Franchise Brands, LLC
- Privacy Statement
- Consent To International Data Transfers
- Consent to Electronic Notice If There is a Security Breach
- Our Use of Your Personal Information and Type of Information We May Collect
- Personal Information We Collect That You Provide Us
- Internet Users – Cookies, Internet Protocol (IP) Address, Aggregate Information
- Compliance With The Digital Advertising Alliance
- Interest-Based/Online Behavioral Advertising
- Children and Data Collection
- A Note to Parents/Guardians—Additional Information About Children’s Privacy
- Collection and Use of Employee Personal Information
- Verifications of Employment
- Medical Information
- Collection and Use of SUBWAY® Franchisee and Prospective Franchisee Information
- Collection and Use of Development Agent Information
- Mobile Information
- Mobile Marketing Promotions and Advertising
- Forward-to-a-Friend and Refer-a-Friend
- Opt-Out of Email Updates
- Sharing of Personal Information
- Storage, Retention and Accuracy of Personal Information
- Access, Control and Update Personal Information About You
- Contact Information
- Links to Non-FWH Web Sites and Third Parties
- Social Media and Online Engagement
- Your California Privacy Rights
- Safe Harbor Compliance
- Members of the European Union
- International Privacy Policies
- Terms and Conditions of Website Use
1. Privacy Statement - (Top)
practices are consistent with:
- The European Union Data Protection Directive and the U.S. Department of Commerce Safe Harbor Program Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.
- Fair information practices established by the Organization for Economic Co-operation and Development (OECD).
- The Asia Pacific Economic Cooperation forum (APEC) Privacy Framework.
FFWH an affiliate of, and service provider to, Doctor’s Associates Inc. (“DAI”), the owner of the SUBWAY® Restaurant System, and the SUBWAY® Group which includes amongst other entities: Subway International B.V. (“SIBV”), Subway Systems Australia Pty Ltd (“SSA”), Subway Franchise Systems of Canada, Ltd. (“SFSC”), Subway Partners Colombia C.V. (“SPCCV”), Subway Systems do Brasil Ltda. (“SSB”), Sandwich and Salad Franchises of South Africa Pty Ltd. (“SSFSA”), Subway Systems India Private Limited (“SSIPL”). DAI owns and licenses the SUBWAY® trademark and SUBWAY® Restaurant System to its affiliates in order to develop SUBWAY® restaurants worldwide. FWH also provides its affiliates with certain services, including but not limited to franchise marketing, franchisee training, and accounting services. FWH, DAI, SIBV, SSA, SFSC, SPCCV, SSB, SSFSA, and SSIPL are collectively referred to herein as the “SUBWAY® Group”.
FWH shares information, including Personal Information, with the SUBWAY® Group and the following SUBWAY® Group advertising entities: Subway Franchisee Advertising Fund Trust, Ltd. (“SFAFT”) is a Connecticut statutory trust, with a business address at 325 Bic Drive, Milford, CT 06461. Subway Franchisee Advertising Fund Trust, B.V. (“SFAFT BV”) is a Netherlands limited liability company, with a business address at Prinsengracht 13, 1015 DK Amsterdam. Subway Franchisee Advertising Fund of Australia Pty. Ltd. (“SFAFA”) is a company limited by shares, with a business address at Level 1, 42 Amelia Street, Fortitude Valley, Queensland, 4006, Australia. Subway Franchisee Advertising Fund of Canada, Inc./Le Fond De Publicité Des Franchisés Subway Du Canada Inc. (“SFAFC”) is a federal corporation, with a business address at Monarch Registries, 11210-107 Avenue NW, Main Floor, Ed Monton, AB T5H 0Y1. The FAF Group administers national and local advertising funds and activity for SUBWAY® restaurants and SUBWAY® franchisees worldwide. SFAFT, SFAFT BV, SFAFA, an SFAFC are collectively referred to herein as the “FAF Group”.
