The Subway Franchisee Advertising Fund Trust ("SFAFT") is the sponsor of web sites covered by this policy, which include without limitation www.subwaykids.com. FAFT values privacy, and we want to give our web site visitors the opportunity to know what information we collect about them and how SFAFT collects, protects, uses, discloses and otherwise manages the information gathered, in conformance with applicable law.
Collection and Use of Personal Information
Certain areas of our sites require visitors to register or complete an online form. The types of Personally Identifiable Information we may collect include name, address, contact information (e.g., e-mail, address, home and mobile telephone numbers) and/or other Personal Information (e.g., information about your interest in and use of our products and offerings) in order to participate in site activities such as: enter a SUBWAY® sweepstakes; participate in a survey or other online activity; request a SUBWAY® coupon; or ask for tips on healthy eating from Jared. We also may collect payment data, such as credit or debit card information. You may choose not to provide Personal Information and you will still be able to visit most of the web site, although you may not be able to participate in certain interactive activities.
We may also collect limited Personal Information about others from you including, but not limited to, name and email address.
We may use this Personal Information for one of several different purposes, for example:
- to administer your participation in a contest or sweepstakes and for other purposes stated on the entry form, such as to allow us to contact you notification of a potential prize you may have won;
- to allow us to send you the specific information or materials that you have requested, such as a coupon, newsletter, or other materials;
- to fulfill your orders;
- to enable you to communicate with friends, for example, to send an electronic greeting card or a notice about a promotion, or to respond to an email or other inquiry or request; and
- to help improve our web site and our services, or to customize your experience at our web site.
We may combine this information with other generally or publicly available information to help us identify our visitors' preferences or interests.
You can choose not to allow us to use 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 email@example.com. 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 our affiliates. At any time you may "opt out" of future contacts by un-subscribing from our contact list through the unsubscribe link available on the website or in an e-mail to firstname.lastname@example.org.
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.
Sharing of Personal Information
We may share Personal Information with agents, or service providers who act for or on behalf of SFAFT in connection with the business of SFAFT, or for further processing in accordance with the purpose(s) for which the data were originally collected, e.g., third party maintenance of secure listing databases or prize fulfillment in connection with a contest or sweepstakes. We require our agents and service providers to agree in writing to maintain the confidentiality and security of Personal Information they maintain on behalf of SFAFT and not to use it for any purpose other than the purpose for which we retained them. SFAFT may also share statistical or demographic information in aggregate form with service providers for marketing or research purposes. This aggregate data will not contain any information that personally identifies you.
We may share Personal Information within the Subway Family, e.g., with Doctor's Associate's Inc., affiliates, related entities and independently owned and operated Subway restaurants to enable us to provide you with additional product and service opportunities we believe would be of interest to you.
If you opt in to receive email communication from us, we may from time to time share your contact information with third parties engaged by us (e.g., other marketers) to enable them to offer you additional product or service opportunities.
We may need to disclose Personally Identifiable Information in certain limited circumstances, such as: (1) to comply with a judicial proceeding, a court order, or subpoena, or as otherwise may be required by law or consistent with legal requirements; (2) to enforce our policies or contracts, or to collect amounts owed to us; (3) to protect users of our sites and our sites from fraudulent or abusive use; (4) to protect DAI's and 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 DAI, SFAFT, or any of the business or assets of DAI or SFAFT); (5) during emergencies when safety is at risk, as determined by SFAFT, or (6) 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, DAI 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.
Cookies and Other Information Collected Using Technology
When you visit SFAFT sites, we may collect some information about the software or other technology you are using. For instance, when you come to our site your IP address is collected so that we know where to send information you are requesting. An IP address is often associated with the place from which you enter the Internet like your ISP (Internet service provider), your company, or your school. The following information is logged by our web servers during visits to the web site: IP addresses, type of operating system, time and duration of visit, web pages visited and browser type. We do not link server log information to any other information in a way that would enable the identification of visitors to the web site. We may analyze server log information in order to improve the web site and to customize the web site for users.
Banner Advertisements, Links to Other Sites, and Collection of Information by Third Party Sites
On this site, we sometimes offer content that is sponsored by or co-branded with identified third parties (e.g., competitions, sweepstakes, or promotions). These third parties may obtain Personal Information that you voluntarily submit to them to provide you with such content. We are not responsible for the collection and use of your personal information by these third parties. However, you will be informed, at the point of collection of such Personal Information, if these third parties will obtain such information.
A Note to Parents/Guardians—Additional Information About Children's Privacy
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.
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 child's, parent's, or friend's e-mail addresses. We use a child's e-mail 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). A friend's e-mail address may be used to send them an electronic greeting card or a forward-to-a-friend message.
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.
We also may collect additional information such as computer information, gender, state/province, zip/postal code, and country, and we may ask additional questions regarding preferences on various topics through surveys.
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 e-mail, write or phone us at:
Attn: Privacy Officer SFAFT
488 Wheelers Farms Road
Milford, CT 06461
Data Integrity and Security
We strive to keep the personally identifiable information you provide secure , and we also require our agents, and service providers to do so. We have implemented technical and organizational measures designed to help secure your Personally Identifiable Information from theft, accidental loss, and from unauthorized access, use, alteration, disclosure or destruction.
SFAFT takes reasonable steps to ensure that data is reliable for its intended use, accurate, complete, and current.
To provide you with an increased level of security online, access to your Personal Information on certain of our web sites may be protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication.
How You Can Access, Control and Update Information About You
We want to be sure that we keep 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.
To protect your privacy, we will take reasonable steps to help verify your identity before granting access or making changes.
If you have any questions or complaints, please contact the Privacy Officer. by telephone at: 1-800-992-6141; by email at: firstname.lastname@example.org, or contact us at the following mailing address:
Attn: Privacy Officer SFAFT
488 Wheelers Farms Road
Milford, CT 06461