PRIVACY STATEMENT

Subway Japan G.K.
〒140-8509 Tokyo Front Terrace 9F, 2-3-14 Higashi-Shinagawa, Shinagawa-ku, Tokyo
Co-representatives: Takanao Suzuki, Tomohisa Aso

Disclosure based on the Act on the Protection of Personal Information

Subway Japan G.K. (hereinafter referred to as "this company") makes the following disclosure based on the "Act on the Protection of Personal Information" (hereinafter referred to as the "Personal Information Protection Law").

In addition, the following matters include information that is to be made readily available and to be put in a "position where it can be known by the person (including cases where we respond without delay at the request of the person)" in accordance with the Personal Information Protection Law.

1. Name of business operator handling personal information

   Subway Japan G.K.

2. Publication of purpose of use

   1. When obtaining personal information in writing directly from the individual (including website screens on the Internet, etc. The same will apply hereinafter.), it is treated as an exception under the purpose of use laws, and we will use personal information only for the purpose clearly stated on each occasion unless otherwise permitted.
   2. Personal information purposes of use other than the above

      Personal information of customers who applied for campaigns, sweepstakes, etc.	This will be used to draw lots and ship prizes. In addition, if you individually consent, we may send you information about our products by email newsletter, direct mail, etc.
      Personal information of customers who participated in questionnaires and other surveys	In order to improve the quality of our products and services, we will use this in the form of statistical information that does not identify individuals.
      Personal information of customers who have applied for email newsletter subscriptions, and customers who have consented to email newsletter distribution	This will be used to distribute email newsletters.
      Personal information of customers who have consented to receive direct mail	This will be used to distribute direct mail.
      Personal information of customers who ordered products by email, fax, etc.	This will be used for product shipment, payment settlement, and sharing information about our products by mail, telephone, and email.
      Personal information of customers who contact us by phone, email, etc.	This will be used for responding to inquiries and keeping company records.
      Personal information of business partners related to our business	This will be used for business communication and correspondence, managing contractual relationships, and sharing information about our products.
      Personal information entrusted by an outsourcing company in connection with work commissioned by the company	This will be used for performing commissioned business processing word related to personal information such as inputting, editing, etc.
      Personal information of those who have applied for franchise affiliation contracts	This will be used only for franchise screening.
      Personal information of franchisees	This will be used to maintain the operations of the Subway chain, such as by providing store operation information and the settlement of royalties.
      Personal information of those who have applied for employment and those who have been introduced to our company by recruitment agencies, etc.	This will be used only for recruitment screening.
      Personal information of former employees	This will be used to comply with labor-related laws and regulations, and to contact former employees in the event of an emergency.
      Personal information of employees, etc.	This will be used for employee hiring and personnel management.
      Shareholder information	This will be used for managing shareholders.
      Personal information related to various requests for disclosure, etc., based on the Personal Information Protection Law	This will be used to comply to each respective request.

      In addition, all items may be used in the form of statistical information that does not identify individuals.

      The following cases are recognized as exceptions by law:

      1. When it is recognized that the purpose of use is clear in terms of acquisition
      2. When notifying the person in question about the purpose of use or making it public will lead to a risk of harm to the life, body, property, or other rights and interests of said person or a third party
      3. When notifying the person in question about the purpose of use or making it public will lead to a risk of harming our company's rights or legitimate interests
      4. When it is necessary to cooperate with national agencies or local governments in carrying out legally mandated affairs, and notifying the person in question about the purpose of use or publicly announcing it may interfere with the execution of the relevant affairs

3. Joint use

   Our company does not currently share personal data with other companies. However, in the event of joint use in the future, we will clearly indicate such at the time of acquisition.

4. Purpose of use for retained personal data

   Retained personal data refers to personal data that we have the authority to disclose, correct, add or delete content, stop using, erase, and stop providing to third parties, excluding the following:

   1. That the public interest or other interests will be harmed if its existence or non-existence becomes known

   *In addition, we will discard or delete the personal information of customers who applied for campaigns, sweepstakes, etc., and the personal information of customers who have provided their opinions in survey postcards, etc., within six months unless otherwise specified.

   The purpose of use for retained personal data at our company is indicated in #2 (2) above (excluding "The purpose of use for personal information entrusted by an outsourcing company in connection with work commissioned by the company"). However, this does not apply to the following cases that are exempted by law:

   1. When notifying the person in question about the purpose of use or making it public will lead to a risk of harm to the life, body, property, or other rights and interests of said person or a third party
   2. When notifying the person in question about the purpose of use or making it public will lead to a risk of harming our company's rights or legitimate interests
   3. When it is necessary to cooperate with national agencies or local governments in carrying out legally mandated affairs, and notifying the person in question about the purpose of use or publicly announcing it may interfere with the execution of the relevant affairs

5. Provision of personal information to third parties

   Our company will not provide personal information to third parties other than subcontractors without obtaining the consent of the person in advance.

