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DAI PRIVACY POLICY
Doctor’s Associates Inc.
Milford, Connecticut, USA
Legal Information
Your privacy is very important to us. This Privacy
Policy discloses how Doctor’s Associates Inc. (“DAI”) and its affiliates
collect, protect, use and share personal information gathered about you, in
conformance with the applicable law. All personal information is collected in a
fair and non-intrusive manner, with your voluntary consent. Personal
Information is not accessible to anyone outside the specific function for which
it is collected. DAI respects the privacy of employees and job applicants,
franchisees, development agents, Subway® customers and other visitors to our
websites who may choose to provide personal information. We recognize the need
for appropriate protection and management of personal information that you
provide to us. This Privacy Policy will assist you to understand what types of
information we may collect, how that information may be used, and with whom the
information may be shared.
In an effort to comply with the law, and our commitment
to protect your personal information, we provide the following, which discloses
our policies. Please note that this Privacy Policy does not govern the privacy
policies and procedures of DAI’s independently owned and operated SUBWAY®
stores.
What type of information do we collect?
Personal Information is any information
concerning the personal or material circumstances of an identified or
identifiable individual. An identifiable person is one who can be identified,
directly or indirectly, by reference to an identification number or to one or
more factors specific to his physical, physiological, mental, economic,
cultural or social identity.
Personal Information shall include but is not limited
to: identifying information such as name, home address, home telephone number,
e-mail address, Social Security number, financial information and
employment-related information such as may be found on resumes, applications,
background verification information, or in employment references.
We will not collect sensitive Personal Information,
except to comply with Affirmative Action data requirements. Sensitive Personal
Information can include but is not limited to: information pertaining to
gender, disabilities and veteran status.
Cookies – Internet Users
In addition to Personal Information, we
use data collection devices such as "cookies" on certain web pages to
help analyze our web page flow and measure promotional effectiveness. Cookies
are pieces of information a website sends to an individual’s hard drive while
they are viewing the website. Cookies allow the website to remember important
information that will make your visit to the site more useful. We use cookies
to help improve your future visits. If you do not wish to receive a cookie or
if you wish to set your browser to warn you each time a cookie is being sent,
or if you wish to turn off all cookies, use the options on your browser to
assist you. The “Help” option on your browser may assist you in changing your
cookie preferences. Please note that by turning cookies off, you will not have
access to many features available on our website.
Children and Data Collection
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 addresses, and phone
numbers) over the Internet.
Our Use of Your Information
We use your Personal Information to
facilitate the services you request. We have tailored our Privacy Policy to
adequately inform you of the use of your Personal Information.
Collection and Use of Employee Personal Information
DAI also collects Personal Information
from its employees and applicants (human resource data) in connection with
administration of its Human Resources programs and functions. These programs
and functions include, but are not limited to: job applications and hiring
programs, compensation and benefit programs, performance appraisals, training,
access to DAI facilities and computer networks, employee profiles, internal
intranet employee directories, Human Resource recordkeeping, Affirmative Action
data, and other employment related purposes.
It is the policy of DAI to keep all past and present
employee information private from disclosure to third parties. There are
certain business related exceptions and they are:
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To comply with county, state or federal agency
requests;
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Inquiries from third parties with a signed
authorization from the employee to release the information, except in
situations where limited verbal verifications are acceptable (see below);
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Third parties with which DAI has contractual agreements
to assist in administration of company sponsored benefits.
Verifications of Employment
Prospective employers, state agencies,
financial institutions, and residential property managers routinely contact DAI
requesting information on a former or current employee's work history and
salary. All such requests of this type shall be referred to and completed on a
confidential basis by the Human Resources Department or Payroll Department.
For written verification of employment requests,
information will be provided on the form only when it is accompanied by an
employee's signed authorization to release information. The form will be
returned directly to the requesting party and filed as part of the Human
Resources or Payroll Department’s confidential records.
Medical Information
DAI is compliant with federal HIPAA
regulations and only utilizes information related to the company sponsored
healthcare plan on a "need to know" basis for administration of the
healthcare plan.
Collection and Use of Customer Information
DAI will not collect customer Personal
Information, unless the customer contacts DAI directly. In order to adequately
address a customer’s concern, their Personal Information may be shared with the
area Development Agent and franchisee. Development Agents assist with franchise
sales, site location, training, and provide operational assistance to
franchisees. Failure to provide necessary information may prevent DAI from
fully addressing any customer concerns.
If you are a participant in the Online SUBWAY® Store, we
ask for contact information, name, shipping address, phone number, and e-mail
address. In the future, we may use this information to contact you regarding
products or promotions, as well as other products and services, which may be of
interest to you. At any time you may “opt out” of future contacts by
un-subscribing from our database or contacting the Privacy Officer.
A customer participating in Subway Express™ through the
www.subway.com website will be asked to
provide Personal Information. Our third party service provider collects and
processes customer information to expedite orders placed on Subway Express™.
