SUBWAY FRANCHISEE ADVERTISING FUND TRUST
WWW.SUBWAYFRESHBUZZ.COM
PRIVACY POLICY
This is the Internet Privacy Policy for the www.subwayfreshbuzz.com web site.
You can write to us at SFAFT, 488 Wheelers Farms Road, Milford, CT 06461.
We can be reached by email at privacyofficer@sfaft.org ,
or you can call us at 1-800-992-6141.
The Subway Franchisee Advertising Fund Trust ("SFAFT"), the sponsor
of the www.subwayfreshbuzz.com web
site, values individual 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. At certain points on the www.subwayfreshbuzz.com
web site, you may be asked to submit information that may personally identify
you ("Personal Information" or "Personally Identifiable Information"). All
Personally Identifiable Information that we gather is collected in a fair and
non-intrusive manner, with your consent, in order to better serve you. Personally
Identifiable Information that you submit via this web site is only accessible
to SFAFT employees, contractors and service providers who need the information
for the purposes for which it is collected or as you consent.
This Privacy Policy applies to the collection of Personal Information at www.subwayfreshbuzz.com .
Different privacy policies and procedures may apply to the collection of Personal
Information by Doctor's Associates Inc. ("DAI"), on its website at
www.subway.com and offline; to the independently owned and operated SUBWAY® restaurants;
to other web sites; and to information that we obtain offline.
Collection and Use of Personal Information
For the areas of the www.subwayfreshbuzz.com web
site where the collection of Personally Identifiable Information is necessary,
you will be aware that such information is required because you will have to
complete an online form. We may collect Personally Identifiable Information
from you, for example, when you visit areas on the www.subwayfreshbuzz.com where
you can submit your name, address and/or other Personal Information in order
to: enter a SUBWAY® sweepstakes; request a SUBWAY® coupon; or ask for
tips on healthy eating from Jared. The Personal Information that you submit
is gathered only on a voluntary basis; 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 collect limited Personally Identifiable Information, including, but
not limited to your name and/or any "nickname", date of birth, email
and postal address and any other information that would allow someone to identify
or contact you, as well as information about your personal/product preferences,
survey responses and online activities, if any, that is known by SFAFT. We
may also collect limited Personal Information about others from you including,
but not limited to, name and email address.
We may collect 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 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;
• 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 or 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 privacyofficer@sfaft.org .
If you have not opted-out of receiving marketing materials, we may also use,
but will not disclose, your Personal Information to promote and market additional
goods, services and special offers from us and our affiliates. Otherwise, we
do not provide your information to third parties for their own direct marketing
purposes. At any time you may "opt out" of future contacts by un-subscribing
from our contact list or contacting the Company Privacy Officer at privacyofficer@sfaft.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.
Typically, we will seek consent for the use of your Personal Information at
the time of collection. In certain circumstances, consent may be sought after
the information has been collected but before use (for example when we want
to use information for a use not previously identified). The form of consent
we seek, including whether it is express or implied, will largely depend on
the sensitivity of the information and the reasonable expectations of the individual
in the circumstances. You may withdraw consent at any time, subject to legal
and contractual restrictions and reasonable notice. If you wish to withdraw
consent, please contact our Privacy Officer in the manner described below.
We will inform you of the implications of withdrawing consent at or before
the time of withdrawal.
We will not, as a condition of the supply of a product or service, require
you to consent to the collection, use or disclosure of information beyond that
required to fulfill the explicitly specified and required purposes for which
the information is being required.
Sharing of Personal Information
Except as described in this Privacy Policy, SFAFT will not disclose your Personal
Information to a third party, unless you request or otherwise consent to such
disclosure, or disclosure is required or authorized by law.
We do not sell information to third parties. We may share information with
agents, affiliates 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, affiliates 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. We also
require any third parties we retain to protect Personal Information disclosed
by us [in accordance with all applicable state, federal, and foreign privacy
requirements and the general privacy principles described in this Privacy Policy].
Your Personal Information may be provided to a courier or freight forwarder
in order to fulfill an order you may have requested from us or supply a promotion
prize or award. 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.
Although we make every effort to preserve user privacy, we may need to disclose
Personally Identifiable Information in certain limited circumstances, specifically:
(1) to comply with a judicial proceeding, a court order, or subpoena, or as
otherwise may be required by law; (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 the www.subwayfreshbuzz.com web
site, we may collect some information about you using software or other technology
where it may not be readily apparent to you that it is being collected. 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.
When you visit our web site, we place a text file called a "cookie" in the
browser directory of your computer's hard drive. Cookies are pieces of information
that a web site sends to your computer while you are viewing the web site.
These pieces of information allow the web site to remember important information
that will make your use of that site more useful. Internet companies use cookies
for a variety of purposes.
We use cookies to help improve your future visits. We may also track data such
as the total number of visits to our web site and the number of visitors to
each page of our web site. We may use this information, in aggregate form,
for system maintenance and to better understand how our visitors use our site
and services so that we can make them better. You can choose to have your computer
warn you each time a cookie is being sent, or you can choose to turn off all
cookies. You do this through your browser (like Netscape Navigator or Internet
Explorer) settings. Each browser is a little different, so look at your browser
Help menu to learn the correct way to modify your cookies. If you turn cookies
off, you won't have access to many features that make your experience on our
web site more efficient and some of our services will not function properly.
