PRIVACY STATEMENT

The Subway Group Privacy Statement

Last Updated: March 3, 2020

Your privacy is important to us. So we’ve developed a Privacy Statement that describes how we collect, use, disclose, transfer, and store your information. It will also tell you about your rights with regard to your personal data.

How To Contact Us

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]

1. About This Statement

   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, subscribe to our news and offers, enter into one of our promotions or contact customer support (collectively, “Subway Services”).

   What this statement does not apply to. This statement does not apply to (1) Subway Services that show a different privacy statement and (2) third party websites including websites that are operated by Subway® franchisees. 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 a change to this statement, we will make previous versions available upon request so that you can see when changes occurred and what they are. If we make any material changes to this statement, we will notify you by means of a notice on this site or by an email (sent to the email address specified in your account). Where we are required by applicable data protection laws, we will also seek your consent to any material changes that affect how we use your personal information. We encourage you to periodically review this page for the latest information on our privacy practices.

2. Personal Information We Collect

   The personal information we collect falls into three categories: (a) information you provide us directly; (b) information we collect through automated methods; and (c) information we collect from third parties.

   Information You Provide Directly

   When you use Subway Services, we may ask you to provide certain personal information to obtain our products or use our services. The personal information we collect from you depends on the nature of your interaction with us or the Subway Services you use, but may include the following:

   • Contact Information. We may collect personal and/or business contact information including your first name, last name, mailing address, telephone number, fax number, email address, and other similar data.

   • Payment Information. If you make a purchase online, you will be required to provide a credit/debit card number and related financial information (such as expiration date, security code and billing address), or other payment (such as via your Subway® Card), depending on the form of payment you choose.

   • Account Information. We collect information such as your username and password when you create an account, access our online services, or buy our products. Account information may also include how you purchased or signed up for Subway Services, your transactions, billing and support history the Subway Services you use and anything else related to the account you create.

   • Usage Data. This is the personal data we collect about you when you are using Subway Services, which may include information about the date and time of your logins and details of your use of third party applications and advertising you receive.

   • Marketing and Communications. We may also collect your preferences in receiving marketing from us and our third parties.

   • Security Credentials. We collect user IDs, passwords, email, and similar security information required for authentication and access to your Subway® accounts.

   • Information through Social Media. You may also be given the option to link to your Facebook or other social media accounts through Subway Services. Your use of these features may result in the collection or sharing of information about you, depending on the feature. For example, these Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. They may also allow third-party social media services to provide us information about you, including your name, email address, and other contact information. The information we receive is dependent upon your privacy settings with the social network. We encourage you to review the privacy policies and settings on the social media sites you use to make sure you understand the information that is collected, used, and shared by those sites.

   • Customer Service, Surveys & Promotions. There may be times you provide us additional personal information when you interact online or by phone or mail with our customer support channels; when you participate in our customer surveys or promotions; or to facilitate delivery of Subway Services or to help us respond to your inquiries. Types of additional personal information may include voice recordings, photographs and videos.

   • Information You Provide about a Third Party. You may decide to provide us with another person’s information (such as their name, email, address or phone number) so that we may recommend or send products or services to that person. Local law may require you to get the consent of that person to provide their information to the Subway Group. We may in turn use the information you provide in accordance with this Privacy Statement.

   • If you fail to provide your personal information. Where we need to collect your personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, in order to provide you with our products or services). In this case, we may have to cancel the contract and notify you accordingly.

   Information Collected Automatically

   Whenever 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 collects information about your online activity. This information may be collected in the following ways:

   • Device & Technical Data. We collect technical information when you visit our websites or use our mobile applications or services. This includes information such as you Internet Protocol (IP) address, your login data, the type of mobile device you use, your device operating system and browser type, time zone setting and location, language, a unique device identifier, the address of a referring website, the path you take through our websites, and other information about your session on our websites.

   • Cookies and Other Technologies. We and our third party 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. 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. For more information, including the types of cookies found on Subway® websites and how to control cookies, please read The Subway Group’s Cookie Policy and the “Targeted Advertising” section below.

   • Geolocation Data. We may collect information about your location when your device is set to provide location information. For example, your device’s GPS signal allows us to show you the nearest Subway® restaurant. To assist us in providing proximity based marketing and other location based services we utilize our Service Provider Google’s Maps API per Google’s Terms of Service which you consent to. For most mobile devices and computer systems, you are able to withdraw your permission for us to collect this information by using your browser or device settings. To withdraw your Google Maps API permission setting please follow the procedures in Google’s Terms of Service. If you have any questions about how to prevent us from collecting exact information about your location, we recommend you contact your mobile-device provider, the device manufacturer, or your web-browser provider. Some online services and in-restaurant technology may not work properly without information about your location.

   Information Received from Third Parties

   We may collect information about you from other companies and organizations, including public databases, social media platforms, our third party marketing partners or various independent purchasing organizations established for the benefit of Subway® franchisees.

   Independent purchasing organizations provide a variety of support functions to Subway® franchisees in that region. Support functions may include, but is not limited to, administering 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 may also 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.

   Combined 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.

   Anonymous and Aggregated Information

   Anonymized and aggregated information does not identify a specific person and is not personal information. We use this type of information for a variety of functions, including measuring users’ interest in and use of Subway Services, conducting internal analysis, data analytics and research. We may also share anonymized or aggregated information with third parties for our or their purposes, but none of this information can be used to identify you or determine anything else personal about you.

3. Lawful Basis For How We Use Your Personal Information

   We may use the information we collect in the following ways.