2. Consent - (Top)
3. Consent To International Data Transfers - (Top)
4. Consent to Electronic Notice If There is a Security Breach - (Top)
If FWH or a Recipient is required to provide notice of unauthorized access of certain security systems, you agree that FWH, or the Recipient, may do so when required or voluntarily by posting notice on the Website or sending notice to any email address FWH or the Recipient has for you, in the good faith discretion of FWH or the Recipient. You agree that notice to you will count as notice to any other individual for whom you are acting and agree to provide the notice to any such individual.
5. Our Use of Your Personal Information and Type of Personal Information We May Collect - (Top)
Personal Information is defined as any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, by reference to a Social Security Number and/or Identification Number (hereinafter “SSN/I.N”) or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.
Personal Information shall include, but is not limited to: name (full name or first initial and last name), maiden name, nickname, email address, home address, home postal code, home telephone number, mobile phone number, date of birth, Social Security Number and/or Identification Number, financial information and employment related information such as may be found on resumes, applications, background verification information, or in employment references, photographic images (especially of face or other identifying characteristic, i.e. tattoo’s), video or voice recording.
FWH takes measures to maintain the confidentiality of your SSN/I.N to protect your SSN/I.N from unlawful disclosure, and to limit access to your SSN/I.N. FWH will not make your SSN/I.N available to the general public, print your SSN/I.N on any card, require you to provide your SSN/I.N to access any products or services, transmit your SSN/I.N over the Internet unless the connection is secure or your SSN/I.N has been encrypted, or requires the transmittal of your SSN/I.N to access our Website without requiring additional authentication.
Non-personal information is information that is already a matter of public record or knowledge. Business contact information is considered non-personal information and not subjected to special protection and it can be routinely shared with anyone
inside or outside of the business. Business contact information shall include but is not limited to: business name, business address, business telephone number, and is not considered personal information in certain jurisdictions.
WE DO NOT COLLECT SENSITIVE DATA
Sensitive data is information that can include but is not limited to, an individual’s gender, racial or ethnic origins, politics, religion, trade union membership, veteran status, physical or mental health, disabilities, sex life, sexual orientation, or criminal (or alleged criminal) activities, proceedings or convictions. We will never collect Sensitive Personal Information except to comply with Affirmative Action data requirements.
6. Personal Information We Collect That You Provide Us - (Top)
FWH will not collect customer Personal Information, unless the customer contacts FWH directly. In order to adequately address a customer’s concern, their Personal Information may be shared with our affiliate FWH and other affiliates within the SUBWAY® Group, the appropriate SUBWAY® Group’s area Development Agent and franchisees. The SUBWAY® Group Development Agents assist with franchise sales, site location, training, and provide operational assistance to franchisees. Failure to provide necessary information may prevent FWH from fully addressing any customer concerns.
Holders of SUBWAY® Loyalty Cards and SUBWAY® Gift Cards (collectively the “SUBWAY® Card”) may voluntarily register their cards through www.mysubwaycard.com. Our third party service provider collects Personal Information on a voluntary basis. This information is used as part of the Lost/Stolen Card Program If you do not wish to receive promotional materials with your use of the SUBWAY® Card you may update your preferences at www.mysubwaycard.com. YOU MUST BE thirteen (13) YEARS OLD OR OLDER TO
REGISTER A SUBWAY® CARD.
For Instance, you may choose to communicate with us in some of the following ways:
- Subscription Services, such as, email and newsletters.
- User registration, such as access to www.subway.com, member or non-public member pages.
- Financial Transaction Information, such as, ordering from http://shop.subway.com/, operated by Franchise Shipping Center Company, Inc. (“FSC”); placing a catering order or signing up for a SUBWAY Card at: www.mysubwaycard.com, Subway Express™, www.tellsubway.com, and www.subwaycatering.com, operated by, Value Pay Services, LLC (“VPS”), a wholly owned subsidiary of Independent Purchasing Cooperative, Inc. (“IPC”).
- Promotions and Sweepstakes.
- Surveys and/or Voting.
7. Internet Users - Cookies, Internet Protocol (IP) Address, Aggregate Information - (Top)
Cookies - In addition to Personal Information, we use data collection devices such as "cookies" on certain web pages to help analyze our web page flow and measure promotional effectiveness. A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer's hard disk so that the website can remember who you are. A cookie will typically contain the name of the domain from which the cookie has come, the 'lifetime' of the cookie, and a value, usually a randomly generated unique number. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site and services.