Our websites may also use small pieces of software code called "web beacons" or "clear
gifs" to collect anonymous and aggregate advertising matrix, such as counting
page views, promotion views, or advertising responses. A web beacon is an electronic
image called a single-pixel or clear GIF. Web beacons can recognize certain
types of information, such as a user's cookie number, time and date of a page
view, and description of the page where the web beacon is placed. You may render
some web beacons unusable if you choose to reject their associated cookies.
These web beacons may be used to deliver cookies that conform with our cookie
policy above.
Banner Advertisements and Links to Other Sites
This Privacy Policy applies only to SFAFT and www.subwayfreshbuzz.com and does not include third-party web sites. Our site may include banner advertisements or contain links to other sites operated by third parties whose information practices may be different than those at this site. Other Internet sites you visit may have their own privacy policies or no policy at all. Other web sites might use Personal Information differently than our policy permits. SFAFT does not guarantee the standards of any web site not related to this site. SFAFT is not responsible for the content, practices, or password information practices of the web sites operated by these third parties. In addition, these banner advertisements and links do not constitute sponsorship, endorsements, or approval by SFAFT of the content, policies, or practices of these web sites.
Please note that the privacy policies of affiliates and/or third party web
sites, including but not limited to, www.subway.com and the Subway Online
Store may differ from those of SFAFT. You should carefully review the
relevant third party web site's privacy policy and terms of use in order
to understand its policies and practices regarding the collection and use
of Personally Identifiable Information before providing any Personal Information.
A Note to Parents/Guardians
SFAFT takes special measures to help maintain and protect the personal privacy
of children under 13 years of age for the purposes of complying with the Children's
Online Privacy and Protection Act of 1998 ("COPPA") in the United
States. For more information about SFAFT's privacy practices for safeguarding
the Personal Information of children, please go to our web site for children,
http://subway-kids.com/privacy.htm, and the Privacy Policy for that web site.
The www.subwayfreshbuzz.com web
site is a general audience site that is neither designed nor intended to collect
any Personally Identifiable Information from children under the age of 13.
At the www.subwayfreshbuzz.com web
site we have put in to place certain screens to ensure that children under
13 do not submit Personally Identifiable Information, and we do not knowingly
accept any information from children under the age of 13. However, if the parent
or legal guardian of a child under 13 believes that the child has provided
us with Personally Identifiable Information, the parent or guardian of that
child should contact us at privacyofficer@sfaft.org if
they want this information deleted from our files. If SFAFT otherwise obtains
knowledge that it has Personally Identifiable Information about a child under
13 in its files, we will delete that information from out existing files so
that it is not in retrievable form.
Data Integrity and Security
We strive to keep any information you provide as secure as possible, and we require our agents, affiliates and service providers to follow the same high standards. 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.
International Visitors
While we operate internationally, the servers that will host, store and process
information relating to www.subwayfreshbuzz.com are
currently based in the United States. Unless otherwise specified, data submitted
to www.subwayfreshbuzz.com will
be processed by us in the United States, where data protection and privacy regulations
may not offer the same level of protection as in other parts of the world. By
providing Personally Identifiable Information to us you authorize the export
of such Personally Identifiable Information to the United States and its storage
and use as specified herein, which includes the use of cookies as described above.
Changes
SFAFT will maintain Personal Information in accordance with this Privacy Policy.
In the future, we may modify this Privacy Policy. If we decide to change our
Privacy Policy, we will post those changes to this Privacy Policy. We will use
information in accordance with the Privacy Policy under which the information
was collected. However, if we are going to use Personally Identifiable Information
in a manner different from that stated at the time of collection we will notify
users by email. Users will have a choice as to whether or not we use their information
in this different manner. If users have opted-out of all communications with
the site, or deactivated their account, then they will not be contacted, nor
will we use their Personally Identifiable Information in this new manner.
How You Can Access, Control and Update Information About You
We want to be sure that we keep only the most 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 privacyofficer@sfaft.org
to update your contact information.
You may choose at any time to remove your name, telephone numbers, and postal
and email addresses from the lists we use to send notices or updates and elect
not to receive correspondence from us by sending us an email at privacyofficer@sfaft.org
.
You may contact the Privacy Officer to access or update your Personal Information.
If necessary, the Privacy Officer will contact another employee to assist in
completing your requested task.
To protect your privacy, we will take reasonable steps to help verify your identity
before granting access or making changes.
Contact Us
If you have any questions or complaints, please contact the Privacy Officer.
The Privacy Officer can be reached by telephone at: 1-800-992-6141; by Facsimile
at: Fax: 203-876-6687; by email at: privacyofficer@sfaft.org, or contact
us at the following mailing address:
SFAFT
Attn: Privacy Officer SFAFT
488 Wheelers Farms Road
Milford, CT 06461
Tel: 1-800-992-6141
Fax: 203-876-6687
We will address your concern and attempt to resolve any problem. 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 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 phone at (202) 382-4357.
This Privacy Policy was last updated on Sept 21, 2006.