   To provide our services and contract with you:

   • carry out your requests, fulfill orders, and process payments for our products and services;

   • communicate with you about your orders, purchases or accounts with us, including handling any requests, questions or comments you may have;

   • provide online services to you, which includes our websites and/or mobile applications; and

   • provide customer support, including processing any concerns about our services.

   To market to you, improve our services, and the following legitimate business interests:

   • tell you about our products and services, competitions, offers, promotions or special events that we believe may interest you when you are part of a Subway® loyalty program;

   • personalize your experience in our restaurants and on our online services;

   • verify your identity or communicate with you about your activities with respect to Subway Services;

   • manage our business, including developing new products and services, conducting consumer and operations research, and assessing the effectiveness of our sales, marketing and advertising;

   • use analytics and profiling technology to personalize your experience; deliver content (including advertising) tailored to your interests and let you know how to use Subway Services (see “TARGETED ADVERTISING” below for more information);

   • link or combine with information we receive from others to help understand your needs, use for interest-based or targeted advertising or re-targeting on your computers or other devices;

   • ensure the security of our networks and systems, including to help diagnose technical and service issues, troubleshoot issues, bugs or defects related to your account or activities;

   To comply with applicable law:

   • protect against fraud and other crime, claims and liabilities;

   • comply with legal obligations and our policies;

   • establish or defend a legal claim; and

   • monitor and report compliance issues.

   For the public interest:

   • we may use your personal information if we reasonably believe that there is an inherent security or product issue that we must either disclose to you or the authorities and the use of your information will prevent or potentially minimize the danger to you or others.

   With your consent (where required by applicable law), we may use the information we collect for the following purposes:

   • to send you emails or text messages about the products and services, competitions, offers, promotions or special events we believe may interest you;

   • to send you emails or text messages about the products and services of our business partners;

   • provide location-based services;

   • use cookies and similar technologies.

   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.

4. Sharing Your Information

   We do not sell any of your personal information including your name, address, email address or credit card information to any third party.

   However, we may share the 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 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 Development Agents. If you choose to contact us or submit a survey about your experience in a Subway® franchisee’s restaurant, we may share your information to the Subway® franchisee in order for them to address your request, compliment or complaint. We may also share your information with the Development Agent who oversees the operations of the restaurant. Development Agents 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 loyalty programs.

   Third Party 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; data processing or other information technology services; carrying out research and analysis, providing customer experience management services and 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.

   Other Third Parties: Your personal information may also be shared with our sponsors, partners, advertisers, advertising networks, advertising servers, and analytics companies or other third parties in connection with marketing, promotional, and other offers, as well as product information. Your information may also be shared with third parties we identify at the time you provide your personal information or otherwise with your consent.

   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 customers 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.

   The Subway Group remains responsible for the personal information that we share with third parties for processing on our behalf in connection with the operation of our business, and we remain liable under this privacy statement if our third parties process your personal information in a manner inconsistent with the Privacy Shield Principles, unless the Subway Group proves that it is not responsible for the matter giving rise to the damage.

5. Targeted Advertising

   We use third parties’ 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 third parties 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, Flash cookies, or other technologies to collect and store non-personal information.

   We 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.

   At our request, these third parties collect, and share with us, usage information about visits to our websites, measure and research the effectiveness of our advertisements, track page usage and paths followed during visits through our websites, help us target our Internet banner advertisements on our websites and on other sites, and track use of our Internet banner advertisements and other links from our marketing partners’ sites to our websites. They may also combine information they collect from your interaction with Subway Services with information they collect from other sources.

   We do not have access to, or control over, these third parties’ use of cookies or other tracking technologies. To learn more about your advertising choices in relation to the collection and use of your information, please see the Subway Group’s Cookie Policy.

6. Opting Out

   Cookies and Other Technologies

   To learn how to opt-out of these services, please see the Subway Group’s Cookie Policy.

   Marketing Communications

   If you have agreed to receive marketing communications from us, you can later opt out by following the opt-out instructions in the marketing communications 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. 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”.

   If you do opt out of receiving marketing communications 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.

   Additional Notice to California Residents. California law permits residents of California to request certain details about how their personal information is shared with third parties or affiliated companies for direct marketing purposes. If you are a California resident and would like to make such a request, please fill out this form. Please note that if you opt out of receiving marketing communications 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® franchisee, then you will need to opt out from them directly.

   Loyalty Program

   U.S. and Canada. Participation in the Subway® loyalty 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. Please note that data originating through other non-program interactions may remain with us.

   International. If you would like to opt out of an international loyalty program, 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 opt out of all information collected via our app(s) by uninstalling it. 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.

   Location Opt Out. You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third parties 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.

7. Your Legal Rights

   Under certain circumstances, you have rights under applicable data protection laws in relation to your personal information. You 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 and to check that we are lawfully processing it. You may reasonably access your personal information by contacting the Subway Group Privacy Office regarding the accuracy of your personal information. Please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information we have about you.

   Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

   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. We will use reasonable efforts to revise it and, if necessary, to use reasonable efforts to inform agents, service providers or other third parties, which were provided with inaccurate information, so records in their possession may also be corrected or updated. However, we reserve the right not to change any personal information we consider accurate.

   Erasure of Your Personal Information. You may ask us to delete or remove personal information where there is no legal reason for us to continue using it. You also have the right to ask us to delete or remove your personal information where you successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with law. Please note that we may not always be able to comply with your request of erasure for specific legal reasons which we will notify you, if applicable, at the time of your request.

   Object to Processing Your Personal Information. You may have the right to object to us processing your information in certain circumstances. This right applies when we are processing your personal information based on a legitimate interest (or those of a third party), which you may challenge if you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. However, in some cases, we may demonstrate that we have compelling legitimate ground to process your information or legal obligations which override your rights and freedoms.