   However, this does not apply to the following cases that are exempted by law:

   1. When required by law
   2. When it is necessary to protect a person's life, body, or property and it is difficult to obtain the consent of the person in question
   3. When it is particularly necessary to improve public health or promote the healthy development of children, and it is difficult to obtain the consent of the person in question
   4. When it is necessary to cooperate with national agencies, local governments, or persons entrusted by them in carrying out affairs prescribed by laws and regulations, and there is a risk that obtaining the consent of the person in question may interfere with the execution of the relevant affairs

6. Procedures for requesting notification of purpose of use and disclosure of personal information

   The following procedures are for personal data held by the company. Please refer to "Requests from Agents" for these requests from agents.

   Please refer to #4 for retained personal data.

   1. Procedures for notification of purpose of use and disclosure of personal information

      In the event that a person requests they be notified of the purpose of use for personal information or disclosure of personal information, the company will, in principle, follow the procedures below and notify the person of the purpose of use or disclosure of personal information without delay. However, please understand in advance that the company may not disclose all or part of the information if any of the following items apply:

      1. When there is a risk of harm to the life, body, property, or other rights and interests of said person or a third party
      2. When there is a risk of significant hindrance to the proper administration of the company
      3. When it violates laws and regulations other than the Personal Information Protection Law
      4. When the identity cannot be verified, such as when the name, address, etc., on the request does not match the name, address, etc, on the identity verification document.
      5. If the request is made by an agent and the power of attorney cannot be confirmed
      6. If there is any deficiency in the documents required for the following procedures:
      [Procedures]

      • When requesting disclosure of the content of personal information (disclosure is only in writing)
        1. For those who have requested notification of the purpose of use and request for disclosure received at the reception desk from #7, we will send you a “Request for Notification of Purpose of Use” or a “Disclosure of Personal Information Request Form” prepared by our company, as well as a guidebook for procedures, etc., describing the address for sending each type of request.
        2. When you receive the request, etc., please fill in the necessary information, attach the identity verification document (*1) designated by our company and a self-addressed envelope (postage stamps worth 800 yen (*2)), and send it to the address provided for request forms.
        3. If our company is able to verify the request, identity verification documents, and self-addressed envelope (with 800 yen worth of postage stamps attached), we will carry out the necessary procedures.

        *1 See the "List of Identity Verification Documents" for identity verification documents.

        *2 In order to protect personal information, it will be sent by certified mail. Please note that if the Japan Post charges are revised, they will be revised accordingly.

        *3 Please note that even if we are unable to notify the purpose of use or disclose personal information, we will not be able to return the documents, postage stamps, etc., sent to us.

      • When requesting disclosure of the content of personal information (disclosure is only in writing)
        1. For those who have requested notification of the purpose of use and request for disclosure received at the reception desk from #7, we will send you a “Personal Information Disclosure Request Form (For Non-Paper Documents)” prepared by our company, as well as a guidebook for procedures, etc., describing the address for sending each type of request.,
        2. When you receive the request, etc., please fill in the necessary information, attach the identity verification document (*) designated by our company, and send it to the address provided for request forms.
        3. If our company is able to verify the request form and identity verification documents, we will carry out the necessary procedures.

        * See the "List of Identity Verification Documents" for identity verification documents. Please note that we cannot return documents, including identification documents, that you have sent to us, as they will be disposed of without delay after we have responded to each request. Thank you for your understanding.

   2. Procedures for correction, deletion, etc.

      (For requests for correction, deletion, etc., from an agent, please refer to [Requests from an agent])

      1. When requested by the person in question to correct, add, or delete personal information because the content of the personal information is not true, the company will comply with laws other than the Act on the Protection of Personal Information regarding the correction and deletion of the content. We will investigate without delay to the extent necessary to achieve the purpose of use, except when special procedures are stipulated by laws and regulations. In this case, if the content of the personal information pertaining to the request is not true, or if the handling of the personal information is not appropriate, the company will correct, add or delete it without delay.
      2. If the company is requested to stop using or to delete personal information because it is handling personal information from the person in question beyond the scope necessary to achieve the purpose of use, the personal information is used in a way that may encourage or induce illegal or unfair acts, or the personal information was acquired by deception or other wrongful means, and it becomes known that the request is justified, the company will suspend use of the personal information or delete it without delay to the extent necessary to correct the violation.
      3. If the company is requested to discontinue provision of personal information to a third party on the grounds that the company has provided personal information to a third party without obtaining the consent of the person in question in advance, and has done so without a basis in laws and regulations or the privacy policy, and it becomes known that the request is justified, the company will suspend provision of the personal information to the third party without delay.