A few important things you should know about cookies are that:
- Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session.
- You may encounter cookies from third parties on certain pages of the sites that we do not control. (For example, if you view a web page created by another user, there may be a cookie placed by that web page.)
Web Beacon - Also called a Web bug or a pixel tag or a clear GIF. We use pixels tags or transparent GIF files, to help manage our online advertising and promotions. These tags collect anonymous (not personally identifiable) information about which advertisements and promotions bring users to our website. With both cookie and tag technology, the information that we collect and share is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address.
Used in combination with cookies, a Web beacon is an often-transparent graphic image, usually no larger than 1 pixel x 1 pixel, which is placed on a Web site or in an e-mail that is used to monitor the behavior of the user visiting the Web site or sending the e-mail. When the HTML code for the Web beacon points to a site to retrieve the image, at the same time it can pass along information such as the IP address of the computer that retrieved the image, the time the Web beacon was viewed and for how long, the type of browser that retrieved the image and previously set cookie values.
Web beacons are typically used by a third-party to monitor the activity of a site. A Web beacon can be detected by viewing the source code of a Web page and looking for any IMG tags that load from a different server than the rest of the site. Turning off the browser's cookies will prevent Web beacons from tracking the user's activity. The Web beacon will still account for an anonymous visit, but the user's unique information will not be recorded.
Internet Protocol (IP) Address - an Internet Protocol (IP) Address is associated with your computer's connection to the internet. FWH may use your IP address to help diagnose problems with FWH’s server, to administer the Website and to maintain contact with you as you navigate through the Website. Your computer's IP address also may be used to provide you with information based upon your navigation through the Website. FWH does not link IP addresses to any Personal Information. Aggregate Information – is used to measure the visitors’ interest in, and use of, various areas of the Website and the various programs that FWH administers, FWH will rely upon aggregate information, which is information that does not identify you, such as statistical and navigational information. With this aggregate information, FWH may undertake statistical and other summary analyses of the visitors' behaviors and characteristics. Although FWH may share this aggregate information with third parties, none of this information will allow anyone to identify you, or to determine anything else personal about you.
8. Compliance with the Digital Advertising Alliance - (Top)
The SUBWAY® Group uses the Evidon assurance platform to comply with the cross-industry Self-Regulatory Program for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA) (http:///aboutads.info). As part of this service, The SUBWAY® Group’s online advertisements and Web sites are sometimes delivered with icons that help consumers understand how their data is being used and provide choice options to consumers that want more control. The list of our advertising partners may be updated from time to time. To opt-out of internet-based advertising by all DAA-participating companies, please visit http://www.aboutads.info/choices/.
9. Interest-Based/Online Behavioral Advertising - (Top)
On some pages of our site we may allow third-party advertising partners to set web tracking tools (e.g., cookies and web beacons) to collect anonymous, non-personally identifiable information regarding your activities on those pages (e.g., your IP address, page(s) visited, time of day). We may also share such information we have collected with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering future targeted advertisements to you when you visit other (non-SUBWAY®) sites within their networks. This practice is commonly referred to as "interest-based advertising" or "online behavioral advertising."
Pages of our website that collect information that may be used by such advertising partners for interest-based advertising purposes may be identified by a link to AdChoices on the page.
Opting out (site pages). If you do not want your browsing while on such pages to be used for interest-based advertising purposes, you may click on the AdChoices link to opt-out of such uses by the listed advertising partner(s). Even if you opt-out through this service, we may still collect non-personally identifiable information regarding your site activities and use it for non-interest-based advertising purposes as described in this privacy statement.