   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. Please note this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

   Notice to Nevada Residents. Nevada law allows consumers to direct certain businesses not to sell their personally identifiable information collected on a business’s website or other online service to third parties to license or sell that information to additional third parties. If you are a Nevada resident, you may submit such opt-out requests by filling out this form. To be effective, your request must include your full name, address, phone number, and email address to verify the authenticity of your request.

   Additional Rights and Choices for California Residents. If you are a California resident, the following additional rights may be available to you.

   Shine the Light.

   Customers who are California residents may request (i) a list of categories of personal information disclosed to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please send us an email or a letter to the addresses in the section entitled “Contact Us” above and specify you are making a “California Shine the Light” request. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

   California Consumer Privacy Act of 2018 (CCPA)

   Beginning January 1, 2020, the CCPA provides California residents with additional rights as described below. Please note your right to know and right to delete are subject to certain exceptions under the CCPA.

   Notice of Collection. During the past 12 months, we have collected the following categories of personal information that the CCPA covers:

   • Identifiers, including name, email address, date of birth, phone number, account name, IP address, and an ID or number assigned to your account.

   • Guest records, billing and delivery address, and credit or debit card information.

   • Commercial information, including purchases and engagement with our websites and mobile applications.

   • Internet activity, including your interactions with our websites and mobile applications.

   • Audio data, including information collected for customer care quality assurance.

   • Geolocation data, including location enabled services such as GPS.

   • Inferences, including information about your interests, preferences and favorites.

   This privacy statement includes additional information about our data practices. For more information on information we collect, including the sources we receive information from, review the “Personal Information We Collect” section. We collect and use these categories of personal information for the business purposes described in the “Lawful Basis For How We Use Your Personal Information” section, including to provide and manage our websites and mobile applications.

   Right to Know. You have the right to know certain information about our data practices in the preceding 12 months. You have the right to request the following information from us:

   • The categories of personal information we have collected about you;

   • The categories of sources from which the personal information was collected;

   • The categories of personal information about you we disclosed for a business purpose or sold;

   • The categories of third parties to whom the personal information was disclosed for a business purpose or sold;

   • The business or commercial purpose for collecting or “selling” the personal information; and

   • The specific pieces of personal information we have collected about you.

   Right to Delete. You have the right to request the deletion of personal information that we collect or maintain about you and your account. 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.

   Right to Opt Out of “Sale”. Subway does not sell information as the term “sell” is traditionally understood. However, Subway may disclose certain information about you when you use Subway Services for purposes that may be considered a “sale” under the CCPA. For example, we may disclose information to advertising partners, advertising technology companies, and companies that perform advertising-related services in order to provide you with more relevant advertising tailored to your interests. This information may include identifiers such as your IP address, advertising identifiers, commercial information, your internet or other electronic network information such as your interaction with an ad, geolocation data and inferences. To the extent Subway sells your personal information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell My Personal Information and following the instructions.

   How to Exercise Your CCPA Rights. To exercise any of these rights, please fill out this form or 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 will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

   • Please note that Subway® restaurants are franchised and are independently owned and operated. Their processing of personal information is subject to their own privacy policies. If you wish to exercise any of these rights with respect to the processing of information by a Subway® restaurant, please visit your local franchise-owned and operated store location to make your requests. We will work with the franchise owner to address your request to the extent required by applicable law.

   • You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly. Please provide written proof via email to [email protected].

   • If you choose to exercise any of these rights, you will not receive different prices or quality of services unless permitted by applicable law, including if those difference are reasonable related to your information. For example, we may from time to time provide special surprise rewards to Subway MyWay® Rewards members who join the Subway MyWay® loyalty program online or by downloading the Subway® App. Any special rewards we offer will reasonably relate to your personal information’s value. Participation in Subway MyWay® Rewards is voluntary, and you may remove the Subway® App from your device at any time. If you maintain your account, you will still be able to use it to order and receive rewards using the Subway website. Otherwise, you will need to use the guest checkout on the website to place an order.

   Please note that if you opt out of receiving marketing communications 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® franchisee, then you will need to opt out from them directly.

   If you wish to exercise any of the rights set above, please contact us. We will need you to provide specific information to help us confirm your identify. This is a security measure to help ensure that your personal information is not disclosed to someone that does not have the right to receive it.

8. International Transfers And Privacy Shield

   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.

   For our customers whose use of Subway Services results in the transfer of personal information from the European Economic Area (EEA) or Switzerland to non-EEA countries, we rely on one or more of the following legal mechanisms: the EU-U.S. Privacy Shield, the Swiss-U.S. Privacy Shield, Standard Contractual Clauses, and consent of the individual.

   The Subway® Group’s service entity, Franchise World Headquarters (FWH), and our other U.S. affiliates: Doctor’s Associates LLC, Franchisee Shipping Center Co., LLC, FWH Technologies, LLC, Subway Franchisee Advertising Fund Trust, Ltd., Subway IP, Inc., Subway MyWay, LLC, Subway Realty, LLC, Subway Real Estate, LLC, comply with the EU-U.S. and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the transfer of personal information from the European Economic Area (EEA) and Switzerland to the United States. Our U.S. affiliates certified that they adhere to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse and liability. If there is any conflict between the terms of this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Program, and to view our certification page, visit https://www.privacyshield.gov.

   Franchise World Headquarters and other U.S. affiliates commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources and non-human resources data transferred from the EU and Switzerland.

   In compliance with the EU-US and Swiss-US Privacy Shield Principles, Franchise World Headquarters and other U.S. affiliates commit to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this Privacy Statement should first contact the Subway’s Privacy Office (see “How to Contact Us” above).

