Effective as of October 19, 2021
PRIVACY POLICY
At SUBWAY Kuwait (“SUBWAY”, “we” or “us”), we appreciate the trust
our customers have in our brand and are committed to protecting and
safeguarding your privacy. This Privacy Policy sets out our privacy
practices when you visit our restaurants; use our websites, mobile
applications and in-restaurant technologies or other service or
platform that links or refers to it; subscribe to our email
newsletters and other digital properties; or provide personal data
to use our services (collectively, the “Services”) as well as
interact with us on third party platforms (such as social media).
1. INFORMATION WE COLLECT
We collect personal information about our users in three ways:
- Information that you provide to us;
-
Information that we collect through your use of the Services;
and
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Information that we collect from third parties and/or publicly
available sources.
INFORMATION YOU PROVIDE TO US:
We collect information you give us when you use the Services. The
types of personal information we collect may include:
-
Account information, such as username, password and any other
identifiers or credentials as may be necessary to access the
Services and acquire SUBWAY products and services;
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Transaction information, such as the products purchased, price,
method of payment, payment details, coupons and rewards used
when processing transactions you have requested;
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Personal details, such as name (first name and last name),
postal address, email address, mobile and/or landline phone
number, date or birth, gender, and other contact information you
provide to us; and
-
Other personal information you provide to us when you interact
with us and use our Services.
The circumstances in which you provide personal information may
include when you:
- Register to use the Services;
- Purchase products using our Services or at our restaurants;
- Request delivery of products purchased;
-
Use coupons and rewards you may have earned in a SUBWAY loyalty
program;
- Opt-in to receive marketing or other communications;
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Use our WiFi networks, kiosks or other in-store technologies;
-
Participate in a surveys, contest, sweepstakes or other
promotion;
- Submit information when providing feedback; or
- Use any other feature of the Services
INFORMATION ABOUT YOUR USE OF THE SERVICES:
In addition to the information you provide to us directly, we may
collect information about your use of the Services. For example, we
may collect:
-
Device information - such as your hardware type and model, IP
address, other unique device identifiers, operating system
version, browser type and version, and settings of the device
you use to access the Services;
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Usage information - such as information about the Services you
use, the time and duration of your use of the Services, address
of a referring website (if any), and other information about
your interaction with content offered through the Services, and
any information stored in cookies and similar technologies that
we have set on your device; and
-
Location information - such as your computer’s IP address, your
mobile device’s GPS and Bluetooth signals or information about
nearby WiFi access points and cell towers that may be
transmitted to us when you use the Services.
INFORMATION FROM THIRD PARTY SOURCES:
We may acquire or receive information about you from publicly and
commercially available sources, as permitted by law, which we may
combine with other information we receive from or about you. For
example, we may receive information about you from a social media
site if you connect to the Services through that site.
OTHER INFORMATION WE COLLECT:
We also may collect other information about you, your device, or
your use of the Services in ways that we describe to you at the
point of collection or otherwise with your consent.
PERSONAL INFORMATION STORAGE TIME:
SUBWAY retains personal information for as long as it is needed to
fulfill the purposes for which it was collected and in order to
comply with legal and regulatory requirements. This may mean that
some information is held for longer than other information.
2. HOW WE USE INFORMATION
We use the information we collect to, among other things:
- Register and create your account;
-
Enable you with access and use of our Services and its features;
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Provide and manage the products and services you request,
including but not limited to fulfilling orders, processing
payments and providing delivery services;
- Personalize your experience with our Services;
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Remember you, for your convenience, when you use our Services;
-
Communicate with you, if you have provided permission,
information about our products, services, offers, contents,
sweepstake or other promotions or those of our business partners
that we believe may interest you;
- Deliver targeted advertising, promotions and offers to you;
-
Communicate with you about your use of Services or your orders,
purchases, customer support inquiries or accounts with SUBWAY;
- Diagnose technical and service issues;
-
Understand our customers so that we can develop and improve our
products, offers, promotions and the Services and other
technologies;
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Perform data analytics, including consumer research, trend
analysis, and financial analysis;
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Protect against, identify, and prevent fraud and other crime,
claims and other liabilities;
-
Use for any other purposes for which you have consented or as
permitted or required by any applicable law; and
- Comply with any applicable laws, rules and regulations.
We may otherwise use your information with your consent or at your
direction.
3. SHARING OF INFORMATION
We do not sell your personal information to any third parties for
monetary or other financial considerations. The following provides
information about entities with which we may share information. Our
practices vary depending on the type of information and sharing.
AFFILIATES, SUBSIDIARIES AND FRANCHISEES. We may share information
within our family of affiliated companies and local owners of
SUBWAY®, restaurants, as applicable, so that we may fulfill your
requests, deliver products and services to you, provide offers and
promotions that may be relevant to you, understand your preferences,
and improve our Services.
BUSINESS PARTNERS. We may also share your information with business
partners to provide you with Services that you request. For example,
if you sign up for a promotion that runs on our Services but that is
sponsored or co-sponsored by another company, your information may
be shared with that sponsor. We are not responsible for the privacy
practices of these entities and recommend you review their privacy
policies carefully.