10. Children and Data Collection - (Top)
At FWH, children’s privacy is important to us. FWH adheres to the United States Federal Privacy Protection standards as stated in the Children's Online Privacy Protection Act (“COPPA”). We will not knowingly allow anyone under thirteen (13) to provide us any personally identifying information. Children under thirteen (13) years of age are required to obtain the express permission of a parent or guardian before submitting any Personal Information about themselves (such as their names, e-mail address, and phone number) over the Internet. If a child has provided us with personally-identifiable information without the consent of a parent or guardian, the parent or guardian of that child should contact the Privacy Officer immediately at email@example.com. We will use reasonable efforts to promptly delete the child's information from our
11. A Note to Parents/Guardians—Additional Information about Children’s Privacy - (Top)
The Children's Online Privacy Protection Act ("COPPA") requires that we inform parents and legal guardians about how we collect, use, and disclose personal information from children under thirteen (13) years of age; and that we obtain the consent of parents and guardians in order for children under thirteen (13) years of age to use certain features of our website. Also, when we use the term "parent", we mean to include legal guardians.
Children can participate in many of our features without providing personally identifiable information. However, to enable their participation in certain interactive features, we may ask children to provide us with personally identifiable information. The types of information we may request include first name as well as the child’s and parent’s email addresses. We use a child’s email address to respond to a specific request to participate in an activity (e.g., participate in a contest or sweepstakes, respond to their question, enable them to subscribe to a newsletter). We use parents’ e-mail addresses to obtain their consent or notify them of their child's online activities and enable the parent to unsubscribe the child from a newsletter or other similar activity.
At any time parents can refuse to permit us to collect further personal information from their child and can request that any personal information we have collected be deleted from our records.
We will provide parents notice by e-mail of any material changes in the way we intend to collect, use, and/or share their child’s personal information. Please note that, at all times, parents should update their personal information to provide us a current email address.
If you would like to review any personally identifiable information that we have collected online from your child, have this information deleted, and/or request that there be no further collection or use of your child's information, or if you have questions about these information practices, you may contact our Privacy Officer:
Franchise World Headquarters, LLC
325 Bic Drive
Milford, CT 06461
Telephone Number: (203) 877-4281 or Toll Free: 1-800-888-4848
Facsimile: (203) 876-6690
Email Address: firstname.lastname@example.org
12. Collection and Use of Employee Personal Information - (Top)
It is the policy of FWH to keep all past and present employee information private from disclosure to third parties, accept for where there are certain business related exceptions, such as:
- To comply with county, state or federal agency requests;
- Inquiries from third parties with a signed authorization from the employee to release the information, except in situations where limited verbal verifications are acceptable (see below);
- Third parties with which FWH has contractual agreements to assist in administration of company sponsored benefits.
13. Verifications of Employment - (Top)
Prospective employers, state agencies, financial institutions, and residential property managers routinely contact FWH requesting information on a former or current employee's work history and salary. All such requests of this type shall be referred to and completed on a confidential basis by the Human Resources Department or Payroll Department.
For written verification of employment requests, information will be provided on the form only when it is accompanied by an employee's signed authorization to release information. The form will be returned directly to the requesting party and filed as part of the Human Resources or Payroll Department’s confidential records.
Franchise Brands will not collect applicants Personal Information, unless the applicant contacts Franchise Brands directly. In the future, we may use this information to contact you regarding products or promotions, as well as other products and services, which may be of interest to you. If you do provide us with Personal Information we may use the information to contact you, via e-mail, regular mail, telephone or other means, to provide you with information you requested about specific products or services, provide additional future information about products or services that may be of interest to you, and to learn about and develop products and services. At any time you may “opt out” of future contacts by un-subscribing from our database or contacting the Privacy Officer.
14. Medical Information - (Top)
FWH is compliant with federal HIPAA regulations and only utilizes information related to the company sponsored healthcare plan on a "need to know" basis for administration of the healthcare plan.
15. Collection and Use of SUBWAY® Franchisee and Prospective Franchisee Information - (Top)
If you choose to, you may submit via www.subway.com an electronic application seeking consideration as a prospective SUBWAY® franchisee. By submitting an electronic application, you agree that we may disclose your personal information to our affiliates within the SUBWAY® Group, their Development Agents, other SUBWAY® Group affiliates, and third party service providers as part of their consideration to your inquiry and to help them conduct their franchise marketing efforts. Information on your online form will become part of any application for a franchise that you might later submit. We require our affiliates within the SUBWAY® Group and their Development Agents to respect FWH privacy practices and not use your personal information for purposes other than to carry out our instructions.