The Personal Information collected shall include, but will not be limited to:
name, e-mail address, and telephone number. Our third party service provider
forwards this information to franchisees in order to fulfill the services
offered through Subway Express™.
Holders of SUBWAY® Loyalty Cards and SUBWAY® Gift Cards
(collectively the “SUBWAY® Card”) may voluntarily register their cards through
www.mysubwaycard.com. Our third party service
provider collects Personal Information on a voluntary basis. Information you
may be asked to provide could include but is not limited to: date of birth,
card number, and e-mail address. Your purchase history may also be linked to
this information. This information is used as part of the Lost/Stolen Card
Program and to provide you with targeted offers from us or from selected third
parties, i.e. suppliers of products offered through the SUBWAY® system. If you
do not wish to receive promotional materials with your use of the SUBWAY® Card
you may update your preferences at
www.mysubwaycard.com. Information is also
collected in aggregate that is not considered Personal Information, concerning
the food items purchased and the demographics of the purchasers. This
information may be shared with DAI and its affiliates to improve our product
marketing and advertising. YOU MUST BE 13 YEARS OLD OR OLDER TO REGISTER A
SUBWAY® CARD.
Collection and Use of Franchisee and Prospective
Franchisee Information
By applying to become a SUBWAY®
franchisee, a prospective franchisee consents to the collection, use, and
disclosure of Personal Information in accordance with the following terms and
conditions. We collect and use Personal Information in order to assist a
prospective franchisee in applying to become a SUBWAY® restaurant franchisee
and to assist DAI in selecting franchisee candidates.
Personal Information collected from prospective
franchisees include, but is not limited to: name, address, telephone number,
facsimile number, email address, date of birth, citizenship, educational
background, criminal background, bank account information for Electronic Funds
Transfer, financial statement, litigation history, and taxpayer identification
number. Failure to provide requested Personal Information may negatively impact
a prospective franchisee’s ability to become a franchisee. Once a prospective
franchisee becomes a franchisee, they may then reference themselves by their
Franchise Agreement Number. In order to better service franchisees, a
franchisee’s Personal Information may be shared between DAI and its affiliates,
pursuant to the service contracts between them.
In order to effectively implement the SUBWAY® Gift Card
Program, and to provide purchasing services to members, a franchisee’s
Personal Information may be shared with an independent purchasing cooperative
or other independent third party. The Personal Information shared with the
independent purchasing cooperative shall include, but will not be limited to:
name, address, and bank account information you provided to DAI to establish
your pre-authorized account for the payment of royalties, advertising fees, and
other charges. Subject to a franchisee’s agreement with the independent
purchasing cooperative, the independent purchasing cooperative may bill a
franchisee’s bank account for fees and other costs associated with the SUBWAY®
Gift Card Program. If a franchisee does not wish to disclose this information,
they must notify the Privacy Officer in writing as described in the section
titled “Contact Information” below.
A franchisee and prospective franchisee’s information
may be shared with the Development Agent in their area. A Development Agent is
an independent contractor of DAI or one of its affiliates. Development Agents
assist with franchise sales, site location, training, and provide operational
assistance. Development Agents also make recommendations as to whether a
prospective franchisee in their territory should be granted a franchise. The
Development Agent may use this information to: address a franchisee’s concerns
in a customer complaint, respond to a franchisee’s inquires for franchise
sales, and any other inquiry which may require a response.
A franchisee’s information may be shared with our third
party service provider in order to implement Subway Express™ through the
www.subway.com website. Franchisees may
provide information to the third party service provider directly or DAI may
supplement additional franchisee information to our third party service
provider.
DAI will also share Personal Information in order to
service franchisee leasing needs and related administrative functions.
Franchisee Personal Information may be shared during store transfers. Finally,
franchisee Personal Information may be shared with Subway Franchisee
Advertising Fund Trust (“SFAFT”) in order to provide advertising services to
member stores.
Finally, upon becoming a SUBWAY® franchisee you consent
to DAI disclosing former or past franchisee contact information including
Personal Information in its Disclosure Document for one (1) year after leaving
the system, as required by law, unless you advise. Contact our Privacy Officer
in writing, either by email or regular mail received, of your desire to not
have your details or contact information disclosed, corrected or changed when
you sell or transfer your SUBWAY® store, or exit the SUBWAY® system (whether by
termination or otherwise). To contact the Privacy Officer, please see the
section provided below entitled “Contact Information”.
Collection and Use of Development Agent Information
By applying to become a SUBWAY®
Development Agent, a Development Agent applicant consents to the collection,
use, and disclosure of Personal Information in accordance with the following
terms and conditions. We collect and use information in order to assist you in
applying, and evaluating you to become a Development Agent. Personal
Information is collected to assist DAI and its affiliates in selecting
Development Agent candidates and for the purpose of operating a development
territory.
Personal Information collected includes, but is not
limited to: name, home address, home telephone number, facsimile number, email
address, date of birth, bank account information for Electronic Funds Transfer,
financial statement, resume, taxpayer identification number and background
checks. Once a Development Agent candidate becomes a Development Agent, they
may then reference themselves by their Development Agent Number.
