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THE SUBWAY® GROUP PRIVACY STATEMENT

 * Privacy Policy
 * California Privacy Notice

Effective Date: October 6, 2021
Last Revised: September 9, 2023

This Privacy Statement describes how we collect, use, disclose, transfer, and
store your information. It will also tell you about your rights with regard to
your personal data.


HOW TO CONTACT US

If after reviewing this Privacy Statement, you would like to submit a request or
you have any questions or privacy concerns, please contact:

The Subway® Group Privacy Office
c/o Franchise World Headquarters, LLC
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 Privacy Statement in
an alternative format, please contact us at privacy@subway.com.


TABLE OF CONTENTS

 * ABOUT THIS STATEMENT
 * PERSONAL INFORMATION WE COLLECT
 * HOW WE COLLECT INFORMATION
 * HOW WE USE YOUR PERSONAL INFORMATION
 * SHARING YOUR INFORMATION
 * COOKIES AND TARGETED ADVERTISING
 * OPTING OUT
 * YOUR RIGHTS AND CHOICES
 * INTERNATIONAL TRANSFERS
 * HOW LONG WE KEEP YOUR INFORMATION
 * CHILDREN’S PRIVACY
 * OUR SECURITY
 * OUR GROUP COMPANIES


1. ABOUT THIS STATEMENT

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The Subway® Group. The Subway® Group (“we,” “us” or “our”) is made up of a
variety of companies including but not limited to, Subway® IP LLC (the owner of
our proprietary system for establishing and operating restaurants in order to
develop Subway® restaurants worldwide), FWH Technologies, LLC (the owner and
licensor of the SubwayPOS® software for use in Subway® restaurants worldwide),
Franchise World Headquarters, LLC (a service-oriented company that provides core
business-related services to other Subway® Group entities), the Subway®
franchisors (which offer and sell franchises worldwide), and the Subway®
advertising entities (which administers national and local advertising funds and
activity for Subway® restaurants and Subway® franchisees worldwide). To see a
list of the Subway® Group entities that may come in contact with your personal
information, please see “Our Group Companies” section below.

What this statement applies to. This Privacy Statement applies to the personal
information that the Subway® Group collects when you interact with the Subway®
brand online and offline. This includes information collected through our
websites, WiFi services or similar technology provided in Subway® restaurants,
branded pages on third party platforms (i.e. social networking services), mobile
applications, and through our direct marketing campaigns or other
communications, as well as, when you purchase our products, request delivery and
carry-out services, subscribe to our news and offers, enter into one of our
promotions or contact customer support, apply for employment, or apply to become
a franchisee (collectively, “Subway® Services”).

What this statement does not apply to. This Privacy Statement does not apply to
(1) Subway® Services that show a different privacy statement (2) third party
websites including websites that are operated by Subway® franchisees, or (3)
when you interact with us as an employee. Subway® restaurants are owned and
operated by independent Subway® franchisees. Each restaurant is solely and
independently responsible for its legal and regulatory compliance and this
Privacy Statement does not apply to Subway® franchisees or to websites or mobile
apps they operate. Please see Subway® franchisees’ privacy notices for
information on how they use customer information. There may also be times we
have a link to third party websites. If you choose to visit those websites, we
are not responsible for the privacy practices or the content of those websites.
We encourage you to review the privacy policies of those websites before
submitting your personal information. Some third parties may choose to share
information about their users with us; that sharing is governed by that
company’s privacy policy and not this Privacy Statement.

Changes to this statement. If we make any material changes to this statement, we
will notify you by means of a notice on this site or by an email (sent to the
email address specified in your account). Where we are required by applicable
data protection laws, we will also seek your consent to any material changes
that affect how we use your personal information. We encourage you to
periodically review this page for the latest information on our privacy
practices.