Personal Information collected from prospective franchisees include, but is not limited to: name, address, telephone number, facsimile number, email address, date of birth, citizenship, educational background, criminal background, bank account information for Electronic Funds Transfer, financial statement, litigation history, and taxpayer identification number. Failure to provide requested Personal Information may negatively impact a prospective franchisee’s ability to become a franchisee. Once a prospective SUBWAY® restaurant franchisee becomes a franchisee, they may then reference themselves by their Franchise Agreement Number. In order to better service franchisees, a franchisee’s Personal Information may be shared between FWH and its affiliates within the SUBWAY® Group, pursuant to the service contracts between them.
In order to effectively implement the SUBWAY® Gift Card Program, and to provide purchasing services to members, a franchisee’s Personal Information may be shared with an independent purchasing cooperative or other independent third party. The Personal Information shared with the independent purchasing cooperative shall include, but will not be limited to: name, address, credit card information, and other related information necessary for billing purposes, such as a mailing address for credit card validation, and bank account information, you provided to FWH to establish your pre-authorized account for the payment of royalties, advertising fees, and other charges. Subject to a franchisee’s agreement with the independent purchasing cooperative, the independent purchasing cooperative may bill a franchisee’s bank account for fees and other costs associated with the SUBWAY® Gift Card Program. If a franchisee does not wish to disclose this information, they must notify the Privacy Officer in writing as described in the section titled “Contact Information” below.
A franchisee and/or prospective franchisee’s information may be shared with the SUBWAY® Group Development Agent in their area. A Development Agent is an independent contractor of the SUBWAY® Group. The Development Agents assist with franchise sales, site location, service franchisee leasing needs, provide operational assistance and related administrative functions, and training to the franchisee. Development Agents also make recommendations as to whether a prospective franchisee in their territory should be granted a franchise. The Development Agent may use this information to: address a franchisee’s concerns in a customer complaint, respond to a franchisee’s inquiries for franchise sales, franchisee Personal Information may be shared during store transfers, and any other inquiry which may require a response. Finally, franchisee Personal Information may also be shared with Subway Franchisee Advertising Fund Trust (“SFAFT”) in order to provide advertising services to member stores.
Finally, upon becoming a SUBWAY® franchisee you consent to FWH disclosing former or past franchisee contact information including Personal Information in its Disclosure Document for one (1) year after leaving the system, as required by law, unless you advise otherwise. Contact our Privacy Officer in writing, either by email or regular mail received, of your desire to not have your details or contact information disclosed, corrected or changed when you sell or transfer your SUBWAY® store, or exit the SUBWAY® system (whether by termination or otherwise). To contact the Privacy Officer, please see the section provided below entitled “Contact Information”.
16. Collection and Use of Development Agent Information - (Top)
By applying to become a SUBWAY® Development Agent via www.subway.com, an applicant consents to the collection, use, and disclosure of Personal Information in accordance with the following terms and conditions. We collect and use Personal Information in order to assist you in applying, and evaluating you to become a SUBWAY® Development Agent. Personal Information is collected to assist FWH and its affiliates within the SUBWAY® Group in selecting Development Agent candidates and for the purpose of operating a development territory.
Personal Information collected includes, but is not limited to: name, home address, home telephone number, facsimile number, email address, date of birth, bank account information for Electronic Funds Transfer, financial statement, resume, taxpayer identification number and background checks. Once a Development Agent candidate becomes a Development Agent, they may then reference themselves by their Development Agent Number. Failure to provide necessary information may negatively impact your ability to become a Development Agent.
Finally, as a Development Agent within the SUBWAY® Group certain business information with respect to stores within your territory may be shared in the aggregate amongst your DA community. Such business information may include, but is not limited to, 3 year DA Performance Report, Emerging Market Developing Activity Report, Developed Market Report, Subway Compared to other QSR Report, and the Weekly Same Store AUV and Units Report.