   Franchise World Headquarters and other U.S. affiliates are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with respect to the Privacy Shield. Under certain conditions, if your complaint is not satisfactorily resolved with us directly, you may submit Privacy Shield-related complaints to the attention of your Data Protection Authority (DPA): http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm, which will establish a panel to investigate and resolve complaints brought under the Privacy Shield. We will fully comply with the advice given by the DPAs and take necessary steps to remediate any non-compliance with the Privacy Shield Principles. Such independent dispute resolution mechanisms are available to EU and Swiss citizens free of charge. Additionally, you may have a right to invoke binding arbitration under the Privacy Shield.

9. How Long We Keep Your Information

   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. If the lawful basis for processing that data is based solely on consent, we will delete the personal information if that consent is revoked.

10. Children’s Privacy

    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.

11. Our Security

    We recognize the importance of maintaining the security of your personal information. We protect your information using security measures, including physical, administrative, and technical safeguards to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of your information.

    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.

12. Our Group Companies

    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
    Sandwich and Salad Franchises of South Africa (Proprietary) Ltd.
    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 Trust B.V.
    Subway Franchisee Advertising Fund Trust Ltd.
    Subway Franchisee Canadian Advertising Trust
    Subway Franchisee Gift Certificate Management Company, LLC
    Subway International B.V. - Ecuador
    Subway International B.V. - South Korea Branch
    Subway International B.V. - Taiwan Branch
    Subway International B.V.
    Subway International de Mexico, S. de R.L. de C.V.
    Subway IP LLC
    Subway Japan G.K.
    Subway MyWay of Canada, ULC
    Subway MyWay, LLC
    Subway Partners Colombia C.V.
    Subway Realty e Desenvolvimento de Software do Brasil Ltda.
    Subway Realty Limited
    Subway Realty of France EURL
    Subway Realty of Italy S.r.l.
    Subway Realty of Spain, S.L.U.
    Subway Realty of the Netherlands B.V. Merkezi Hollanda Istanbul Merkezi Şubesi
    Subway Subs of Canada, ULC
    Subway Systems Australia Pty. Ltd.
    Subway Systems do Brasil Ltda.
    Subway Restaurant Management (Shanghai) Co. Ltd.
    Subway Systems India Private Limited
    Subway Systems Middle East FZ-LLC
    Subway Systems Singapore Pte. Ltd.
    Subway Vermietungs-und Servicegesellschaft mbH
    Subway Vermietungs-und Servicgesellschaft G.m.b.H. -organizachi slozka (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.

Business Developer (‘BD’) Privacy Notice

Last Revised: April 16, 2021

The Subway® Group (“we” or “us” or “our”) cares about our Business Developers(“you” or “your”) privacy. This privacy notice explains our privacy practices regarding your personal information, including:

• The types of personal information we may obtain about you;
• How we may use your personal information and with whom we may share it;
• What we do to safeguard the personal information we collect;
• Your rights regarding your personal information; and
• How to contact us.

This Privacy Notice does not apply to the Subway® Group’s prospective and current employees, Subway® restaurant employee applicants or employees, Business Developers or their employees, consumers, or other personal information we collect for other purposes. All BDmust must be at least the minimum age to enter into a contract under applicable law and therefore, this privacy notice also does not apply to any individual under the age of eighteen.

Personal Information We Collect

Following are some of the types of personal information we may collect:

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:

Please note all information, including personal information submitted by you as part of the application process, may become part of your BDfile file.

How We Collect Your Personal Information

Generally, we collect your personal information directly from you (for example, during the BD application process, or registering for training). In some instances, the personal information we collect has been inferred about you based on other information you provided us, either through your interactions with us, or from third parties. When we collect your personal information from third parties it is either because you have given us express consent to do so, your consent was implied by your actions, or because you provided explicit or implicit consent to the third party to provide the personal information to us.

Where permitted or required by applicable law, we may collect personal information about you without your knowledge or consent. This may include, but is not limited to, when the collection is necessary for:

• The performance of a contract to which you are or will be a party;
• Compliance with a legal obligatin to which we are subject;
• The purpose of a legitimate interest we are pursuing.

We also reserve the right to monitor the use of our premises, equipment, devices, computers, network, applications, software, and similar assets and resources. In the event such monitoring occurs, it may result in the collection of personal information about you. This monitoring may include the use of CCTV cameras in and around our premises.

How We Use Your Personal Information

We may use the information we collect to:

• Respond to requests about Subway® Group BD opportunities.
• Respond to and process BDapplications applications.
• Onboard third-party delivery companies.
• To Business Developers, to facilitate franchise sales, site location assistance, training, and operational assistance in their territories.
• Administer Subway Group® events and online events that you sign up for.
• Conduct criminal & credit background checks (e.g. OFAC searches) as permitted or required by law.
• Establish and manage your accounts (e.g., Point-of-Sale System, customer care, extranet access, financial accounts, etc.).
• Verify your identity, such as on service calls, login credentials, convention registration, etc.
• Provide products and services to assist with your operations, such as training and marketing.
• Perform data analyses (including market research, trend analysis and financial analysis).
• Communicate about, and administer your participation in, special events, programs, webinars, surveys, contests, sweepstakes, and other offers or promotions.
• Operate, evaluate and improve our business (including developing new products and services, managing our communications, determining the effectiveness of our sales, marketing and advertising; analyzing and enhancing our products, services and Sites; and performing accounting, auditing, billing, reconciliation and collection activities).
• Prevent fraud and other criminal activity, claims and other liabilities.
• Enforce our contracts with you and seek indemnity from you under those contracts.
• Comply with applicable legal requirements, (including franchise disclosure laws) and our policies (e.g. national security, tax purposes, etc.).