2. PERSONAL INFORMATION WE COLLECT

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Guests

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


 * Contact Information. We may collect personal and/or business contact
   information including your first name, last name, mailing address, delivery
   address, telephone number, email address, and other similar data.
 * Payment Information. If you make a purchase online, you will be required to
   provide a credit/debit card number and related financial information (such as
   expiration date, security code and billing address), or other payment
   information (such as your Subway® Card), depending on the form of payment you
   choose.
 * Account Information. We collect information such as your username and
   password when you create a Subway® account, access our online services, or
   buy our products. Account information may also include how you purchased or
   signed up for Subway® Services, your transactions, billing and support
   history for the Subway® Services you use and anything else related to the
   account you create. This includes information pertaining to your use of
   Subway® Cards and your participation in Subway® MVP Rewards, including all
   related transactions, both in-restaurant and online, whether that information
   is obtained directly from you or through a service provider we have engaged
   to help provide those programs.
 * Usage Data. This is the personal information we collect about you when you
   are using Subway® Services, which may include information about the date and
   time of your logins and details of your use of third-party applications and
   advertising you receive.
 * Marketing and Communications. We may also collect your preferences in
   receiving marketing from us and our partners.
 * Security Credentials.We collect user IDs, passwords, email, and similar
   security information required for authentication and access to your Subway®
   accounts.
 * Information through Social Media. You may be given the option to link to your
   Facebook or other social media accounts through Subway® Services. Your use of
   these features may result in the collection or sharing of information about
   you, depending on the feature. For example, these features may collect your
   IP address and information about pages you visit on our site, and may set a
   cookie to enable the feature to function properly. They may also allow social
   media services to provide us information about you, including your name,
   email address, and other contact information. The information we receive is
   dependent upon your privacy settings with the social media network. We
   encourage you to review the privacy policies and settings on the social media
   services you use to make sure you understand the information that is
   collected, used, and shared by those sites.
 * Customer Service, Surveys & Promotions. There may be times you provide us
   additional personal information when you interact with our customer support
   channels online or by phone or mail; when you participate in our customer
   surveys or promotions; or to facilitate delivery of Subway® Services or to
   help us respond to your inquiries. Types of additional personal information
   may include voice recordings, photographs and videos.
 * Information You Provide about Others. You may decide to provide us with
   another person’s information (such as their name, email, address or phone
   number) so that we may recommend or send products or services to that person.
   Local law may require you to get the consent of that person to provide their
   information to the Subway® Group. We may in turn use the information you
   provide in accordance with this Privacy Statement.
 * Device & Technical Data. We collect technical information when you visit our
   websites or use our mobile applications or other electronic services. This
   includes information such as you Internet Protocol (IP) address, your login
   data, the type of mobile device you use, your device operating system and
   browser type, time zone setting and location, language, device identifiers,
   the address of a referring website, the path you take through our websites,
   and other information about your session on our websites.
 * Geolocation Data. We may collect information about your location by inferring
   it from your IP address or receiving it from your mobile device when your
   device is set to share location information. For example, to assist us in
   showing you the nearest Subway® restaurant, we utilize location information
   provided by services such as Google Maps and Apple Maps. For most devices and
   browsers, you can control the sharing of location data with us by adjusting
   your browser or device settings. For more about how Google Maps collects and
   shares location data, please review Google’s Privacy Policy.
 * There may be instances in which the personal information that you provide to
   us is considered “Sensitive Personal Information” under applicable privacy
   laws. Sensitive personal information we collect includes: Precise Geolocation
   and certain Payment and Account information that includes security codes,
   access codes, or passwords allowing access to an account.


Prospective Employees

If you apply for employment with the Subway® Group, we collect information as
part of your application as well as the recruitment process. Personal
information collected may include: Your Name, Personal Email, Physical Home
Address, Personal Phone Number(s), Government Issued Id (Passport, Driver's
License #, SSN), Date of Birth, Banking Information, Education, Criminal
Background, Job Qualifications, Employment History, Financial Statements,
Electronic Signature, Physical limitations & Special Needs, and References. We
may also receive this information if you submit your application via a
third-party site or through a recruiter or employment agency.

There may be instances in which the personal information that you provide to us
is considered “Sensitive Personal Information” under applicable privacy laws.
Sensitive personal information we collect includes: Racial or Ethnic Origin,
Philosophical Beliefs, Nationality, Trade Union Membership, Sexual Orientation,
Political Opinion, Health Information, Citizenship, Passport, Driver's License
#, SSN, and other categories established by applicable law. To the extent you
make Sensitive Personal Information available to Subway®, where required by law
you consent to Subway® processing such information in accordance with this
Privacy Statement.