17. Mobile Information - (Top)
You may submit Personal Information via your cell phone, smartphone, and tablet. If you use any location-enabled products, you may be sending us location information. FWH does not store or use this information other than to provide the service you requested. For example, a mobile product may use GPS data to find a nearby restaurant you requested. Location-enabled features are opt-in and you have control over your participation and can turn these services off at any time.
FWH uses a variety of new technologies and social media options to communicate and interact with consumers. These websites and mobile applications include popular social networking and media sites, such as, Twitter and Facebook. If you post updates to or receive updates from www.twitter.com, www.facebook.com, and other social networking websites, during the Promotion Period via SMS from your wireless phone, your wireless-service provider may charge you for each text message you send and receive. You must consult your wireless service provider regarding its pricing plans, as rates may vary. Use of third party social networking websites, such as, Twitter and Facebook, are governed by the privacy practices of those websites. FWH does not capture or store your login information or any other personally identifiable information for Twitter, Facebook, and other social networks, however, session information or cookies may be stored on your wireless phone, by their websites.
Mobile Information We Collect
- Some mobile applications will utilize Google Analytics (or similar tool) to help us better serve our customers through improved products, services, and revisions to the mobile applications. This collected information will not identify you to FWH. It may, however, let us know anonymously, which services and features you are using the most within the application, as well as device type and hardware features, country and language of download.
- Use of 3rd party services such as social sharing sites (e.g., Facebook and Twitter) is governed by the privacy practices of those services. FWH does not capture or store your login information or other personally identifiable information for these services, however session info or cookies may be stored.
Mobile Information Sharing
- FWH does not share any collected information with 3rd parties with the following exceptions:
- FWH may provide some personal data to third-party partners that are providing services essential to your mobile user experience.
- All requests are sent through your mobile carrier's network and your carrier may have access to it. Consult your carrier's privacy policies for additional information.
- Certain mobile products and services and manufacturers allow you to interact and share your information with others. For example, you may want to Tweet or post to your Facebook page content from a FWH mobile application. Consult your mobile device manufacturer, or mobile product or application developer's privacy policies for additional information.
18. Mobile Marketing Promotions and Advertising - (Top)
(only if specifically requested), and your mobile carrier's name.
Please note that most wireless transmissions are not secured and there is a greater risk of an unknown third party's interception of messages or a user's Personal Information when using a wireless communications device.Users that register for FWH's wireless services acknowledge, understand and agree that they may be charged by the user's wireless carrier for all messages between FWH and the user. Standard messaging rates will apply, unless noted otherwise. Under no circumstances will our website, FWH, the SUBWAY® Group, or its affiliates be held responsible for any wireless email or text messaging charges incurred by a user or by a person that has access to a user's wireless device, telephone number, or email address.
Termination of Wireless Services by User - Users may revoke their consent to receive mobile messages for marketing promotions from FWH and/or its affiliates by the following procedure:
A user may cancel one or more services via his/her wireless device at any time by using the unsubscribe mechanism provided by FWH at the time the message is sent, or by sending a text message that says "STOP", "END", "CANCEL", "REMOVE", "UNSUBSCRIBE"
or "QUIT". FWH will terminate the user's registration for the most recent wireless service sent to the user. Any of these words followed by the word "ALL" in the user's termination request will cancel all of the user's registered wireless services with FWH. If the user unsubscribes from one or all of FWH service(s) via his or her wireless device, the service(s) will be terminated immediately and will cancel the user's previous opt-in. Use of Information - FWH will not use a wireless telephone number, wireless or conventional internet email address, or other Information submitted for its wireless marketing promotions for any other purpose than to provide the services requested, unless we provide to you advance notice of any other use. We will not share any Personal Information with third party service providers unless you opt-in for such disclosure.
19. Forward-To-A-Friend and Refer-A-Friend - (Top)
You may use a referral feature (either on a web page, in an e-mail, from a banner ad or other communication) to inform a friend about a FWH web page or promotion. FWH may use any e-mail address provided when using this referral feature to send both an initial e-mail and a subsequent e-mail to recipients about the particular promotion, product, or service in which you indicated your "friend" may have an interest.