Additionally, we may process sensitive information (such as race or nationality) if it is needed for business objectives or if it is required to comply with applicable law. For example, we may process information related to race for diversity reporting. Sensitive information will not be collected, processed or transferred, except where adequate privacy protection mechanisms are in place and is permitted by law.

Sharing Your Personal Information

We may disclose your personal information, including to our affiliates, subsidiaries, and other third parties, as follows:

• When you request us or provide your consent to do so.
• As necessary to complete any transaction or provide any product or service you request or authorize.
• Among our affiliates and subsidiaries, which may involve transferring personal information from one country to another.
• With our customers when addressing their comments and/or complaints about their experience at your store.
• To our contractors and third party service providers who need to know in order to carry out the uses of personal information (see How We Use Your Personal Information). For example, we provide updated franchisee contact information to search engine and social networking service providers to improve store and location information available on their sites.
• Where the personal information is public.
• To professional advisors (e.g. bankers, lawyers, accountants).
• As part of a corporate transaction such as a merger or sale of assets.
• When we have a good faith belief that doing so is necessary to-
  • Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;
  • Protect our customers from substantial harm or to prevent loss of life or serious injury;
  • Operate and maintain the security of our computer systems and networks; or
  • Protect the rights or property of the Subway® Group.

The Subway Group remains responsible for the personal information that we share with third parties for processing on our behalf in connection with the operation of our business, and we remain liable under this privacy statement if our third parties process your personal information in a manner inconsistent with the Privacy Shield Principles, unless the Subway Group proves that it is not responsible for the matter giving rise to the damage.

Cross-Border Transfers & Privacy Shield

Your personal information may be kept in hard copy or electronic format within Headquarters, Regional Offices, or in the cloud which may be located in the United States or other countries where Subway® affiliates, agents, or contractors conduct business.

We may transfer personal information from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections travel with your information.

Franchise World Headquarters, LLC (“FWH”), on its own behalf and on behalf of the U.S. members of the Subway® Group: Doctor’s Associates LLC, FWH Technologies, LLC, Subway Franchisee Advertising Fund Trust, Ltd., Subway IP, Inc., Subway MyWay, LLC, Subway Realty, LLC, Subway Real Estate, LLC, complies with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. FWH, on its own behalf and on behalf of the U.S. members of the Subway® Group, has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If third-party agents process personal information on our behalf in a manner inconsistent with the principles of either Privacy Shield Framework, we remain liable unless we prove we are not responsible for the event giving rise to the damage.

If there is any conflict between the terms in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles will govern. To learn more about the Privacy Shield Program, and to view our certification page, visit https://www.privacyshield.gov

If you have a question or complaint related to FWH or other U.S. members of the Subway® Group’s participation in the EU-U.S. or Swiss-U.S. Privacy Shield, we encourage you to contact the Subway® Group’s Privacy Team (see Contact Information below).

For any complaints related to Privacy Shield frameworks that cannot be resolved with the Subway® Group directly, You may submit Privacy Shield-related complaints to the attention of your Data Protection Authority: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm, which will establish a panel to investigate and resolve complaints brought under the Privacy Shield. We will fully comply with the advice given by the DPAs and take necessary steps to remediate any non-compliance with the Privacy Shield Principles. Such independent dispute resolution mechanisms are available to EU and Swiss citizens free of charge. Additionally, you may have a right to invoke binding arbitration under the Privacy Shield. FWH on its own behalf and on behalf of the U.S. Members of the Subway® Group are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Retention of Your Personal Information

Except as otherwise permitted or required by applicable law, we may retain your personal information only for as long as we believe it is necessary to fulfill the purposes for which it was collected or for the other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.

You may request that we delete the personal information about you that we hold. There are instances where applicable law or regulatory requirements allow or require us to refuse to delete this personal information. In the event we cannot delete your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Security

Although “guaranteed security” does not exist, we are committed to protecting the security of the personal information we collect about you, and we take reasonable physical, electronic, and administrative safeguards (including all steps required by law) to help protect your personal information from unauthorized or inappropriate access, use, loss or modification.

Accessing Your Personal Information

You may reasonably access your personal information by contacting the Subway® Group’s Privacy Team regarding the accuracy of your personal information.

Please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information we have about you.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Modifying or Updating Your Personal Information

We endeavor 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. We will use reasonable efforts to revise it and, if necessary, to use reasonable efforts to inform agents, service providers or other third parties, which were provided with inaccurate information, so records in their possession may also be corrected or updated. However, we reserve the right not to change any personal information we consider accurate.

Inquiries, Complaints and Objections

If you have concerns about how we process your personal information or sensitive information, please contact the Subway® Group’s Privacy Team. We will try to find a reasonable way to address your concerns. However, we must process personal information where required by law. In other cases, if we cannot process your personal information, you may be denied certain benefits.

If you believe that your personal information is not handled in accordance with applicable law or our Privacy Statement, you may submit a complaint to the Subway® Group’s Privacy Team. We will investigate the complaint.

Contact Information

This notice provides basic information about our processing of your personal information and your privacy rights. Should you have additional questions, you may contact the Subway® Group’s Privacy Team:

Subway® Group’s Privacy Team
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]

Changes to this Privacy Notice

We may change this Privacy Notice at any time. The effective date of each version of this Privacy Notice is identified below as the “Last Revised” date and will take effect immediately after being posted.