All information, including personal information submitted by you as part of the
application process, will become part of your employee file should you become an
employee. Employees’ personal information is governed by separate policies and
not by this Privacy Statement.

Franchisees & Business Developers

If you apply to become a Franchisee or a Business Developer with the Subway®
Group, we may collect information as part of your application. Personal
information collected may include, but is not limited to: Your Name, Date of
Birth, Personal/Work Email, Physical Home Address, Personal Phone Number(s),
Government Issued Id,(Passport, Driver's License #, SSN), Photographs & Videos,
Marital Status, Educational Background, Voice Recordings, Financial & Banking,
Litigation History, Criminal & Credit History, Job title, Job Qualifications,
Employment History, Tax Records, Electronic Signature, and Military Veteran
Status.

Some of the personal information that you provide may be considered “Sensitive
Personal Information” under the privacy laws of some countries. Sensitive
Personal information may include: Racial or Ethnic Origin, Philosophical
Beliefs, Nationality, Trade Union Membership Sexual Orientation, Political
Opinion, Health Information, Citizenship, Passport, Driver's License #, SSN, and
other categories established by applicable law.

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


3. HOW WE COLLECT INFORMATION

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We Collect Information Directly From You

When you use Subway® Services, we may ask you to provide certain personal
information to obtain our products or use our services. For example, we collect
information if you place an order, create an account, or contact us. We also
collect information from you if sign up for email communications, submit a job
application, or otherwise submit your information to us. This could be in
person, by phone, or online.

We Collect Information Automatically

When you visit or interact with Subway® Services as well as any third-party
advertisers and/or service providers, we may use a variety of technologies that
automatically or passively collect information about your online activity. We
and our service providers use technologies such as cookies, web beacons, unique
advertising identifiers, and mobile device identifiers to collect information
about the use of our websites and mobile services. For more information,
including the types of cookies found on Subway® websites and how to control
cookies, please read the “Cookies & Targeted Advertising” section below.

We Receive Information from Third Parties

We may collect information about you from other companies and organizations,
including our service providers, public databases, social media platforms, our
marketing partners or various independent purchasing organizations established
for the benefit of Subway® franchisees. This includes, for example, information
from public databases or data aggregators that may include your demographic
information, media consumption, previous purchases, shopping habits, loyalty
program information or lifestyle preferences.

Independent purchasing organizations provide a variety of support functions to
Subway® franchisees in each region. Support functions may include, but are not
limited to, administering rewards, loyalty, and gift card programs, in which we
may work with the independent purchasing organization in joint marketing efforts
in relation to those programs. The Independent purchasing organizations we work
with are Independent Purchasing Cooperative, Inc. (United States, its
territories, and Canada), Independent Purchasing Company (Australasia) Ltd.
(Asia, Australia, and New Zealand), Latin American and Caribbean Independent
Purchasing Company (Latin America and Caribbean), Independent Purchasing Company
Europe Limited (Europe) and Middle East Independent Purchasing Company Ltd.
(MEIPC)(Middle East).

We Collect Information that is Publicly Available

For example, we may collect public information about your when you interact with
us through social media. By collecting additional information about you, we can
correct inaccurate information, enhance the security of your transactions, and
give you product recommendations and special offers that are more likely to
interest you.

We Combine Information

We may combine the information we receive about you, including information you
provide directly to us and information we automatically collect through Subway®
Services, as well as information collected across other computers or devices
that you may use, from other online or offline sources, and from third parties.
If we combine your personal information and non-personal information, we will
treat the combined information as personal information in accordance with this
Privacy Statement.


4. HOW WE USE YOUR PERSONAL INFORMATION

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

To provide our services and contract with you, including to:

 * carry out your requests, fulfill orders, and process payments for our
   products and services;
 * establish and manage your accounts;
 * communicate with you about your orders, purchases or accounts with us, or
   changes to our terms & conditions or Privacy Statement, including handling
   any requests, questions or comments you may have;
 * communicate about, and administer your participation in, special events,
   programs, webinars, surveys, contests, sweepstakes, and other offers or
   promotions;
 * provide Subway® Card services to you;
 * enabling your participation in the Subway® MVP Rewards program;
 * provide online services to you, which includes our websites and/or mobile
   applications;
 * provide customer support, including processing any concerns about our
   services;
 * verify your identity, such as on service calls, login credentials, convention
   registration;
 * enforce our contracts with you and fulfill the performance of a contract; and
 * for legitimate human resources and business management reasons