20. Opt-Out of Email Updates - (Top)
You may have the opportunity to elect to receive email communications from FWH. FWH will only email you if you elect to receive them. If you elect to receive email communications, FWH will send you occasional updates about new additions to the Website as well as special offers and promotions of which you can take advantage. If at any time you decide you would rather not receive these types of communications from FWH, you can opt-out by clicking the unsubscribe link at the bottom of any FWH email, update the contact preferences for your account, or contact the Privacy Officer at email@example.com.
21. Sharing of Personal Information - (Top)
The Personal Information you provide FWH is considered a company asset and may be disclosed and/or transferred to a third party in the event of a proposed or actual purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, or financing of all or any portion of FWH or of any of the business assets or shares of FWH or a division thereof, in order for a customer to continue to receive the same products and services from the third party.
Although we make every effort to preserve user privacy, we reserve the right to disclose Personally Identifiable Information to a third party in certain limited circumstances, specifically: to comply with a law, regulation, search warrant, subpoena, judicial proceeding, a court order, or as otherwise may be required by law, to enforce our policies or contracts, to collect amounts owed to us, to protect users of our sites from fraudulent or abusive use, during emergencies when safety is at risk, as determined by FWH, or otherwise where necessary for the establishment, exercise or defense of legal claims. In addition, from time to time, server logs may be reviewed for security purposes; for example, to detect unauthorized activity on the web site. In such cases, server log data, containing IP addresses, would be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
As described above, FWH, its affiliates within the SUBWAY® Group, third party service providers, and SUBWAY® Development Agents may share and exchange Personal Information in order to process franchisee applications, administer the SUBWAY® franchise system, and protect the integrity of the SUBWAY® franchise system and trademarks. Personal Information may be provided to a courier or freight forwarder to fulfill an order, which may have been requested from us.
22. Security - (Top)
Phishing- Identity theft and the practice currently known as “phishing” are of great concern to FWH. Accordingly, safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, Social Security Number or National Identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
23. Storage, Retention, and Accuracy of Personal Information - (Top)
All reasonable steps are taken to safeguard your Personal Information against loss; unauthorized access, use, modification, disclosure; or any other misuse. We take all reasonable steps to insure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading. FWH will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws and your consent to such purpose(s) remains valid after termination of our relationship with you.
FWH may store your Personal Information in its databases located in the United States and/or other countries outside of the European Economic Area (“EEA”). Additionally, some of our service providers may reside in the United States or other countries outside of the EEA and will be subject to the laws of the local jurisdiction. As a result, in certain circumstances, the United States and other foreign governments, courts, law enforcement agencies or regulatory agencies may be entitled to access the Personal Information collected and held by FWH.
24. Access, Control, and Update Personal Information - (Top)
You may contact the Privacy Officer to access, correct or delete your Personal Information. If necessary, the Privacy Officer will contact another individual to assist in completing your requested task. We want to be sure that we keep only the most accurate and up-to-date Personal Information in our records. You can email us at firstname.lastname@example.org to update your contact information. To protect your privacy, we will take reasonable steps to help verify your identity before granting access or making changes.
25. Contact Information - (Top)
If you have any questions or concerns, please contact: Privacy Officer
Franchise World Headquarters, LLC
325 Bic Drive
Milford, CT 06461
Telephone Number: (203) 877-4281 or Toll Free: 1-800-888-4848
Facsimile: (203) 876-6690
Email Address: email@example.com
We will address your concern and attempt to resolve any problem. Download Privacy Information Request Form here: http://www.subway.com/subwayroot/InfoRequestForm.pdf.
26. Links to Non-FWH Web Sites and Third Parties - (Top)
27. Social Media and Online Engagement - (Top)
FWH and the SUBWAY® Group, use a variety of new technologies and social media options to communicate and interact with consumers. These sites and applications include popular social networking and media sites, open source software communities and more. To better engage the public in ongoing dialog, the SUBWAY® Group uses several third-party platforms including, but not limited to, Facebook, Twitter, and YouTube. Third-Party Websites and Applications (TPWA) are Web-based technologies that are not exclusively operated or controlled by the SUBWAY® Group. When interacting with the SUBWAY® Group presence on those websites, you may reveal certain personal information to the SUBWAY® Group or to third parties. Except when used by the SUBWAY® Group employee’s for the purpose of responding to a specific message or request, the SUBWAY® Group will not use, share, or retain your personal information.
