention, and Accuracy of Personal Information - (Top)

All reasonable steps are taken to safeguard your Personal Information against loss, unauthorized access, use, modification, disclosure, or any other misuse. DAI takes all reasonable steps to insure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading. 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 all applicable laws. Your consent to such purpose(s) remains valid after termination of DAI’s relationship with you.

DAI may store your Personal Information in its databases located in the USA and/or other countries outside of the USA. Additionally, some of DAI’s service providers may be located in the USA or other countries outside of the USA and will be subject to the applicable laws of the local jurisdiction. As a result, in certain circumstances, the USA and other foreign governments, courts, law enforcement agencies, or regulatory agencies may be entitled to access the Personal Information which was collected about you and is held by DAI.

26. Access, Control, and Update Your Personal Information - (Top)

You may contact DAI’s Privacy Officer to access, correct or delete your Personal Information. If necessary, DAI’s Privacy Officer will contact another individual to assist in completing your requested task. DAI wants to be sure that we keep only the most accurate and up-to-date Personal Information in our records. You can email DAI’s Privacy Officer at: privacyofficer@subway.com, to update your contact information. To protect your privacy, DAI will take all reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

27. DAI's Privacy Officer Contact Information - (Top)

If after reviewing this Privacy Statement, you would like to submit a request or you have any questions or privacy concerns, please contact DAI’s Privacy Officer at:

DAI 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

Where allowed by law, you may also use the above email or postal address to request access to Personal Information held about you by DAI. Such requests will be processed in line with local laws, and there may be circumstances where DAI is unable to provide access where it is legally permissible to do so, including where the information contains legal privilege, is a security risk, would compromise others’ privacy, or where it is commercially proprietary. You may also ask DAI to update Personal Information we hold about you where you believe it is incomplete, inaccurate or out of date.

Please note, DAI will address your concerns and attempt to resolve any privacy issues in a timely manner.

Or, you can download the Privacy Information Request Form located at: http://www.subway.com/subwayroot/InfoRequestForm.pdf.

28. Links to Non-DAI Websites and Third-Parties - (Top)

Please note that DAI’s website: www.subway.com may contain links to other websites for your convenience and information. DAI does not control those websites or their privacy practices, which may differ from www.subway.com. DAI’s Privacy Statement cannot and does not apply to external websites. DAI does not endorse or make any representations about third-party websites. The Personal Information you choose to give to unrelated third-parties is not covered by the DAI Privacy Statement. DAI encourages 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 Information with DAI; that sharing is governed by that third-party company’s Privacy Policy, not, DAI’s Privacy Statement.

29. DAI’s Use of Social Media and Online Engagement - (Top)

The SUBWAY® Group, may use a variety of new technologies and Social Media options to communicate and interact with SUBWAY® consumers. These Social Media websites and applications include popular social networking and media websites, open source software communities, and more. To better engage the public in ongoing dialog, the SUBWAY® Group and/or their Authorized Social Media Representative, use several third-party platforms including, but not limited to: Facebook, Twitter, YouTube, Foursquare, Google+, Pinterest, Instagram, LinkedIn, etc. Third-Party Websites and Applications (TPWA) are web-based technologies that are not exclusively operated or controlled by the SUBWAY® Group and/or their Authorized Social Media Representative. When interacting with the SUBWAY® presence on those websites, you may reveal certain Personal Information to the SUBWAY® Group and/or their Authorized Social Media Representative, or to other third-parties. Except when used by the SUBWAY® Group’s and/or their Authorized Social Media Representative’s employees for the purpose of responding to a specific message or request, the SUBWAY® Group and/or their Authorized Social Media Representative, will not use, share, or retain your Personal Information.

