THE SUBWAY® GROUP PRIVACY STATEMENT
INTRODUCTION
Effective Date: March 12, 2024
Last Updated: January 14, 2026
This Supplemental U.S. State Privacy Notice (“U.S. Notice”) supplements our other privacy policies and notices, including the Subway Group Privacy Statement (“Privacy Statement”), and describes how we collect, use, disclose, transfer, and store personal information about residents of California and consumers in states with comprehensive privacy laws, including Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia (collectively, “Covered States”). It will also tell you about your rights with regard to your personal information. It does not cover employee personal information.
When information identifies or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, we refer to it as “personal information.” “Personal information” includes “personal data” as defined by Covered State privacy laws, but does not include information that is publicly available, deidentified, or aggregated.
HOW TO CONTACT US
If after reviewing this Privacy Statement, you would like to submit a request or you have any questions or privacy concerns, please contact:
The Subway Group Privacy Office
c/o Franchise World Headquarters, LLC
1 Corporate Drive, Suite 1000
Shelton, CT, 06484
USA
Email Address: privacy@subway.com
If you are a user with a disability and need access to this U.S. Notice in an alternative format, please contact us at privacy@subway.com.
Changes to this Notice. If we make any material changes to this Notice, we will notify you by the means described in our Privacy Statement.
SUPPLEMENTAL U.S. STATE PRIVACY NOTICE
Changes to this Notice. If we make any material changes to this Notice, we will notify you by the means described in our Privacy Statement.
Categories of Personal Information We Collect and Disclose
The following chart details which categories of personal information we collect from and about consumers in Covered States, as well as the categories of parties to which we disclose each category of information for a business purpose, and the categories of third parties to which we have “sell” or “share” each category of information for purposes of targeted or cross-context behavioral advertising (where applicable).
Category of Personal Information |
Categories of Recipients |
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| Disclosures for a Business Purpose | Sold or Shared for Targeted/Cross-Context Behavioral Advertising | |
| Identifiers, including real name, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers |
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| Personal Records, including name, signature, social security number, address, telephone number, passport number, driver's license or state identification card number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information. |
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| Characterizations of protected classes, such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information) |
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| Commercial Information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
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| Internet or other electronic network activity information, including search history, and information regarding interactions with our websites, applications, or advertisements. |
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| Geolocation data. |
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| Audio, electronic, visual, thermal, olfactory, or similar information. |
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| Professional or employment-related information. |
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| Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99). |
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| Inferences used to create a profile reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes |
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| Sensitive personal information, including log-in information for accounts in combination with passwords allowing access to the accounts and precise geolocation. |
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How we use your Information
We use the personal information we collect for the business purposes described within our Privacy Statement, including:
- To provide our services and contract with you;
- To market to you, improve our services, and for other legitimate business interests;
- To comply with applicable law, when our use is in the public interest, or otherwise with your consent.
For more information, please review “How We Use Your Personal Information” section of our Privacy Statement.
Disclosure of Personal Information for a Business Purpose
In addition to the categories of recipients identified in the chart above, we may disclose your information if we believe that the disclosure is required by law, a subpoena or other legal process, if we believe that the disclosure is necessary to enforce our agreements or policies, or if we believe that the disclosure will help us protect the rights, property or safety of the Subway Group or our guests or partners.
For more information, please review the “Sharing your Information” section of our Privacy Statement.
Retention Period
We retain your information for as long as necessary to carry out the purpose for which we originally collected your information and other legitimate business purposes, including legal or compliance obligations. For more information, please review the “How Long We Keep Your Information” section of our Privacy Statement.
Sharing or Selling your Personal Information
Although we do not “sell” personal information in exchange for money, some of our online advertising practices and transfers of personal information to other companies for certain types of data enrichment or analytics may be classified as a “sale” under Covered State law. As detailed in the chart above, we sell and share certain categories of your personal information with third parties for targeted or cross-contextual behavioral advertising. Please refer to the chart above for additional details.
We do not “sell” or “share” the personal information of individuals we know to be under 16 years of age.
Use of Sensitive Personal Information
The Subway Group only collects and uses sensitive personal information for certain limited purposes, such as providing services and products to consumers, detecting data security incidents, protecting against fraud, and as part of our employee, Business Developer, and Franchisee application processes.
The Subway Group collects the following Sensitive Personal Information:
- Personal Information that reveals an account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
- Precise geolocation
We do not use or disclose sensitive personal information for purposes to which the right to limit use and disclosure applies under California law.
Your Rights
Right to Correct . We aim to ensure that personal information in our possession is accurate, current and complete. If you believe that your personal information is incorrect, incomplete or outdated, you may request the revision or correction of that information.
Right to Delete.You have the right to request the deletion of personal information that we collected from you. Please note that if you are a Subway Loyalty® Rewards member, requesting deletion may require the deletion of your account which, upon completion, cannot be undone. Where we use deidentification, we may maintain de-identified data and will not attempt to reidentify the information in accordance with applicable law.