SERVICE PROVIDERS. We may share information with companies providing
services on our behalf, such as fulfilling orders and providing
information technology and data processing services, delivery
services, advertising services, data analytics, marketing services,
and research services. We also may share your information, including
your payment information, as appropriate to process your payments
for the Services or complete a transaction. Our service providers
are given the information they need to perform their designated
functions, and we do not authorize them to use or disclose personal
information for purposes other than those provided in the Privacy
Policy.
SOCIAL MEDIA SERVICES. If you connect a social media account with
the Services or engage with our services through a social media
platform, we may share your information with that social media
platform, and it may share information about you with us. We may use
this information to personalize your experience on the Services and
on the third party social media platforms, or to provide you with
offers or other products or Services you may request. The social
media services’ use of the shared information will be governed by
the social media services’ privacy policy and your social media
account settings. If you do not want your information shared in this
way, do not connect your social media service account with the
Services.
COMPANIES THAT PROVIDE CONTENT, ADVERTISING, OR FUNCTIONALITY. Some
of the content, advertising, and functionality on our Services may
be provided by third parties, such as our advertisers. These
companies may collect or receive certain information about your use
of the Services, including through the use of cookies, beacons, and
similar technologies, and this information may be combined with
information collected across different websites and online services
in order to deliver ads that are more relevant to you, both on and
off our Services.
OTHER PARTIES WHEN REQUIRED OR PERMITTED BY LAW, OR AS NECESSARY TO
PROTECT OUR USERS AND SERVICES. We and our service providers
(including affiliates) may use and share your personal information
as we believe is necessary or appropriate to protect, enforce, or
defend the legal rights, privacy, safety, or property of the
Services, our employees or agents or users, to detect, suppress or
prevent fraud or where otherwise required or permitted by applicable
law or legal process, including legally valid requests from public
and government authorities.
OTHER PARTIES IN CONNECTION WITH A CORPORATE TRANSACTION. We reserve
the right to transfer any information we have about you in the event
that we sell or transfer all or a portion of our business or assets
to a third party, such as in the event of a merger, acquisition, or
in connection with a bankruptcy reorganization. We may transfer
information we have collected and stored, including personal
information, to the party or parties involved in the transaction as
part of that transaction.
OTHERWISE WITH YOUR CONSENT OR AT YOUR DIRECTION. In addition to the
sharing described in this Privacy Policy, we may share information
about you with third parties whenever you consent to or direct such
sharing.
AGGREGATED DATA. We also may provide aggregated information, and
data with personal identifiers removed, to third parties to describe
how our customers are using the Services.
4. COOKIES, SIMILAR TECHNOLOGIES AND ONLINE ADVERTISING
We and other companies that provide advertising and other services
on our Services may use cookies, web beacons, and similar
technologies to facilitate administration and navigation, to better
understand and improve our Services, to determine and improve the
advertising shown to you here or elsewhere, and to provide you with
a customized online experience.
COOKIES. “Cookies” are small files that are placed on your computer
or Internet connected device when you visit a website. Cookies may
be used to store a unique identification number tied to your
computer or device so that you can be recognized as the same user
across one or more browsing sessions, and across one or more sites.
Cookies serve many useful purposes. For example:
-
Cookies can remember your sign-in credentials, so you do not
have to enter those credentials each time you visit a
Service
-
Cookies can help us and third parties understand which parts
of our Services are the most popular because they help us
see which pages and features visitors access and how much
time they spend on the pages. By studying this kind of
information, we are better able to adapt our Services and
provide you with a better experience.
-
Cookies help us and third parties understand which ads you
have seen so that you do not receive the same ad each time
you access a Service.
Most browsers accept cookies automatically but can be configured not
to do so. If you wish to disable cookies, refer to your browser help
menu to learn how to disable cookies. If you disable cookies, it may
interfere with the functioning of the Services.
BEACONS. We, along with third parties, also may use technologies
called beacons (or “pixels”) that communicate information from your
device to a server. Beacons can be embedded in websites,
applications, online content, videos, and emails, and can allow a
server to read certain types of information from your device, know
when you have viewed particular content or a particular email
message, determine the time and date on which you viewed the beacon,
and the IP address of your device. We and third parties use beacons
for a variety of purposes, including to analyze the use of our
Services and (in conjunction with cookies) to provide content and
ads that are more relevant to you both on and off the Service.
DO-NOT-TRACK SIGNALS AND SIMILAR MECHANISMS. Some web browsers may
transmit “do-not-track” signals to the websites with which the user
communicates. Because of differences in how web browsers incorporate
and activate this feature, it is not always clear whether users
intend for these signals to be transmitted, or whether they even are
aware of them. Because there currently is no industry standard
concerning what, if anything, websites should do when they receive
such signals, the Services currently do not take action in response
to these signals. If and when a final standard is established and
accepted, we will reassess how to respond to these signals.
