In an effort to comply with the law, and our commitment to protect your personal information, we provide the following, which discloses our policies. Please note that this Privacy Policy does not govern the privacy policies and procedures of DAI’s independently owned and operated SUBWAY® stores.

What type of information do we collect?
Personal Information is 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 an identification number 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: identifying information such as name, home address, home telephone number, e-mail address, Social Security number, financial information and employment-related information such as may be found on resumes, applications, background verification information, or in employment references.  

DAI takes measures to maintain the confidentiality of your Social Security Number, to protect your Social Security Number from unlawful disclosure, and to limit access to your Social Security Number.  DAI will not make your Social Security Number available to the general public, print your Social Security Number on any card, require you to provide your Social Security Number to access any products or services, transmit your Social Security Number over the Internet unless the connection is secure or your Social Security Number has been encrypted, or require the transmittal of your Social Security Number to access our Website without requiring additional authentication.

We will not collect Sensitive Personal Information, except to comply with Affirmative Action data requirements.  Sensitive Personal Information can include but is not limited to: information pertaining to gender, disabilities and veteran status.

Cookies – Internet Users
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. Cookies are pieces of information a website sends to an individual’s hard drive while they are viewing the website. Cookies allow the website to remember important information that will make your visit to the site more useful. We use cookies to help improve your future visits. If you do not wish to receive a cookie or if you wish to set your browser to warn you each time a cookie is being sent, or if you wish to turn off all cookies, use the options on your browser to assist you. The “Help” option on your browser may assist you in changing your cookie preferences. Please note that by turning cookies off, you will not have access to many features available on our website.

Children and Data Collection
DAI adheres to the federal privacy protection standards as stated in the Children's Online Privacy Protection Act (“COPPA”).  We care about the safety of children. We will not knowingly allow anyone under 13 to provide us any personally identifying information. Children under 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 privacyofficer@subway.com. We will use reasonable efforts to promptly delete the child's information from our servers.

A Special Note about Children who reside in the State of Maine, USA
DAI adheres with the Maine state law titled "An Act To Prevent Predatory Marketing Practices against Minors". The law applies to the collection and use of personal information for marketing purposes of children who are under the age of 18.  DAI’s website www.subway.com is not intended to solicit information of any kind from children under 18 years of age. It is possible that due to fraud or deception by others, we may unknowingly receive information pertaining to children under 18 years of age. If this is the case, the parent or guardian of the minor must notify the Privacy Officer immediately at privacyofficer@subway.com. Once we have verified the accuracy of the information received by the parent or guardian regarding the child under 18 years of age, we will promptly delete the child’s information from our servers. 

Our Use of Your Information
We use your Personal Information to facilitate the services you request. We have tailored our Privacy Policy to adequately inform you of the use of your Personal Information.

Collection and Use of Employee Personal Information
DAI also collects Personal Information from its employees and applicants (human resource data) in connection with administration of its Human Resources programs and functions.  These programs and functions include, but are not limited to: job applications and hiring programs, compensation and benefit programs, performance appraisals, training, access to DAI facilities and computer networks, employee profiles, internal intranet employee directories, Human Resource recordkeeping, Affirmative Action data, and other employment related purposes.

It is the policy of DAI to keep all past and present employee information private from disclosure to third parties. There are certain business related exceptions and they are:

1. To comply with county, state or federal agency requests;
2. Inquiries from third parties with a signed authorization from the employee to release the information, except in situations where limited verbal verifications are acceptable (see below);
3. Third parties with which DAI has contractual agreements to assist in administration of company sponsored benefits.

Verifications of Employment
Prospective employers, state agencies, financial institutions, and residential property managers routinely contact DAI requesting information on a former or current employee's work history and salary. All such requests of this type shall be referred to and completed on a confidential basis by the Human Resources Department or Payroll Department.

For written verification of employment requests, information will be provided on the form only when it is accompanied by an employee's signed authorization to release information. The form will be returned directly to the requesting party and filed as part of the Human Resources or Payroll Department’s confidential records.

Medical Information
DAI is compliant with federal HIPAA regulations and only utilizes information related to the company sponsored healthcare plan on a "need to know" basis for administration of the healthcare plan.

Collection and Use of Customer Information
DAI will not collect customer Personal Information, unless the customer contacts DAI directly. In order to adequately address a customer’s concern, their Personal Information may be shared with the area Development Agent and franchisee. Development Agents assist with franchise sales, site location, training, and provide operational assistance to franchisees. Failure to provide necessary information may prevent DAI from fully addressing any customer concerns.

If you are a participant in the Online SUBWAY® Store, we ask for contact information, name, shipping address, phone number, e-mail address, credit card information, and other related information necessary for billing purposes, such as a mailing address for credit card validation. 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. At any time you may “opt out” of future contacts by un-subscribing from our database or contacting the Privacy Officer.

A customer participating in Subway Express™ through the www.subway.com website will be asked to provide Personal Information. Our third party service provider collects and processes customer information to expedite orders placed on Subway Express™. The Personal Information collected shall include, but will not be limited to:  name, e-mail address, telephone number, and credit card information. Our third party service provider forwards this information to franchisees in order to fulfill the services offered through Subway Express™.