      However, please understand that even if a request for (b) or (c) above is received, we may not stop using, erase, or discontinue provision to third parties all or part of the personal information if any of the following items apply:

      1. In the event that suspension of use, addition, erasure, or suspension of provision to a third party of the retained personal data requires a large amount of expenses, or it is difficult to suspend use, erase, or suspend provision to a third party, so long as alternative measures are taken as necessary to protect the rights and interests of the individual
      2. When the identity cannot be verified, such as when the name, address, etc., on the request does not match the name, address, etc., on the identity verification documents.
      3. If the request is made by an agent and the power of attorney cannot be confirmed
      4. If there is any deficiency in the documents required for the following procedures.
      [Procedures]

      1. For those who have requested correction, deletion, suspension of use, erasure, suspension of provision to third parties at the reception desk from #7, we will send you a “Request for Personal Information Correction/Deletion” or a “Request for Suspension of Use, Erasure, or Suspension of Provision to Third Parties of Personal Information” prepared by our company, as well as a guidebook for procedures, etc., describing the address for sending each type of request.
      2. When you receive the request, etc., please fill in the necessary information, attach the identity verification document (*) designated by our company, and send it to the address provided for request forms.
      3. If our company is able to verify the request form and identity verification documents, etc., we will carry out the necessary procedures.

      * See the "List of Identity Verification Documents" for identity verification documents. Please note that we cannot return documents, including identification documents, that you have sent to us, as they will be disposed of without delay after we have responded to each request. Thank you for your understanding.

7. Request for notification of purpose of use, disclosure, correction, etc., and point of contact for suggestions or complaints (reception desk)

   Please direct inquiries to the customer service desk. (Please understand that we are unable to respond to visits to our company)

   • List of Identity Verification documents

     Please enclose a copy of one of the following. Please make a copy of the part where your name and address are written. If your current address is different, please submit a certificate of residence that shows your residential history. In addition, in the case of a driver's license, passport, etc., in which the permanent domicile, etc., is stated, please make a copy that excludes items such as "permanent domicile".

     • Passport
     • Driver's license
     • Various insurance cards (health insurance card, etc.)
     • Nursing care insurance card
     • Pension book
     • Certificate of Alien Registration
     • A copy of your resident card
     • Utility charges for the most recent three months (electricity, gas, water, telephone, etc.) confirming your name and current address

     *The above documents will not be used for anything other than identity verification, and will be disposed of without delay after each request has been processed. Please note that we cannot process returns.

   • Requests from agents

     Requests from legal representatives

     1. In the case of a legal representative of a minor
        1. In addition to the various request forms, we will send a "Power of Attorney Confirmation Form" and "Guidelines for Procedures, etc." prepared by our company to the legal representative who presented the request at the reception desk from #7.

        2. When you receive the request, confirmation, etc., please fill in the necessary information in each document and send the following documents for confirmation of power of attorney to the address provided for request forms.

           "Documents for confirmation of power of attorney"

           and documents to confirm that you are the legal representative (certificate of registered matters, family register, or official certificate that shows parent-child relationship) 1 copy

           "Documents for confirmation of the identity of the legal representative"

           Same as the [List of Identity Verification Documents]

           *The above documents cannot be returned and will not be used for anything other than confirmation of power of attorney, etc., as they will be discarded without delay after each request has been processed. Thank you for your understanding.

        3. If our company is able to verify the request form and identity verification documents, we will carry out the necessary procedures.
     2. In the case of a legal representative such as for an adult ward
        1. In addition to the various request forms, we will send a "Power of Attorney" and "Guidelines for Procedures, etc." prepared by our company to the legal representative who presented the request at the reception desk from #7.

        2. When you receive the request, power of attorney, etc., please fill in the necessary information in each document and send the following documents for confirmation of power of attorney to the address provided for request forms.

           "Documents for confirmation of power of attorney"

           and a Certificate of Registration as stipulated in Article 10 of the Act on Guardianship Registration, etc.

           "Documents for confirmation of the identity of the legal representative"

           Same as the [List of Identity Verification Documents]

           *The above documents cannot be returned and will not be used for anything other than confirmation of power of attorney, etc., as they will be discarded without delay after each request has been processed. Thank you for your understanding.

        3. If our company is able to verify the request form, identity verification documents, power of attorney confirmation documents, etc., we will carry out the necessary procedures.

     Requests from representatives based on delegation (discretionary representatives)

     1. In addition to the various request forms, we will send a "Power of Attorney" and "Guidelines for Procedures, etc." prepared by our company to the legal representative who presented the request at the reception desk from #7.

     2. When you receive the request, power of attorney, etc., please fill in the necessary information in each document and send the following documents for confirmation of power of attorney to the address provided for request forms.

        "Documents for confirmation of power of attorney"

        and a power of attorney and certificate of the person's seal stamped on the power of attorney

        "Documents for confirmation of the identity of the legal representative"

        Same as the [List of Identity Verification Documents]

        *The above documents cannot be returned and will not be used for anything other than confirmation of power of attorney, etc., as they will be discarded without delay after each request has been processed. Thank you for your understanding. In addition, if there is no affixed personal seal or certificate of seal impression of the person in question, only that person will be contacted regarding the result of disclosure, etc.

     3. If our company is able to verify the above documents, etc., we will carry out the necessary procedures.