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

 * tell you about our products and services, competitions, offers, promotions or
   special events that we believe may interest you when you are part of a
   Subway® loyalty program;
 * personalize your experience in our restaurants and on our online services;
 * verify your identity or communicate with you about your activities with
   respect to Subway® Services;
 * operate, evaluate, and improve our business, including developing new
   products and services, managing our communications, conducting consumer and
   operations research, assessing the effectiveness of our sales, marketing and
   advertising, analyzing and enhancing our products and services, performing
   accounting, auditing, billing, reconciliation and collection activities;
 * administer and protect our business and this website (including
   troubleshooting, data analysis, testing, system maintenance, support,
   reporting and hosting of data;
 * to respond to and process applications from potential franchisees and
   business developers and potential employees;
 * use analytics and profiling technology to personalize your experience;
   deliver content (including advertising) tailored to your interests and let
   you know how to use Subway® Services (see “COOKIES AND TARGETED ADVERTISING”
   below for more information);
 * link or combine with information we receive from others to help understand
   your needs, use for interest-based or targeted advertising or re-targeting on
   your computers or other devices;
 * ensure the security of our networks and systems, including to help diagnose
   technical and service issues, troubleshoot issues, bugs or defects related to
   your account or activities;
 * identify and evaluate candidates for potential employment, as well as for
   future roles that may become available;
 * conduct criminal and credit background checks (e.g., OFAC searches) as
   permitted or required by law;


To comply with applicable law, including to:

 * protect against, identify, and prevent fraud and other criminal activities,
   claims and liabilities;
 * comply with legal obligations and our policies;
 * establish or defend a legal claim; and
 * monitor and report compliance issues.


For the public interest:

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


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

 * to process Sensitive Personal Information (where required by applicable law)
 * to send you emails or text messages about the products and services,
   competitions, offers, promotions or special events we believe may interest
   you;
 * to send you emails or text messages about the products and services of our
   business partners;
 * provide location-based services;
 * use cookies and similar technologies.


We may use the information we collect about you in other ways, which we will
tell you about at the time we collect it and for which we will seek your consent
if required by law.

We do not use or disclose sensitive personal information, as defined by
California law, for inferring characteristics or for purposes other than those
permitted by law.


5. SHARING YOUR INFORMATION

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We may share information collected from or about you with the following
categories of companies in the following ways:

Within the Subway® Group

The Subway® Group may share your information amongst our entities in order to
administer our rewards and loyalty programs, process orders and requests, and
expand and promote our product and service offerings. Members of the Subway®
Group who receive your personal information are not authorized to use or share
the information, except as set out in this Privacy Statement.

With Third Parties

Subway® Franchisees and Business Developers. If you choose to contact us or
submit a survey about your experience in a Subway® franchisee’s restaurant, we
may share your information with the Subway® franchisee in order for them to
address your request, compliment or complaint. We may also share your
information with the Business Developer who oversees the operations of the
restaurant. Business Developers are independent contractors of the Subway®
franchisor who are responsible for the growth of the franchise in a specific
territory.

Independent Purchasing Organizations. Depending on your region, we may share
your personal information with the applicable independent purchasing
organization in your market and their subsidiaries in connection with online
purchases, registration of gift cards and the administration of rewards and
loyalty programs.

Service Providers. We may share your personal information with vendors who
provide services to us, such as business, professional or technical support
functions. This includes, but is not limited to: service providers that host or
operate Subway® Services; payment processors; food delivery companies; data
processing or other information technology services; research and analytics
vendors, customer experience management services and vendors that assist with
personalizing individual customer experiences. We do not allow these vendors to
use or share this information for any purpose other than to provide services on
our behalf.

Advertising Partners. We may share information, excluding mobile originator and
opt-in consent data, with third parties to provide marketing and advertisement
purposes, including to provide cross-contextual behavioral advertising on our
websites. In our California Privacy Notice (below) we outline which categories
of information are shared for cross-contextual behavioral advertising on our
websites.

Sweepstakes, Contests, and Promotions. If you choose to enter into one of our
sweepstakes, contests, or other promotions, we may disclose your information to
third parties or the public in connection with the administration of such
promotion, as required by law, as otherwise permitted by the Promotion’s
official rules, or otherwise in accordance with this Privacy Statement.