Right to Opt Out.Subway® does not sell personal information for monetary consideration. However, as detailed in the chart above, we disclose certain categories of personal information to third parties for purposes that may be considered “selling” or “sharing” for targeted or cross-context behavioral advertising under Covered State law. You have the right to opt-out of the selling or sharing of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell or Share My Personal Information and following the instructions.
Additionally, residents of some Covered States have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. We do not engage in practices that qualify as profiling producing legal or similarly significant effects under applicable state privacy law.
Right to Know, Access, or Confirm.California residents have the right to know certain information about our data practices in the preceding 12 months, including:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or “sold” or “shared”;
- The categories of third parties to whom the personal information was disclosed for a business purpose or “sold” or “shared”;
- The business or commercial purpose for collecting “selling” or “sharing” the personal information; and
- The specific pieces of personal information we have collected about you.
Consumers in other Covered States may request to confirm whether we are processing your personal information, to access your personal information, and to obtain a copy of your personal information. Delaware and Oregon consumers may also request information about third parties to which we disclose personal information.
Right to Appeal. If Subway rejects your request, you may have the right to appeal that rejection within a reasonable time period. To do so, you can contact us as described in the “How to Contact Us” section above.
Shine the Light. Guests who are California residents may request (i) a list of categories of personal information disclosed to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please fill out the "Privacy Request Webform." We may require additional information from you such as email confirmation or other forms of identification based on the request to allow us to verify your identity.
We will not discriminate against individuals who exercise their privacy rights under applicable law.
How to Exercise Your Rights. To exercise any of these rights, please use our "Privacy Request Webform" or email us at privacy@subway.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We may require specific information from you to help us verify your identity and process your request. This is a security measure to help ensure that your personal information is not disclosed to someone that does not have the right to receive it. If we are unable to verify your identity, we may deny your request.
Depending on your state of residence and the nature of your request, you may designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly. Please provide written proof via email to privacy@subway.com. Your request may be submitted via the webform or email described above.
Please note that Subway® restaurants are franchised and are independently owned and operated. Their processing of personal information is subject to their own privacy policies. If you wish to exercise any of these rights with respect to the processing of information by a Subway® restaurant, please visit your local franchise-owned and operated store location to make your requests. We will work with the franchise owner to address your request to the extent required by applicable law.
Some browsers also allow you to tell websites not to sell your personal information or disclose it for targeted/cross-contextual behavioral advertising. Selections are browser and device specific. If you choose to use a browser-based opt out signal, you will only be opted out of online sales and sharing for cross-contextual behavioral or targeted advertising, and will need to turn it on for each browser you use. To opt out of targeted/cross-contextual behavioral advertising, submit a request using our "Privacy Request Webform" and follow the directions.
Additional Information About Our Loyalty Programs and Offers
We offer the Subway® Sub Club rewards program that provides certain perks, such as rewards and exclusive offers. You can enroll at Rewards | Subway® or through the Subway® App. Full Program terms apply. We may also provide other programs, such as sweepstakes, contest, or other similar promotional campaigns (collectively, the “Programs”) from time to time. The terms of each Program will be presented to you at the time you sign up. Participation in a Program is voluntary.
You may withdraw from participating in a Program at any time. You can withdraw from Subway® Sub Club by removing the Subway® App from your device at any time or submitting a request using the "Privacy Request Webform." If you maintain your account, you will still be able to use it to order and receive rewards using the Subway website. Otherwise, you will need to use the guest checkout on the website to place an order.
California Notice of Financial Incentive
When you sign up for one of these Programs, we typically ask you to provide certain personal information, such as your name and contact information (such as email address). The Programs also collect other categories of personal information about participants, such as commercial information relating to your purchases. Because our Programs involve the collection of personal information, they might be interpreted as a “financial incentive” program under California law. The value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the Program, less the expense related to offering those products, services, and benefits to Program participants.
Colorado Bona Fide Loyalty Program Disclosure
Subway® does not sell personal information for monetary consideration. However, as detailed in this notice, we disclose certain categories of personal information to third parties for purposes that may be considered “selling” or “sharing” for targeted or cross-context behavioral advertising under Colorado law. When you participate in the Subway® Sub Club rewards program, we may sell or process for targeted advertising some categories of personal information about you, including contact information and commercial information relating to your purchases. The categories of third parties who receive this information include advertising partners, advertising technology companies, companies that perform advertising-related services, and affiliated companies outside the Subway Group for data enrichment and analytics. You have the right to delete your personal information associated with your Rewards Program account; however if you delete your personal information, we will be unable to link your rewards to your account, and therefore you will be unable to continue receiving benefits from the Program.
Bona Fide Loyalty Program Partners and Bona Fide Loyalty Program Benefits provided by each: N/A.