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. Information you may be asked to provide could include but is not limited to: date of birth, card number, and e-mail address. Your purchase history may also be linked to this information.  This information is used as part of the Lost/Stolen Card Program and to provide you with targeted offers from us or from selected third parties, i.e. suppliers of products offered through the SUBWAY® system. 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. Information is also collected in aggregate that is not considered Personal Information, concerning the food items purchased and the demographics of the purchasers. This information may be shared with DAI and its affiliates to improve our product marketing and advertising. YOU MUST BE 13 YEARS OLD OR OLDER TO REGISTER A SUBWAY® CARD.

Collection and Use of Franchisee and Prospective Franchisee Information
By applying to become a SUBWAY® franchisee, a prospective franchisee 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 a prospective franchisee in applying to become a SUBWAY® restaurant franchisee and to assist DAI in selecting franchisee candidates.

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 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 DAI and its affiliates, 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 DAI 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 prospective franchisee’s information may be shared with the Development Agent in their area. A Development Agent is an independent contractor of DAI or one of its affiliates. Development Agents assist with franchise sales, site location, training, and provide operational assistance. 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 inquires for franchise sales, and any other inquiry which may require a response.

A franchisee’s information may be shared with our third party service provider in order to implement Subway Express™ through the www.subway.com website. Franchisees may provide information to the third party service provider directly or DAI may supplement additional franchisee information to our third party service provider.

DAI will also share Personal Information in order to service franchisee leasing needs and related administrative functions. Franchisee Personal Information may be shared during store transfers. Finally, franchisee Personal Information may 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 DAI 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.  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”.

Collection and Use of Development Agent Information
By applying to become a SUBWAY® Development Agent, a Development Agent applicant consents to the collection, use, and disclosure of Personal Information in accordance with the following terms and conditions. We collect and use information in order to assist you in applying, and evaluating you to become a Development Agent. Personal Information is collected to assist DAI and its affiliates 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.

Sharing of Personal Information
We may share Personal Information with our service providers, consultants and affiliates for our internal business purposes. Except as described in this Privacy Policy, DAI will not share Personal Information with a third party, unless a customer requests, consents to such disclosure, or disclosure is required or authorized by law. DAI reserves the right to disclose Personal Information to a third party if a law, regulation, search warrant, subpoena, or court order legally requires or authorizes us to do so. DAI also reserves the right to disclose and/or transfer Personal Information to a third party in the event of a proposed or actual purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, or financing of all or any portion of DAI or of any of the business or assets or shares of DAI or a division thereof in order for a franchisee or Development Agent to continue to receive the same products and services from the third party.

As described above, DAI, its affiliates, third party service providers and Development Agents may share and exchange Personal Information in order to process franchisee and Development Agent applications, administer the SUBWAY® franchise system, implement the SUBWAY® Gift Card program, implement Subway Express™ and protect the integrity of the SUBWAY® franchise system and trademarks. Personal Information may be provided to a courier or freight forwarder in order to fulfill an order, which may have been requested from us.

Our Development Agents and other service providers are prohibited from using Personal Information for any purpose other than to provide assistance. Development Agents are required to protect Personal Information disclosed by us and to comply with the general privacy principles described in this Privacy Policy.

Storage, Retention and Accuracy of Personal Information
DAI insures that Personal Information is safeguarded against loss, access, use, modification, disclosure or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your Personal Information.

DAI will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purpose(s) remains valid after termination of our relationship with you.

We take all reasonable steps to insure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading.

DAI may store your Personal Information in its databases located in the United States and/or other countries outside of the United States.  Additionally, some of our service providers may reside in the United States or other countries outside of the United States 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 DAI.

Contact Information
You may contact the Privacy Officer to access, correct or delete your Personal Information. If necessary, the Privacy Officer will contact another employee to assist in completing your requested task.

If you have any questions or complaints, please contact the Privacy Officer. The Privacy Officer can be reached by telephone at: (203) 877-4281 or 1-800-888-4848; by Facsimile at: (203) 876-6690; by email at: privacyofficer@subway.com; or by mail at Doctor’s Associates Inc., 325 Bic Drive, Milford, CT, 06461, USA. We will address your concern and attempt to resolve any problem. Download Privacy Information Request Form here.

Links to Non-DAI Web Sites and Third Parties
Please note that DAI or SUBWAY® web sites may contain links to other web sites for your convenience and information.  DAI does not control those sites or their privacy practices, which may differ from www.subway.com.  DAI’s privacy policy cannot and does not apply to external Web areas.  We do not endorse or make any representations about third party web sites.  The personal data you choose to give to unrelated third parties is not covered by the DAI privacy policy.  We encourage you to review the privacy policy of any company or website before submitting your Personal Information.  Some third parties may choose to share their personal data with DAI; that sharing is governed by that third party company’s privacy policy.

Safe Harbor Compliance
DAI is in compliance with the U.S. Department of Commerce Safe Harbor requirements regarding the transfer of personal information from European Union member countries to the United States.  DAI has been Self-Certified 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.

REVISED:   DAI  09/03/09