OUR GROUP COMPANIES

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
Sandwich and Salad Franchises of South Africa (Proprietary) Ltd.
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 Trust B.V.
Subway Franchisee Advertising Fund Trust Ltd.
Subway Franchisee Canadian Advertising Trust
Subway Franchisee Gift Certificate Management Company, LLC
Subway International B.V. - Ecuador
Subway International B.V. - South Korea Branch
Subway International B.V. - Taiwan Branch
Subway International B.V.
Subway International de Mexico, S. de R.L. de C.V.
Subway IP LLC
Subway Japan G.K.
Subway MyWay of Canada, ULC
Subway MyWay, LLC
Subway Partners Colombia C.V.
Subway Realty e Desenvolvimento de Software do Brasil Ltda.
Subway Realty Limited
Subway Realty of France EURL
Subway Realty of Spain, S.L.U.
Subway Realty of the Netherlands B.V. Merkezi Hollanda Istanbul Merkezi Şubesi
Subway Subs of Canada, ULC
Subway Systems Australia Pty. Ltd.
Subway Systems Colombia S.A.S.
Subway Systems do Brasil Ltda.
Subway Restaurant Management (Shanghai) Co. Ltd.
Subway Systems de Venezuela, C.A.
Subway Systems India Private Limited
Subway Systems Middle East FZ-LLC
Subway Systems Singapore Pte. Ltd.
Subway Vermietungs-und Servicegesellschaft mbH

Subway Vermietungs-und Servicgesellschaft G.m.b.H. -organizachi slozka (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.

Subway® Group Prospective Employees Privacy Notice

Last Revised: January 09, 2019

Subway® Group, and its subsidiaries and affiliates (“Subway®”, “us” or “we”), understand that your privacy is important to you. This Prospective Employees Privacy Notice describes:

• What information we collect during our application and recruitment process;
• How and why we collect it;
• How we use and share that information; and
• How you can access and update that information.

This Privacy Notice only applies to the Personal Information of job applicants, potential candidates for employment, and our optional recruiting programs and events. It does not apply to Subway® restaurant applicants or employees, consumers, Franchisees, Development Agents and their employees, or other personal information Subway® collects for other purposes.

Subway® Group Defined

“Subway®” means the specific Subway® affiliates, subsidiaries, and contracted service providers who will collect, use and maintain your Personal Information in connection with your application for employment, our recruiting, talent management processes, and any hiring process if you are extended an offer of employment.

Prospective Employee Acknowledgements

By submitting your Personal Information to us, you acknowledge that:

• You have read and understood this Privacy Notice and agree to the use of your Personal Information as set out herein.
• Your Personal Information may be transferred and processed worldwide, including countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Privacy Notice.
• You are not required to provide any requested information to us, but failing to do so may result in not being able to continue your candidacy for the job for which you have applied.
• All of your representations are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature. Providing any inaccurate information may make you ineligible for employment.
• This Privacy Notice does not form part of any contract of employment offered to candidates hired by Subway®.

Personal Information We Collect

As used in this Privacy Notice, “Personal Information” means information that identifies job applicants and potential candidates for employment with us, either submitted as part of the online application and/or through alternative channels (e.g., written application or via professional recruiting firms).

Personal Information collected may include, but is not limited to:

There may be instances in which the Personal Information that you provide to us is considered “Sensitive Personal Information” under the privacy laws of some countries. Sensitive Personal Information is a subset of Personal Information that includes, but is not limited to:

To the extent you make Sensitive Personal Information available to Subway®, you consent to Subway® processing such information in accordance with this Privacy Notice.

How We Collect Your Personal Information

Generally, we collect your personal information directly from you in circumstances where you provided information (e.g. during the application process). However, Subway® may need to obtain Personal Information about you from third parties in order to supplement, update or verify your information, and/or to process your application for consideration as a Subway® employee. Applicable law may require that you authorize a third party to share your Personal Information with the Subway® 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 Subway®, you consent to our collection, use, and disclosure of your Personal Information in this manner.

Information Regarding Children

We do not intend for our employment services to be used by anyone under the age of 13. If you are a parent or guardian and believe we may have collected information about a child, please contact us as described in the “Contact Information” section, below.

How We Use Your Personal Information

We collect and use your Personal Information for legitimate human resources and business management reasons, including:

• identifying and evaluating candidates for potential employment, as well as for future roles that may become available;
• provide applicant support and respond to and communicate with you about your requests, questions and comments;
• process Sensitive Personal Information, such as citizenship or nationality information or health information, when relevant for a position and permitted by law;
• establish and manage your Careers Sites account;
• obtain background check information where permitted by law;
• contact you regarding possible employment;
• operate, evaluate and improve our business;
• perform data analyses to improve our recruitment and hiring process;
• if you have a disability and would like Subway® to consider an accommodation;
• protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;
• ensuring compliance with legal requirements, including diversity and inclusion requirements and practices, and our policies;
• even if we do not employ you, we may nevertheless continue to retain and use your Personal Information in accordance with specific country requirements for system administration purposes, to consider you for potential future roles, and to perform research.

Sharing Your Personal Information

In general, access to your Personal Information will be restricted to minimize the number of people in Subway® Group who need it in order to evaluate your application for employment or perform functions supporting our recruiting and talent managing functions. To carry out its hiring and recruiting processes and programs, the affiliated entities within the Subway® may share your Personal Information amongst themselves.

We do not sell or otherwise share your Personal Information, except as described in this Privacy Notice. We may share the Personal Information we obtain with our affiliates for the purposes described in this Privacy Notice. We also share Personal Information with third parties who perform services on our behalf based on our instructions. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

Subway® may be required to disclose certain Personal Information to other third parties (i) as required by law; (ii) to protect Subway®’s legal rights to the extent authorized or permitted by law; or (iii) in an emergency where the health or safety of a prospective employee or other individual may be endangered. In addition, we reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

The Subway Group remains responsible for the personal information that we share with third parties for processing on our behalf in connection with the operation of our business, and we remain liable under this privacy statement if our third parties process your personal information in a manner inconsistent with the Privacy Shield Principles, unless the Subway Group proves that it is not responsible for the matter giving rise to the damage.

