Table of Contents
SFAFT operates as the advertising part of the SUBWAY® Group’s advertising entities, which includes, but is not limited to: 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, and SFAFC are collectively referred to herein as the “FAF Group”.
SFAFT shares information, including Personal Information with the SUBWAY® Group, which includes, but is not limited to: Franchise World Headquarters, LLC (“FWH”), which operates as a service-oriented company for and on behalf of the SUBWAY® System worldwide by providing core business related services for the following franchising entities: Doctor’s Associates Inc. (“DAI”). DAI owns and licenses the SUBWAY® trademark and SUBWAY® Restaurant System to its affiliates, including, but not limited to, 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”) and Subway Systems India Private Limited (“SSIPL”), in order to develop SUBWAY® restaurants worldwide. FWH, DAI, SIBV, SSA, SFSC, SPCCV, SSB, SSFSA, and SSIPL are collectively referred to herein as the “SUBWAY® Group”.
If SFAFT or a Recipient is required to provide notice of unauthorized access of certain security systems, you agree that SFAFT, or the Recipient, may do so when required or voluntarily by posting notice on the Website or sending notice to any email address SFAFT or the Recipient has for you, in the good faith discretion of SFAFT 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.
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, home address, home zip code, home telephone number, mobile phone number, email address, 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.
SFAFT 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. SFAFT 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.
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.
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:
Cookies can expire at the end of a browser session (from when a user opens the browser window to when they exit the browser) or they can be stored for longer. There are many different types and uses of cookies, but most can be classified in a number of different ways.
First and Third Party Cookies – whether a cookie is ‘first’ or ‘third’ party refers to the website or domain placing the cookie. First party cookies in basic terms are cookies set by a website visited by the user - the website displayed in the URL window. Third party cookies are cookies that are set by a domain other than the one being visited by the user. If a user visits a website and a separate company sets a cookie through that website this would be a third party cookie.
Session Cookies – allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes such as remembering what a user has put in their shopping basket as they browse around a site. They could also be used for security or to facilitate use of webmail. These session cookies expire after a browser session and would not be stored long term.
Persistent Cookies – are stored on a users’ device in between browser sessions which allows the preferences or actions of the user across a site (or in some cases across different websites) to be remembered. Persistent cookies may be used for a variety of purposes including remembering users’ preferences and choices when using a site or to target advertising. Persistent cookies are also used to track visitor behaviour as they move around a site, this data is used to try and understand what people do and don't like about a site. This practice is known as Web Analytics. Analytics cookies are probably the most common form of persistent cookies in use today.
To opt out of being tracked by Google Analytics across all websites visit: http://tools.google.com/dlpage/gaoptout.
Secure Cookies - Secure cookies are only transmitted via HTTPS - which you will typically find in the checkout pages of online shopping sites. This ensures that any data in the cookie will be encrypted as it passes between the website and the browser.
Disabling/enabling cookies - You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our site if cookies are disabled. For more information about cookies, including how to see what cookies have been set and how to manage, block and delete them, visit www.allaboutcookies.org. The website www.allaboutcookies.org gives you detailed step by step guidance on how to control and delete cookies depending on your browser type. You can adjust your browser settings to your preferred level of protection.
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, that 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. SFAFT may use your IP address to help diagnose problems with SFAFT’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. SFAFT 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 SFAFT administers, SFAFT will rely upon aggregate information, which is information that does not identify you, such as statistical and navigational information. With this aggregate information, SFAFT may undertake statistical and other summary analyses of the visitors' behaviors and characteristics. Although SFAFT 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.
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, visit http://www.aboutads.info/choices/.
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.
SFAFT 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 firstname.lastname@example.org. We will use reasonable efforts to promptly delete the child's information from our servers.
At SFAFT, children’s privacy is important to us. Therefore, we take additional measures to help children protect their privacy while online including not asking them to disclose more personally identifiable information than is necessary for them to participate in an activity and encouraging them to use non-personally identifiable screen names rather than their real names.
SFAFT is dedicated to protecting your privacy and handling any personal information we obtain from you with care and respect. This Children's Privacy Statement is designed to answer your questions regarding our privacy policies and principles with respect to children under the age of 13. SFAFT recognizes the need to provide additional privacy protections when children visit our website at www.subwaykids.com.
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 13 years of age; and that we obtain the consent of parents and guardians in order for children under 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 of our 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. The Privacy Officer can be reached by telephone at: (203) 877-4281 or 1-800-888-4848; by Facsimile at: (203) 783-7479; by email at: email@example.com; or by mail at SFAFT, In Care of, Franchise World Headquarters, LLC, 325 Bic Drive, Milford, CT, 06461, USA.
We may collect Personally Identifiable Information from you such as your name, home address and/or other Personal Information in order for you to enter a SUBWAY® sweepstakes or to request a SUBWAY® coupon. The Personal Information that you submit is gathered only on a voluntary basis.
We may collect limited Personally Identifiable Information, including, but not limited to your name and/or any "nickname", date of birth, email and/or home address, and any other information that would allow someone to identify or contact you, as well as information about your personal product preferences, survey responses and online activities, if any.
