THE SUBWAY® GROUP PRIVACY STATEMENT
CALIFORNIA PRIVACY NOTICE
These additional disclosures apply only to individuals who reside in California and are provided pursuant to the California Consumer Privacy Act, as modified by the California Privacy Rights Act of 2020 (the 'CCPA'). 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.”
Categories of Personal Information We Collect and Disclose
The following chart details which categories of personal information we collect, and have collected, from and about California residents in the past twelve (12) months, as well as the categories of third parties to whom we have disclosed each category of information for a business purpose, and the categories of third parties with whom we have “sold” or “shared” each category of information for purposes of cross-context behavioral advertising (as such terms are defined in the CCPA) (where applicable).
|Category of Personal Information||Categories of Recipients|
|Disclosures for a Business Purpose||Sold or Shared for 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|
|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.|
|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)|| |
|Commercial Information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|Internet or other electronic network activity information, including search history, and information regarding interactions with our websites, applications, or advertisements.|
|Audio, electronic, visual, thermal, olfactory, or similar information.|
|Professional or employment-related information.|
|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).|
|Inferences used to create a profile reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes|
|Sensitive personal information, including log-in information for accounts in combination with passwords allowing access to the accounts and precise geolocation.|
How we use your Information
Disclosure of Personal Information for a Business PurposeIn 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.
Sharing or Selling your Personal Information
Although we do not “sell” personal information in exchange for money, some of our advertising practices on our websites may be classified as a “sale” under the CCPA. As detailed in the chart above, we sell and share certain categories of your personal information with third parties for 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
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 form located here. 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.
Right to Know. You have the right to know certain information about our data practices in the preceding 12 months. You have the right to request the following information from us:
- 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.
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 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 of “Sale” or “Share”. 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” under California 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.
How to Exercise Your California Rights. To exercise any of these rights, please fill out this form or 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. 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.
You can 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 email@example.com.
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 disclose 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 here.
Notice of Financial Incentive
We offer the Subway® MVP Rewards Program that provides certain perks, such as rewards and exclusive offers. You can enroll at Rewards. Full Program terms can be found here. 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.
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). 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.
You may withdraw from participating in a Program at any time. You can withdraw from Subway® MVP Rewards by removing the Subway® App from your device at any time or submitting a request here. 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.
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