Cross-Border Transfers & Privacy Shield

Due to our global operations, prospective employee Personal Information may be transferred to and processed in the United States and other countries that may not be deemed to provide the same level of data protection as your home country. Subway® maintains and applies data protection standards regarding prospective employee Personal Information consistent with those specified in this Privacy Notice to its operations globally.

Additionally, Subway®’s Franchise World Headquarters and other U.S. affiliates: Doctor’s Associates LLC, Franchisee Shipping Center Co., LLC, FWH Technologies, LLC, Subway Franchisee Advertising Fund Trust, Ltd., Subway IP, Inc., Subway MyWay, LLC, Subway Realty, LLC, Subway Real Estate, LLC, comply with the EU-US and Swiss-US Privacy Shield Frameworks and adheres to the Privacy Shield Principles as set forth by the U.S. Department of Commerce (“DoC”) and the Federal Trade Commission (“FTC”) regarding the collection, use, and retention of personal information transferred from the European Union (“EU”) and Switzerland to the United States, respectively. If there is any conflict between the terms in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Program, and to view our certification page, visit https://www.privacyshield.gov.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Franchise World Headquarters and other U.S. affiliates commit to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this Privacy Notice should first contact the Subway® Group’s Privacy Officer (see Contact Information below).

Franchise World Headquarters and other U.S. affiliates are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with respect to the Privacy Shield. Under certain conditions, if you complaint is not satisfactorily resolved with us directly, you may submit Privacy Shield-related complaints to the attention of your DPA: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm, which will establish a panel to investigate and resolve complaints brought under the Privacy Shield. We will fully comply with the advice given by the DPAs and take necessary steps to remediate any non-compliance with the Privacy Shield Principles. Such independent dispute resolution mechanisms are available to EU and Swiss citizens free of charge. Additionally, you may have a right to invoke binding arbitration under the Privacy Shield.

Retention of Your Personal Information

Except as otherwise permitted or required by applicable law or regulatory requirements, Subway® endeavors to retain your Personal Information only for as long as it believes is necessary to fulfill the purposes for which your Personal Information was collected as outlined in this Privacy Notice. We may, instead of destroying or erasing your Personal Information, make it anonymous such that it cannot be associated with or tracked back to you. Security

Although “guaranteed security” does not exist, we are committed to protecting the security of the personal information we collect about you, and we take reasonable physical, electronic, and administrative safeguards (including all steps required by law) to help protect your personal information from unauthorized or inappropriate access, use, loss or modification.

Accessing Your Personal Information

You may reasonably access your personal information by contacting the Subway® Group’s Privacy Officer with regard to the accuracy of your personal information.

Please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information we have about you.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous. In the event that we cannot provide you with access to your personal information, we will information you of the reasons why, subject to any legal or regulatory restrictions.

Updating or Deleting Your Personal Information

We endeavor 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. We will use reasonable efforts to revise it and, if necessary, to use reasonable efforts to inform agents, service providers or other third parties, which were provided with inaccurate information, so records in their possession may also be corrected or updated. However, we reserve the right not to change any personal information we consider accurate.

You may request that we delete the personal information about you that we hold. There are instances where applicable law or regulatory requirements allow or require us to refuse to delete this personal information. In the event we cannot delete your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Automated Decisions

Subway® generally does not make recruiting or hiring decisions based solely on automated decision-making within the meaning of the EU Data Protection Directive. In the event that Subway® relies solely on automated decision-making that could have a significant impact on you, we will provide you an opportunity to express your views and will provide any other safeguards required by law.

Inquiries, Complaints and Objections

You may withdraw consent to the processing of your Personal Information or submit inquiries, complaints and/or objections to the processing of your Personal Information by contacting the Subway® Group’s Privacy Officer. We will try to find a reasonable way to address your concerns. However, we must process personal information where required by law. In other cases, if we cannot process your personal information, you may be denied employment.

If you believe that your personal information is not handled in accordance with applicable law or our Privacy Statement, you may submit a complaint to the Subway® Group’s Privacy Officer. We will investigate the complaint.

Contact Information

This notice provides basic information about our processing of your personal information and your privacy rights. Should you have additional questions, you may contact the Subway® Group’s Privacy Officer:

Subway® Group’s Privacy Team

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

Facsimile: (203) 783-7479

Email Address: [email protected]

Changes to this Privacy Notice

We may change this Privacy Notice at any time. The effective date of each version of this Privacy Notice is identified below as the “Last Revised” date and will take effect immediately after being posted.

Our Group Companies

Subway IP LLC

Franchise World Headquarters, LLC

Franchisee Shipping Center Co., LLC

Franchisee Shipping Center Co., LLC Toronto Branch

Subway International B.V. Sucursal Argentina

Subway Systems Australia Pty. Ltd.

Subway Systems do Brasil Ltda.

Subway Realty e Desenvolvimento de Software do Brasil Ltda.

Subway Subs of Canada, ULC

Subway Brand Management & Consultant (Shanghai) Co., Ltd.

Subway Vermietungs-und Servicegesellschaft m.b.H. -organizacni slozka

Subway International B.V. Ecuador Branch

Subway Realty of France EURL

Subway Vermietungs-und Servicegesellschaft mbH

Subway Realty of the Netherlands B.V. Hong Kong Branch

Subway Systems India Private Limited

Subway Realty of Italy S.r.l.