Business Transfers. Your Personal Information is considered a company asset and
may be disclosed or transferred to a third party in the event of a proposed or
actual purchase, any reorganization, sale, lease, merger, joint venture,
assignment, amalgamation or any other type of acquisition, disposal or financing
of all or any portion of our business or of any of the business assets or shares
(including in connection with any bankruptcy or similar proceeding) of the
Subway® Group or a division thereof, in order for you to continue to receive the
same products and services from, or to continue the same or similar relationship
with, the third party.

Legal Disclosures. We may disclose your information if we believe that the
disclosure is required by law, a subpoena or other legal process, if we believe
that the disclosure is necessary to enforce our agreements or policies, or if we
believe that the disclosure will help us protect the rights, property or safety
of the Subway® Group or our guests or partners.

When You Consent. We may share your information with other companies if you give
us permission or direct us to share the information.




6. COOKIES AND TARGETED ADVERTISING

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We use cookies and similar technologies for a wide range of purposes in our
websites, applications and email communications to deliver the Subway® Services
and improve your experience. For example, we use information collected from
cookies and similar technologies to help us recognize you, customize and improve
your experience, provide security, analyze usage of the Subway® Services, gather
demographic information about our user base, to offer the Subway® Services to
you, to monitor the success of marketing programs, and to serve targeted
advertising on our site and on other sites around the Internet. To learn more
about the categories of cookies we (and our service providers) use and what they
are used for please click on Cookie Settings.

We also use analytics and tracking tools, such as Google Analytics, Adobe
Marketing Cloud, Facebook Customer Audience and others, to help us track,
segment and analyze usage of the Subway® Services, and to help us or those
vendors serve more targeted advertising to you on the Subway® Services and
across the Internet. Those tools may use technology such as cookies, web
beacons, pixel tags, log files, or other technologies to collect and store
certain information, such as Usage Data, Device & Technical Data, and
Geolocation Data. We also participate in the Adobe Marketing Cloud Device Co-op
to better understand how you use our website and apps across the various devices
you use, and to deliver tailored promotions. Go to
https://cross-device-privacy.adobe.com to learn more about how Adobe does this.
You may opt-out of having your activity on our website made available to Google
Analytics by installing the Google Analytics browser add-on, available at:
https://tools.google.com/dlpage/gaoptout.

Do Not Track: Some browsers have “do not track” features that allow you to tell
a website not to track you. We do not currently respond to those signals unless
noted in this policy.


7. OPTING OUT

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Cookies and Other Technologies

Your browser may give you the ability to control cookies or other tracking
tools. How you do so depends on the type of tool. Certain browsers can be set to
reject browser cookies. If you block cookies, certain features on our sites may
not work.

To manage your cookie preferences, please click on Cookie & Ad Settings

Additionally, the Self-Regulatory Program for Online Behavioral Advertising
provides consumers with the ability to manage certain choices online here and
provides a tool for managing mobile choices here. European users should use the
following link.

Please note, options you make are browser and device specific.

Marketing Communications

You may opt-out of marketing communications by following the opt-out
instructions in the marketing emails we send you or you can also contact us by
using the contact details provided under the “How to Contact Us” section above.
Depending on the Subway® Services you use, you may also have the ability to
change your communication preferences in the profile section of the online
services that you use or in your device settings.

If you do opt out of receiving marketing emails from us, we may still send
communications to you about your transactions, any accounts you have with us,
and any contests, competitions, prize draws or sweepstakes you have entered.
Opting out of one form of communication does not mean you’ve opted out of other
forms as well. For example, if you opt out of receiving marketing emails, you
may still receive marketing text messages if you’ve opted in to receiving them.
Please note that if you are receiving communications from a Subway® franchise,
then you will need to opt out from them directly.

Push Notifications

Where our mobile applications allow for the delivery of “push notifications”,
you can also opt out of receiving these notifications by going into your mobile
phone settings and toggling the “Notifications” switch within our mobile
application to “off”.