At this time, the SUBWAY® Group has three (3) Social Media Accounts:

Facebook: https://www.facebook.com/subway 
Twitter: https://twitter.com/subway
YouTube: http://www.youtube.com/subway

Facebook: On the: https://www.facebook.com/subway  Facebook page, the SUBWAY® Group and/or their Authorized Social Media Representative, may post news and other items of interest to individuals. If you have a Facebook account or 'Like' our Facebook page at: https://www.facebook.com/subway, you can post comments or click on the 'like' option for individual entries. If you post comments or click on the 'like' button, your Personal Information may be visible to the SUBWAY® Group and/or their Authorized Social Media Representative, as well as other Facebook website visitors. The amount of visible Personal Information will depend on your own Facebook privacy settings. You can completely avoid displaying any Personal Information by not creating an account, not posting comments, and not clicking the 'like' option on the official SUBWAY® Facebook page. The SUBWAY® Group and/or their Authorized Social Media Representative, does not collect, use, or disclose any Personal Information about visitors who comment or 'like' the SUBWAY® Facebook page. Facebook collects and reports on Non-Personal Information about activities on Facebook pages. This information is password protected and only available the SUBWAY® Group and/or their Authorized Social Media Representative’s designated staff, who require this information in order to perform their duties. The Facebook Privacy Policy is available at: http://www.facebook.com/about/privacy/.

Twitter: The SUBWAY® Group and/or their Authorized Social Media Representative, 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 official SUBWAY® Twitter feeds without subscribing to them, visitors who want to subscribe to (or follow) the official SUBWAY® 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 and/or their Authorized Social Media Representative’s designated staff, monitor the number of subscribers and respond to comments and queries via Twitter, but the SUBWAY® Group and/or their Authorized Social Media Representative’s designated employees never takes possession of the Personal Information which belongs to any SUBWAY® Twitter followers. The SUBWAY® Group and/or their Authorized Social Media Representative’s designated staff, does not collect, maintain, disclose, or share any Personal Information about the people who follow SUBWAY® on Twitter. The Twitter Privacy Policy is available at: http://twitter.com/privacy.

YouTube: The SUBWAY® Group and/or their Authorized Social Media Representative, post videos on YouTube in order 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-Personal Information about its website 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 website 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 website use will not be associated with you or your YouTube account. The YouTube Privacy Policy is available at: http://www.youtube.com/t/privacy.

SUBWAY® Franchisees may have the opportunity to sponsor their own social media pages, such as, but not limited to: Facebook, Twitter, YouTube, Foursquare, Google+, Pinterest, Instagram, LinkedIn, etc.

Please note: the Privacy Policies of individual SUBWAY® Franchisees Social Media pages are located on the individual SUBWAY® Franchisees website. This Privacy Statement does not govern the Personal Information handling practices and procedures of individual SUBWAY® Franchisees Social Media pages and their individual websites.

30. Promotion, Sweepstakes, etc. - (Top)

DAI may operate sweepstakes, contests, raffles and similar promotions through the website that may require online registration. DAI typically asks you for certain Personal Information when you enter and, if applicable, Promotion, Sweepstakes, etc. DAI may share this Personal Information with third-party sponsors of such Promotion, Sweepstakes, etc., (irrespective of whether it is hosted by DAI), or otherwise in accordance with the rules applicable to such Promotion, Sweepstakes, etc. You should carefully review the rules of each Promotion, Sweepstakes, etc., in which you participate through the website, as they may contain additional important information about DAI's or a sponsors use of your Personal Information. Insofar as the terms and conditions of such rules concerning the treatment of your Personal Information may conflict with this Privacy Statement, the terms and conditions of such rules shall control.

31. Your California Privacy Rights (As provided by California Civil Code Section 1798.83) - (Top)

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.

32. U.S. – EU and the U.S. - Swiss Safe Harbor Compliance - (Top)

DAI, 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. DAI has been Self-Certified under the Safe Harbor privacy frameworks as set forth by the U.S. Department of Commerce, European Commission and Federal Data Protection and Information Commissioner of Switzerland regarding the collection, storage, use, transfer and other processing of personal data transferred from the European Economic Area or Switzerland to the U.S., in accordance with Directive 95/46/EC of the European Parliament, and the Swiss Federal Act on Data Protection (FADP) effective July 1993, modified January 2008. Organizations that Self-Certify under Safe Harbor must comply with the U.S. – EU and the U.S. - Swiss “Safe Harbor” Frameworks Privacy Principles which are

  • Notice - Individuals must be informed that their data is being collected and about how it will be used;
  • Choice - Individuals must have the ability to opt out of the collection and forward transfer of the data to third parties;
  • Onward Transfer (Transfers to Third Parties)- Transfers of data to third parties may only occur to other organizations that follow adequate data protection principles;
  • Security - Reasonable efforts must be made to prevent loss of collected information;
  • Data Integrity - Data must be relevant and reliable for the purpose for which it was collected;
  • Access - Individuals must be able to access information held about them, and correct or delete it if it is inaccurate;
  • Enforcement - There must be effective means of enforcing these rules.