LOCAL STORAGE AND OTHER TRACKING TECHNOLOGIES. We, along with third
parties, may use other kinds of technologies, such as Local Shared
Objects (also referred to as “Flash cookies”) and HTML5 local
storage, in connection with our Services. These technologies are
similar to the cookies discussed above in that they are stored on
your device and can be used to store certain information about your
activities and preferences. However, these technologies may make use
of different parts of your device from standard cookies, and so you
might not be able to control them using standard browser tools and
settings. For HTML5 local storage, the method for disabling HTML5
will vary depending on your browser. For Flash cookies, information
about disabling or deleting information contained in Flash cookies
can be found here.
INTEREST - BASED ADVERTISEMENTS. We may use third parties to serve
advertisements on our Services and on other websites and digital
platforms. These companies may use cookies, web beacons or other
technologies to report certain information about your visits to our
Services and other websites (such as web pages you visit and your
response to ads) in order to measure the effectiveness of our
marketing campaigns and to deliver ads that are more relevant to
you, both on and off our Services. To learn more and to opt-out of
having your information used by these companies for online
behavioral advertising purposes, please see “Choices with Respect to
Interest-Based Advertisements” below. We may also use services
provided by third parties (such as social media platforms) to serve
targeted ads to you and others on such platforms. We may do this by
providing a hashed version of your email address or other
information to the platform provider.
5. PRIVACY AND CHOICES AVAILABLE TO YOU
CHOICES WITH RESPECT TO COOKIES AND SIMILAR TECHNOLOGIES. You may
block cookies and similar technologies in your browser or device
settings, as and if permitted by such device. If you block cookies
and similar technologies, you may not be able to take advantage of
all the feature of the Services.
CHOICES WITH RESPECT TO LOCATION INFORMATION. You may withdraw your
permission for SUBWAY to acquire your location information in your
browser or device settings, as and if permitted by such device.
Certain features of the Services may not function properly with
access to precise location information.
CHOICES WITH RESPECT TO MARKETING COMMUNICATIONS. If you have
opted-in to marketing communications, you may opt out of receiving
commercial email, text message, and other electronic messages from
us (excluding transactional messages) by following the instructions
contained in those messages.
CHOICES WITH RESPECT TO INTEREST - BASED ADVERTISING. You may opt
out of receiving targeted advertising from participating ad
networks, audience segment providers, ad serving vendors, and other
service providers by visiting websites operated by the Network
Advertising Initiative and Digital Advertising Alliance:
MANAGE YOUR ACCOUNT. You may access or modify your account on the
account page, or by emailing or writing to us at the contact
information set out below under Contacting Us. Whichever way you
elect to contact us, we may ask that you confirm and verify your
identity.
DATA ACCESS. Subject to applicable law and certain exceptions
prescribed by law, you may request access, updating, correction and
deletion personal information in our custody and control by emailing
or writing to us at the contact information set out below under
Contacting Us. Whichever way you elect to contact us, we may ask
that you confirm and verify your identity and/or provide other
details to assist us in responding to your request.
6. DATA SECURITY
SUBWAY is committed to taking appropriate measures designed to keep
personal information secure. We have in place physical, electronic
and managerial procedures to protect personal information in our
custody and control against loss, theft and unauthorized access,
use, modification and disclosure. However, as effective as these
measures are, no security system is impenetrable. We cannot
guarantee the security of our Services, nor can we guarantee that
the information you provide will not be intercepted while being
transmitted to us over the Internet. You agree that, under such
circumstances, we shall not be liable or responsible for any
unauthorized use, sharing, transfer, alteration, loss, or damage to
any information that we may have gathered.
7. OTHER IMPORTANT INFORMATION
CHILDREN'S PRIVACY. We do not knowingly collect any personal
information from children under the age of 13 without parental
consent, unless permitted by law. If we learn that a child under the
age of 13 has provided us with personal information without parental
consent, we will delete this information in accordance with
applicable law. Parents may change previously provided consent and
request no further collection or use of their child’s personal
information. To do so, please contact us by emailing or writing to
us at the contact information set out below under Contacting Us.
LINKS TO THIRD PARTY SITES
Our Services may link to third party websites and services that
are not operated by SUBWAY and/or our affiliates or may have
other apps, tools, widget and plug-ins on our Services, such as
Facebook “Like” buttons (“Third Party Services”). We are not
responsible for the security or privacy of any information
collected by Third Party Services, and any information you
submit to these Third Party Services are subject to their
privacy policies. Please exercise caution and review the privacy
policies applicable to the Third Party Services you use.
INTERNATIONAL TRANSFERS
Please be aware that information you provide to us or that we
obtain as a result of your use of the Services may be collected
in your country and subsequently transferred to, maintained and
processed in the United States or another country by us or our
service providers for the purposes mentioned above in accordance
with applicable law. The privacy laws of these countries may not
always offer the same level of protection as in your country. By
using the Services, you consent to the collection, international
transfer, storage, and processing of your information.
CONSENT
By using Services, you consent to this Privacy Policy and the
SUBWAY Terms & Conditions.
CHANGES TO OUR PRIVACY POLICY
We may modify this Privacy Policy from time to time. We will
notify you of changes by posting the revised version here, or by
other means. Any changes to the Privacy Policy will become
effective when the updated policy is posted on the Services.
Your use of Services or your provision of personal information
to use the Services following such changes indicates your
acceptance of the revised Privacy Policy.