Rewards and Loyalty Programs

U.S., Canada, United Kingdom, Finland. Participation in the Subway® MVP Rewards
program is voluntary; you may end your participation in the Subway® loyalty
program by using the contact details provided under the “How to Contact Us”
section above, in which case any data gathered through the program will be
deleted except what we are legally required to keep and subject to the remainder
of this Privacy Statement. Please note that data originating through other
non-program interactions may remain with us.

Other regions. If you would like to opt out of a loyalty program in a region not
listed above, please contact the independent purchasing organization that is
responsible for administering the program in the region in which you registered.
For a list of all the independent purchasing organizations and their regions,
please see the “Information Received from Third Parties” section above.

App Tracking Preferences

Opt Out By Deletion. You may use the standard uninstall, application, and data
management processes available through your mobile device. Once you have
uninstalled the app, all the information that is stored in the app is deleted,
including any preferences you previously set for location permissions and
whether you have allowed us to send you push notifications. Once the app is
uninstalled and preferences are deleted, push notifications from the app will
stop. You may also refrain from using application features that collect specific
types of data. If you are an Apple user, our app also allows you to request
deletion of all account data from us.

Location Opt Out. You may be able to adjust the settings of your device so that
information about your physical location is not shared with our app or other
apps by (a) disabling location services within the device settings; or (b)
denying certain websites or mobile applications permission to access location
information by changing the relevant preferences and permissions in your mobile
device or browser settings. Please note your location may be derived from your
WiFi, Bluetooth, and other device settings. See your device settings for more
information.


8. YOUR RIGHTS AND CHOICES

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Under certain circumstances, and depending on your state or country of
residency, you may have rights under applicable data protection laws in relation
to your personal information. You may have the right to:

Access Your Personal Information. You can request access to your personal
information. This enables you to receive a copy of the personal information we
hold about you as well as details about how we are processing it.

Modify or Update Your Personal Information. We aim to ensure that personal
information in our possession is accurate, current and complete. If you believe
that the personal information about you is incorrect, incomplete or outdated,
you may request the revision or correction of that information.

Erasure of Your Personal Information. You may ask us to delete or remove
personal information we hold about you, subject to certain exceptions.

Please note that if you are a Subway® MVP Rewards member, requesting deletion
may require the deletion of your account which, upon completion, cannot be
undone.

Object to Processing Your Personal Information. You may have the right to object
to us processing your information in certain circumstances.

Right to Opt-out of Sale/Sharing/Targeted Advertising.

Some states require that we tell you if we sell personal information to third
parties for monetary or other valuable consideration, if we share personal
information for cross-context behavioral advertising, or use your personal
information for targeted advertising. We do not sell personal information in
exchange for money; however, we do engage in targeted advertising, and some of
our advertising practices on our websites may be classified as sales or sharing
under certain state laws. We do not sell personal information of minors under
the age of 16 for monetary or other valuable consideration. In certain
jurisdictions, you have the right to opt-out of the sale or sharing of your
personal information. You may submit a request by clicking Do Not Sell or Share
My Personal Information in the footer of our website and following the
instructions. Some browsers also allow you to tell websites not to share your
information for cross-contextual behavioral advertising. To learn how to
configure this setting, view here. Selections are browser and device specific.
To opt out of cross-contextual behavioral advertising, you can also manage your
selections Cookie & Ad Settings in the footer.

Data Portability. You may request the transfer of your personal information to
you or a third party. We will provide to you, or a third party you have chosen,
your information in a structured, commonly used, machine-readable format.

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 .

Please note, not all of the rights described above are absolute, and they do not
apply in all circumstances. In some cases, we may limit or deny your request
because the law permits or requires us to do so, or if we are unable to
adequately verify your identity. We will not discriminate against individuals
who exercise their privacy rights under applicable law.

How to Exercise Your Rights. You may exercise any of these rights, by submitting
a request using our webform here and following the instructions. You may also
call our toll-free number at 800-888-4848. In the request, please specify which
right you are seeking to exercise and the scope of the request. We may require
specific information from you to help us verify your identity and process your
request, including your name, email address, and country of residency. If we are
unable to verify your identity, we may deny your requests.

 * 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.


If you are not satisfied with our response, and are in the European Union or
United Kingdom, you may have a right to lodge a complaint with your local
supervisory authority.


