Effective Date: October 6, 2021
Last Revised: March 1, 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.
If after reviewing this Privacy Statement, you would like to submit a request or you have any questions or privacy concerns, please contact:
The Subway Group Privacy Office
c/o Franchise World Headquarters, LLC
325 Sub Way
Milford, CT, 06461
USA
Telephone Number: (203) 877-4281 or Toll Free: 1-800-888-4848
Email Address: [email protected]
If you are a user with a disability and need access to this Privacy Statement in an alternative format, please contact us at [email protected].
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The Subway Group. The Subway Group (“we,” “us” or “our”) is made up of a variety of companies including but not limited to, Subway IP LLC (the owner of our proprietary system for establishing and operating restaurants in order to develop Subway® restaurants worldwide), FWH Technologies, LLC (the owner and licensor of the SubwayPOS® software for use in Subway® restaurants worldwide), Franchise World Headquarters, LLC (a service-oriented company that provides core business-related services to other Subway Group entities), the Subway® franchisors (which offer and sell franchises worldwide), and the Subway® advertising entities (which administers national and local advertising funds and activity for Subway® restaurants and Subway® franchisees worldwide). To see a list of the Subway Group entities that may come in contact with your personal information, please see “Our Group Companies” section below.
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”).
What this statement does not apply to This Privacy Statement does not apply to (1) Subway Services that show a different privacy statement (2) third party websites including websites that are operated by Subway® franchisees, or (3) when you interact with us an employee. Subway® restaurants are owned and operated by independent Subway® franchisees. Each restaurant is solely and independently responsible for its legal and regulatory compliance and this Privacy Statement does not apply to Subway® franchisees or to websites or mobile apps they operate. Please see Subway® franchisees’ privacy notices for information on how they use customer information. There may also be times we have a link to third party websites. If you choose to visit those websites, we are not responsible for the privacy practices or the content of those websites. We encourage you to review the privacy policies of those websites before submitting your personal information. Some third parties may choose to share information about their users with us; that sharing is governed by that company’s privacy policy and not this Privacy Statement.
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.
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Guests
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:
Prospective Employees
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.
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We Collect Information Directly From You
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.
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We may use the information we collect in the following ways.
To provide our services and contract with you, including to:
To market to you, improve our services, and the following legitimate business interests, including to:
To comply with applicable law, including to:
For the public interest:
With your consent (where required by applicable law), we may use the information we collect for the following purposes:
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.
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We may share information collected from or about you with the following categories of companies in the following ways:
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 with third parties for 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.
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We use cookies and similar technologies for a wide range of purposes in our websites, applications and email communications to deliver the Subway Services and improve your experience. For example, we use information collected from cookies and similar technologies to help us recognize you, customize and improve your experience, provide security, analyze usage of the Subway Services, gather demographic information about our user base, to offer the Subway Services to you, to monitor the success of marketing programs, and to serve targeted advertising on our site and on other sites around the Internet. To learn more about the categories of cookies we (and our service providers) use and what they are used for please click on Cookie Settings.
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.
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Cookies and Other Technologies
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 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.
Marketing Communications
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.
Push Notifications
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 MyWay® 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.
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Under certain circumstances, and depending on your state or country of residency, you may have rights under applicable data protection laws in relation to your personal information. You may have the right to:
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 MyWay® 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 here.
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.
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.
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Due to our global operations, your personal information may be transferred to and processed in the United States and other countries that may not provide the same level of data protection as your home country. The Subway Group’s privacy practices are consistent with all applicable country, national, state, and local data protection and security laws.
FFor 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.
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To the extent permitted by applicable law, we retain your personal information as long as (1) it is needed for the purposes for which we obtained it and in accordance with this Privacy Statement or (2) we have another lawful basis, stated in this Privacy Statement or at the point of collection, for retaining that information beyond the period for which it is necessary to serve the original purpose for obtaining the personal 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.
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Our services are not intended for use by children under the age of 13 or equivalent minimum age depending on the jurisdiction.
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.
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We use reasonable security measures as required by applicable law. While we have employed security technologies and procedures to assist safeguarding your personal information, no system can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us. You use Subway Services and provide us with your information at your own risk. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
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Here is a list of our entities that may be involved in processing your personal information:
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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