Further information regarding the “Safe Harbor” Frameworks privacy principles and certification process can be found at: www.export.gov/safeharbor.

In addition, the U.S. Department of Commerce maintains lists of compliant organizations (i.e., the U.S.-EU Safe Harbor List and the U.S.-Swiss Safe Harbor List), which can be accessed at: http://safeharbor.export.gov/list.aspx and https://safeharbor.export.gov/swisslist.aspx.

DAI uses a self-assessment approach to assure compliance with this Privacy Statement and periodically verifies that this Privacy Statement is accurate, easily accessible, prominently displayed, abides by, and contains the information intended to be covered by the Safe Harbor Frameworks, as stated above.

If you are a resident of the European Economic Area (“EEA”) or Switzerland and have any questions, concerns, or complaints, regarding DAI’s use or disclosure of your Personal Information, and compliance with the Safe Harbor Frameworks, please contact DAI’s designated Privacy Officer at: privacyofficer@subway.com. DAI’s Privacy Officer will investigate and attempt to resolve any complaints or disputes regarding the use and disclosure of your Personal Information, in compliance with any applicable Data Protection Laws, which may be required by various local, state, federal, or international laws, regarding any and all websites operated by and on behalf of DAI.

If a complaint or dispute cannot be resolved through DAI’s internal process, DAI has agreed to participate in the dispute resolution procedures established by the EU Data Protection Authorities (DPAs) to resolve disputes pursuant to the U.S. – EU Safe Harbor Privacy Principles in respect to Personal Information received from the EEA. DAI has also agreed to cooperate and comply with any advice given by the Information Commissioner of Switzerland in the investigation and resolution of complaints brought under the U.S. – Swiss Safe Harbor Privacy Principles. The EU DPAs’ panel may be contacted at:
ec-dppanel-secr@ec.europa.eu and the EU DPAs’ may be contacted directly via the information provided at: http://ec.europa.eu/justice/data-protection/bodies/authorities/eu/index_en.htm. The contact information for the Swiss FDPIC can be found at: http://www.edoeb.admin.ch/kontakt/index.html?lang=en .

33. Residents of the European Union, European Economic Area, and Switzerland - (Top)

If you are a resident of the European Economic Area (“EEA”) or Switzerland and have any concerns or complaints, please first address these issues to DAI’s Privacy Officer, as provided in the above section entitled “DAI Privacy Officer Contact Information”.

34. International Privacy Statements - (Top)

DAI encourages you to view your country’s Privacy Statement at: www.subway.com. To view your country’s Privacy Statement please go to: http://www.subway.com/subwayroot/exploreourworld.aspx. At the top of the page, please click on CHANGE, which brings you the EXPLORE OUR WORLD page. To choose your Country click on the Country name, then go to the very bottom of the Country’s page and click the PRIVACY STATEMENT link to view the website Privacy Statement specific to your Country.

35. Changes to DAI’s Privacy Statement - (Top)

DAI will update this Privacy Statement occasionally. When DAI posts changes to this Privacy Statement, we will also revise the "LAST REVIEWED" date on DAI’s Privacy Statement. If there are any material changes to this Privacy Statement, DAI will notify you by email, or by means of a notice on our home page. DAI encourages you to review this Privacy Statement periodically to be informed of how DAI is protecting your information and to be aware of any changes to DAI’s Privacy Statement. Your continued use of DAI’s website: www.subway.com 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 DAI. Any changes to this Privacy Statement are effective immediately after being posted by DAI.

36. Terms and Conditions of Website Use - (Top)

The Terms and Conditions located at: http://www.subway.com/subwayroot/TermsOfUse.aspx, governs the use of DAI’s 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: 05/02/2015

 
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