9. INTERNATIONAL TRANSFERS

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Due to our global operations, your personal information may be transferred to
and processed in the United States and other countries that may not provide the
same level of data protection as your home country. The Subway® Group’s privacy
practices are consistent with all applicable country, national, state, and local
data protection and security laws.

For our customers whose use of Subway® Services results in the transfer of
personal information from the European Economic Area (EEA), United Kingdom,
Switzerland, or other jurisdictions with adequacy provisions to non-adequacy
country, we rely on one or more of the following legal mechanisms: Standard
Contractual Clauses, and consent of the individual.


10. HOW LONG WE KEEP YOUR INFORMATION

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To the extent permitted by applicable law, we retain your personal information
as long as (1) it is needed for the purposes for which we obtained it and in
accordance with this Privacy Statement or (2) we have another lawful basis,
stated in this Privacy Statement or at the point of collection, for retaining
that information beyond the period for which it is necessary to serve the
original purpose for obtaining the personal information.

To determine the appropriate retention period for personal information, we
consider the amount, nature, and sensitivity of the personal information; the
potential risk of harm from unauthorized use or disclosure of the personal
information; the purposes for which we use the personal information; whether we
can achieve the purposes through other means; and the applicable legal
requirements.


11. CHILDREN’S PRIVACY

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Our services are not intended for use by children under the age of 13 or
equivalent minimum age depending on the jurisdiction.

If you are a parent or legal guardian and believe we may have collected
information about your child, please contact us as described in the “How to
Contact Us” section above.

If we learn that we have inadvertently collected the personal information of a
child under 13, or equivalent minimum age depending on the jurisdiction, we will
take steps to delete the information as soon as possible.


12. OUR SECURITY

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We use reasonable security measures as required by applicable law. While we have
employed security technologies and procedures to assist safeguarding your
personal information, no system can be guaranteed to be 100% secure. Please note
that we cannot ensure or warrant the security of any information you transmit to
us. You use Subway® Services and provide us with your information at your own
risk. In the event that we are required by law to inform you of a breach to your
personal information we may notify you electronically, in writing, or by
telephone, if permitted to do so by law.


13. OUR GROUP COMPANIES

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Here is a list of our entities that may be involved in processing your personal
information:

Doctor's Associates LLC
Franchise World Headquarters, LLC
FWH Technologies, LLC
SJ Marketing G.K.
Subway Brand Management & Consultant (Shanghai) Co., Ltd.
Subway Franchise Systems of Canada, ULC
Subway Franchisee Advertising Fund Trust B.V. Sucursal Argentina
Subway Franchisee Advertising Fund of Australia Pty. Ltd.
Subway Franchisee Advertising Fund of Canada Inc.
Subway Franchisee Advertising Fund Trust B.V.
Subway Franchisee Advertising Fund Trust Ltd.
Subway Franchisee Canadian Advertising Trust
Subway International B.V. - South Korea Branch
Subway International B.V. - Taiwan Branch
Subway International B.V.
Subway International B.V. Sucursal Argentina
Subway International B.V. Sucursal El Salvador
Subway International B.V. Philippines Branch
Subway International de Mexico, S. de R.L. de C.V.
Subway IP LLC
Subway Japan G.K.
Subway Japan Restaurants G.K.
Subway MyWay of Canada, ULC
Subway MyWay, LLC
Subway Partners Colombia C.V.
Subway Payment Services, LLC
Subway Payment Services Canada, ULC
Subway Realty Limited
Subway Realty of France EURL.
Subway Realty of Spain, S.L.U.
Subway Subs of Canada, ULC
Subway Systems Australia Pty. Ltd.
Subway Systems Colombia S.A.S.
Subway Restaurant Management (Shanghai) Co. Ltd.
Subway Systems Middle East FZ-LLC
Subway Systems Singapore Pte. Ltd.
Subway Vermietungs-und Servicegesellschaft mbH
Subway Vermietungs-und Servicgesellschaft G.m.b.H. -organizační složka (Czech
Republic)

Thank you for reading our Privacy Statement. If you have any questions about
this Statement or about how we process personal information, please contact us
by using the contact details provided under “How to Contact Us”, which is
located at the top of this document.

If we are unable to resolve your concerns, you have the right to contact a data
privacy supervisory authority in the country where you live or work, or where
you consider that the data protection rules have been breached or seek a remedy
through the courts.




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