Subway Japan G.K.

Subway Brand Management Systems Bahrain W.L.L.-Lebanon Branch

Subway International de Mexico, S. de R.L. de C.V.

Subway International B.V.

Subway Systems Singapore Pte. Ltd.

Sandwich and Salad Franchises of South Africa ( Proprietary) Ltd.

Subway International B.V. South Korea Branch

Subway Realty of Spain, S.L.U.

Subway International B.V. Taiwan Branch

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Subway Realty Limited

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.

Cookie Policy

Last Updated: December 07, 2018

At Subway, we want to ensure that your visit to our websites are smooth, reliable and as useful to you as possible. To do this, we use cookies, tags, and other similar technologies. For simplicity, we refer to all these technologies as “cookies”. When you visit our web site, we will use cookies to ensure that you get the best experience on our website. These cookies might be about you, your preferences or your device. The information does not usually directly identify you, but it can give you a more personalized web experience.

Because we respect your right to privacy, you can choose not to allow some types of cookies. Your Internet browser(s) will offer you the option to refuse cookies, but doing so may affect your use of some portions of our web services. Please refer to your browser options to learn more about cookie management.

We use this information to help us recognize you, customize and improve your experience, provide security, analyze usage of our Services (such as to analyze your interactions with the results, reports, and other features of the Services), gather demographic information about our user base, to offer our 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 targeted advertising, please read the Subway Group’s Privacy Statement

TYPES OF COOKIES AND TAGS ON OUR WEBSITES

Strictly Necessary:These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

A preference cookie is required to maintain a record of your Do Not Track preferences, so that we may respect them for future visits.

Functionality (such as language preference): These cookies help us customize our Website content based on a user’s preferences. They remember the user’s choices, their language, the country pages visited, and any changes the user makes to text size or other parts of our Website pages. The information these cookies collect may be anonymized and they cannot track browsing activity on other websites.

Performance cookies (such as those used for Google Analytics): These cookies collect information on how users use our Website, in order to help us fix technical issues or errors, and highlight areas such as navigation where we can improve our Website. For example, Google Analytics uses cookie identifiers to track the number of visitors to the Website, providing us with the volumes and sources of web page traffic. This allows us to analyze web traffic patterns and run tests to optimize web pages and visits against key metrics.

The information collected by Google Analytics itself is anonymous, but if you respond to a marketing email, then a random ID is generated for Google Analytics which we can use along with your email address to manually identify you from other information we already hold in your customer profile. We may then use this information to generate potential sales leads or advertising.

You can find more information about how Google Analytics safeguards your data at:

Interest-Based Advertising / Targeting (such as those used by advertising platforms we may use, such as Facebook or Twitter): These cookies may be set through our site by our advertising partners. They can be used and shared by those companies to build a profile of your interests and show you relevant adverts on other sites. This is based on uniquely identifying your browser and internet device. The website or domain owner can then use the information to try and draw certain conclusions about you, such as, what you might be interested in. For example: after reviewing the information that was sent to the website or domain owner, they might conclude that you are a football fan, a health and fitness enthusiasts, or a person who loves to travel. If you do not allow these cookies, you will experience less targeted advertising.

For more information about digital advertising visit AdChoices at: https://www.youradchoices.com.

Social Media: We allow users to share our Website on social media such as Facebook and Twitter through the use of their cookies. These cookies are not within our control. Please refer to the respective privacy policies of the social media provider for how their cookies work.

To find out more about cookies and your privacy on the web, visit the online resource All About Cookies.

How long will cookies stay on my device?

The length of time a cookie will stay on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted.

HOW TO OPT OUT

First Party Tracking. To opt out of first party tracking (that is, tracking with cookies placed by Subway) on our websites, you may be able to opt out by adjusting the appropriate settings in your browser. Each browser is different, but many common browsers (Internet Explorer, Chrome, Firefox, and Safari) have preferences or options that may be adjusted to allow you to either accept or reject cookies and certain other technologies before they are set or installed or allow you to remove or reject the use or installation of certain technologies altogether. If you want to learn the correct way to modify your browser settings, please use the Help menu in your browser.

Third Party Tracking. To opt out of third party tracking (that is, tracking with cookies placed by persons other than Subway), you can:

• Click here to visit the Network Advertising Initiative site or click here to visit the Digital Advertising Alliance to set preferences and opt out of third party targeting programs
• Click here to opt out of the Google Ad Network (DoubleClick, AdSense)
• Click here to opt out of Google Analytics
• Click here to opt out of Adobe Site Services

To learn more about advertisers’ use of cookies and how to opt-out the following links may be helpful to our visitors:

• European Interactive Digital Advertising Alliance (EU)
• Internet Advertising Bureau (US)
• Internet Advertising Bureau (EU)

Adobe Flash Player Technology. We allow Adobe to set and enable special cookies that are necessary to deliver video content for Adobe Flash Player. You cannot remove Flash cookies simply by changing your browser settings. If you would like to limit the websites that can store information in Flash cookies on your device, you must visit the Adobe website: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

“Do Not Track” Technology. Some newer web browsers have a “Do Not Track” preference that transmits a “Do Not Track” header to the websites you visit with information indicating that you do not want your activity to be tracked. However, we currently do not respond to browser “Do Not Track” signals.

Other helpful resources

Browser manufacturers provide help pages relating to cookie management in their products. Please see below for more information:

• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Android Browser
• Opera
• Opera Mobile

For other browsers, please consult the documentation that your browser manufacturer provides.

HOW TO CONTACT US

If you have questions about our use of cookies, please contact:

The Subway® Group Privacy Team

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

Facsimile: (203) 783-7479

Email Address: [email protected]