PRIVACY POLICY

SUBWAY FRANCHISEE ADVERTISING FUND TRUST
www.subwayfreshbuzz.com


PRIVACY POLICY

SUBWAY FRANCHISEE ADVERTISING FUND TRUST

www.subwayfreshbuzz.com
This is the Internet Privacy Policy for the www.subwayfreshbuzz.com 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 Web site 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 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.