At this time, the SUBWAY® Group has three Social Media Accounts, Facebook.com/subway, Twitter.com/subwayfreshbuzz (we also own and in the near future will be migrating our Twitter Account to twitter.com/subway), and Youtube.com/subway. Facebook: On the Facebook.com/subway Facebook page, the SUBWAY® Group staff posts news and other items of interest to individuals. If you have a Facebook account or 'Like' Facebook.com/subway Facebook page, you can post comments or click on the 'like' option for individual entries. If you comment or click on the 'like' button, personally identifying information will be visible to the SUBWAY® Group staff and other Facebook site visitors. The amount of visible personal information will depend on your own Facebook privacy settings. You can completely avoid displaying any personally identifiable information by not creating an account, not posting comments and not clicking on the 'like' options in Facebook. the SUBWAY® Group staff does not collect, use or disclose any information about visitors who comment or 'like' the SUBWAY® Facebook site. Facebook collects and reports on non-personally identifiable information about activities on Facebook pages. This information is password protected and only available to the SUBWAY® Group employees, members of the SUBWAY® Communications and Web Teams,
28. Your California Privacy Rights (As provided by California Civil Code Section 1798.83) - (Top)
29. Safe Harbor Compliance - (Top)
FWH is in compliance with the U.S. Department of Commerce Safe Harbor requirements regarding the transfer of personal information from the European Economic Area (“EEA”) or Switzerland to the United States. FWH has been Self-Certified under the Safe Harbor privacy frameworks as set forth by the U.S. Department of Commerce, European Commission and Switzerland regarding the collection, storage, use, transfer and other processing of personal data transferred from the European Economic Area or Switzerland to the U.S., in accordance with the EU Directive on Personal Data Protection. The principles of Safe Harbor compliance are:
- Notice - Individuals must be informed that their data is being collected and about how it will be used;
- Choice - Individuals must have the ability to opt out of the collection and forward transfer of the data to third parties;;
- Onward Transfer - Transfers of data to third parties may only occur to other organizations that follow adequate data protection principles;
- Security - Reasonable efforts must be made to prevent loss of collected information;
- Data Integrity - Data must be relevant and reliable for the purpose for which it was collected;
- Access - Individuals must be able to access information held about them, and correct or delete it if it is inaccurate;
- Enforcement - There must be effective means of enforcing these rules.
Further information regarding the Safe Harbor principles and certification process can be found at www.export.gov/safeharbor. In addition, the U.S. Department of Commerce maintains a list of all compliant organizations, which can be accessed at http://web.ita.doc.gov/safeharbor/shlist.nsf/webPages/safe+harbor+list.
30. Members of the European Union - (Top)
If you are a resident of the European Economic Area (“EEA”) or Switzerland and have any concerns or complaints, please first address these issues to the Privacy Officer. FWH is located in the United States, as are the servers that make their site available. All matters relating to privacy issues and this website are governed by the laws of the United States and the State of Connecticut. If the Privacy Officer does not satisfactorily address a complaint within thirty (30) days, any dispute, controversy or claim shall be settled by an arbitration administered by an arbitration agency, such as the American Arbitration Association (“AAA”). All arbitrations will be conducted in English. Judgment rendered by the arbitrator may be entered in any court having jurisdiction. The costs of the arbitration will be borne equally by the parties. Connecticut, U.S.A. shall be the site of all hearings, and such hearings shall be before a single arbitrator. You may also submit complaints to the Federal Trade Commission at http://www.ftc.gov/ftc/complaint.htm or via phone at (202) 382-4357.
31. International Privacy Policies - (Top)
32. Members of the European Union - (Top)
33. Terms and Conditions of Website Use - (Top)
LAST UPDATED: 03/26/13