Failure to provide necessary information may negatively
impact your ability to become a Development Agent.
Sharing of Personal Information
We may share Personal Information with
our service providers, consultants and affiliates for our internal business
purposes. Except as described in this Privacy Policy, DAI will not share
Personal Information with a third party, unless a customer requests, consents
to such disclosure, or disclosure is required or authorized by law. DAI
reserves the right to disclose Personal Information to a third party if a law,
regulation, search warrant, subpoena, or court order legally requires or
authorizes us to do so. DAI also reserves the right to disclose and/or transfer
Personal Information to a third party in the event of a proposed or actual
purchase, sale, lease, merger, amalgamation or any other type of acquisition,
disposal, or financing of all or any portion of DAI or of any of the business
or assets or shares of DAI or a division thereof in order for a franchisee or
Development Agent to continue to receive the same products and services from
the third party.
As described above, DAI, its affiliates, third party
service providers and Development Agents may share and exchange Personal
Information in order to process franchisee and Development Agent applications,
administer the SUBWAY® franchise system, implement the SUBWAY® Gift Card
program, implement Subway Express™ and protect the integrity of the SUBWAY®
franchise system and trademarks. Personal Information may be provided to a
courier or freight forwarder in order to fulfill an order, which may have been
requested from us.
Our Development Agents and other service providers are
prohibited from using Personal Information for any purpose other than to
provide assistance. Development Agents are required to protect Personal
Information disclosed by us and to comply with the general privacy principles
described in this Privacy Policy.
Storage, Retention and Accuracy of Personal Information
DAI insures that Personal Information is
safeguarded against loss, access, use, modification, disclosure or other
misuse. All reasonable steps are taken to prevent unauthorized use or
disclosure of your Personal Information.
DAI will retain your Personal Information only for as
long as necessary to fulfill the purpose(s) for which it was collected and to
comply with applicable laws, and your consent to such purpose(s) remains valid
after termination of our relationship with you.
We take all reasonable steps to insure that your
Personal Information is accurate, up-to-date, complete, relevant and not
misleading.
DAI may store your Personal Information in its databases
located in the United States and/or other countries outside of the United
States. Additionally, some of our service providers may reside in the United
States or other countries outside of the United States and will be subject to
the laws of the local jurisdiction. As a result, in certain circumstances, the
United States and other foreign governments, courts, law enforcement agencies
or regulatory agencies may be entitled to access the Personal Information
collected and held by DAI.
Contact Information
You may contact the Privacy Officer to
access, correct or delete your Personal Information. If necessary, the Privacy
Officer will contact another employee to assist in completing your requested
task.
If you have any questions or complaints, please contact
the Privacy Officer. The Privacy Officer can be reached by telephone at: (203)
877-4281 or 1-800-888-4848; by Facsimile at: (203) 876-6690; by email at:
privacyofficer@subway.com; or by mail at
Doctor’s Associates Inc., 325 Bic Drive, Milford, CT, 06461, USA. We will
address your concern and attempt to resolve any problem. Download
Privacy Information Request Form here.
Links to Non-DAI Web Sites and Third Parties
Please note that DAI or SUBWAY® web
sites may contain links to other web sites for your convenience and
information. DAI does not control those sites or their privacy practices, which
may differ from
www.subway.com. DAI’s privacy policy cannot and does not
apply to external Web areas. We do not endorse or make any representations
about third party web sites. The personal data you choose to give to unrelated
third parties is not covered by the DAI privacy policy. We encourage you to
review the privacy policy of any company or website before submitting your
Personal Information. Some third parties may choose to share their personal
data with DAI; that sharing is governed by that third party company’s privacy
policy.
Safe Harbor Compliance
DAI is in compliance with the U.S.
Department of Commerce Safe Harbor requirements regarding the transfer of
personal information from European Union member countries to the United States.
DAI has been Self-Certified in accordance with the EU Directive on Personal
Data Protection. The principles of Safe Harbor compliance are notice, choice,
onward transfer, security, data integrity, access and enforcement. Additional
information about Safe Harbor principles and certification process can be found
at
http://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.
Members of the European Union
If you are a resident of a Member State
of the European Union and have any concerns or complaints, please first address
these issues to the Privacy Officer. Doctor’s Associates Inc. is located in the
United States, as are the servers that make our websites available. All matters
relating to privacy issues and websites 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
telephone at (202)382-4537.
International Privacy Policies
To view your country’s Privacy Policy
please go to
www.subway.com. At the top of the page, please click on
AROUND THE WORLD, then click on your country. Go to the very bottom of your
country’s page and click PRIVACY POLICY to view your country’s specific Privacy
Policy.
Changes to our Privacy Policy
We reserve the right to modify this
privacy statement at any time, so please review it frequently. If we make
material changes to this policy, we will notify you in this Privacy Policy, by
email, or by means of a notice on our home page.
International
Privacy Policies
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