We may collect Personal Information for one of several different purposes, such as:
We may combine this information to help us identify our visitors' preferences or interests with other general or publicly available information.
You can choose not to allow us to use or your Personally Identifiable Information for direct marketing purposes by indicating your preference at the time of collection, by responding to the promotional email in the manner provided for or by contacting our Privacy Officer at firstname.lastname@example.org. If you have not opted-out of receiving marketing materials, we may also use your Personal Information to promote and market additional goods, services, and special offers from us and/or SFAFT’s affiliates. Otherwise, we do not provide your information to third parties for their own direct marketing purposes. At any time you may "opt out" of future contact from SFAFT by un-subscribing from our contact list or contacting the Privacy Officer at email@example.com.
We sometimes use the non-Personally Identifiable Information that we collect to improve the design and content of our site and to enable us to personalize your Internet experience. We may use this information in the aggregate (grouped with information from other users) to analyze site usage, as well as to offer you products, programs, or services.
Generally, we seek your consent for the use of your Personal Information at the time of collection. The form of consent we seek, including whether it is express or implied, will largely depend on the sensitivity of the information and the reasonable expectations of the individual in the circumstances. You may withdraw consent at any time. If you wish to withdraw consent, please contact our Privacy Officer in the manner described below.
Mobile Information We Collect
Mobile How We Use Collected Information
Mobile Information sharing
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 SFAFT web page or promotion. SFAFT 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.
You may have the opportunity to elect to receive email and mobile communications from SFAFT. SFAFT will only email you or send you mobile alerts if you elect to receive them. If you elect to receive email and mobile communications, SFAFT 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 SFAFT, you can opt-out by clicking the unsubscribe link at the bottom of any SFAFT email, update the contact preferences for your account, for mobile marketing, you may opt-out by following the instructions provided in the text messages you receive, or contact the Privacy Officer at firstname.lastname@example.org.
Although we make every effort to preserve user privacy, we may need to disclose Personally Identifiable Information in certain limited circumstances, specifically: to comply with a judicial proceeding, a court order, or subpoena, or as otherwise may be required by law, to enforce our policies or contracts, or to collect amounts owed to us, to protect users of our sites and our sites from fraudulent or abusive use, to protect SFAFT’s rights or property (including without limitation in the event of a bankruptcy, merger, acquisition, or transfer of control or assets or other business venture involving SFAFT, or any of the business or assets of SFAFT, during emergencies when safety is at risk, as determined by SFAFT, or otherwise where necessary for the establishment, exercise or defense of legal claims. The Personally Identifiable Information you provide is considered a company asset and may be included among transferred assets if SFAFT or any or all of their subsidiaries or affiliates or any of their assets is ever acquired by a third party. 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.
We endeavor to protect your Personal Information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our control. These measures include safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use and modification.
Currently, our website utilizes a variety of different security measures designed to protect Personal Information by users both inside and outside SFAFT, including the use of encryption mechanisms (e.g., Secure Socket Layers or SSLs), password protection, and other security measures to help prevent unauthorized access to your personally identifiable information. This helps maintain the confidentiality, privacy, and integrity of your transactions, and helps to protect your confidential information - such as credit card numbers, online forms and financial data, from loss, misuse, interception and hacking.
Identity theft and the practice currently known as “phishing” are of great concern to SFAFT. 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.
SFAFT ensures 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.
SFAFT 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.
We take all reasonable steps to ensure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading.
We want to be sure that we keep only the most accurate and up-to-date Personal Information in our records. Therefore, whenever you believe that your Personal Information needs to be updated, you can email us at email@example.com to update your contact information. You may choose at any time to remove your name, telephone numbers, and postal and email addresses from the lists we use to send notices or updates and elect not to receive correspondence from us by sending us an email at firstname.lastname@example.org.
To protect your privacy, we will take reasonable steps to help verify your identity before granting access or making changes.
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) 783-7479; by email at: email@example.com; or by mail at SFAFT, In Care of, Franchise World Headquarters, LLC, 325 Bic Drive, Milford, CT, 06461, USA. We will address your concern and attempt to resolve any problem. Download Privacy Information Request Form here: http://www.subway.com/subwayroot/InfoRequestForm.pdf.
SFAFT uses 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, SFAFT 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 SFAFT. When interacting with the SFAFT presence on those websites, you may reveal certain personal information to SFAFT or to third parties. Except when used by SFAFT employee’s for the purpose of responding to a specific message or request, SFAFT will not use, share, or retain your personal information.
At this time, SFAFT 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.
Under California’s “Shine the Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to that customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. To request the above information, please email the Privacy Officer at firstname.lastname@example.org or write to us at:
SFAFT Privacy Officer
We will respond to such written requests within 30 days following receipt at the mailing address above. We reserve the right not to respond to requests submitted other than to the address specified above or otherwise exempted by law. Please note that we are required only to respond to each customer once per calendar year.
SFAFT 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. SFAFT has been Self-Certified under the Safe Harbor privacy framework 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:
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.
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, a member of the SUBWAY Group, 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.
LAST UPDATED: 11/01/12
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