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Privacy Policy

SRS PRIVACY POLICY
Subway Realty of Spain, S.L.
Madrid, Spain

Your privacy is very important to us. This privacy policy discloses how Subway Realty of Spain, S.L. ("SRS") collects, protects, uses and shares personal information gathered about you, in conformance with Directive 95/46/EC of the European Parliament, the Council of 24 October 1995, and the Safe Harbor Principles established by the United States Department of Commerce in consultation with the European Commission. 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. SRS respects the privacy of our customers, franchisees, and other visitors to our websites who may choose to provide personal information. We recognize the need for appropriate protections 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 the 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, and Identification Number, among other information,

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 Subway International B.V. ("SIBV"), the franchisor of the SUBWAY® system in Spain, in selecting franchisee candidates.
Personal Information collected from prospective franchisees includes, but is not limited to: name, address, telephone number, facsimile number, and email address. 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 SIBV and its affiliates, pursuant to the service contracts between them.
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 SIBV. 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.

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, SRS 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. SRS 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. SRS 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 SRS or of any of the business or assets or shares of SRS order for a franchisee or Development Agent to continue to receive the same products and services from the third party.
As described above, SRS, its affiliates, third party service providers and Development Agents may share and exchange Personal Information in order to process franchisee applications.
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

SIBV 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.
SIBV 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.

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: +34 902 109 004; by Facsimile at: +34 911881316; by email at: This email address is being protected from spambots. You need JavaScript enabled to view it. or by mail at: Subway Realty of Spain, S.L. Paseo de la Castellana 144 7ºE, 28046, Madrid, Spain.
We will address your concern and attempt to resolve any problem.
Links to Non-SIBV Web Sites and Third Parties
Please note that SIBV or SUBWAY® web sites may contain links to other web sites for your convenience and information. SRS does not control those sites or their privacy practices, which may differ from www.subwayspain.com. SRS'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 SRS privacy policy. We encourage you to review the privacy policy of any company or web site before submitting your Personal Information. Some third parties may choose to share their personal data with SRS; that sharing is governed by that third party's privacy policy.

Safe Harbor Compliance

Doctor's Associates Inc., the owner of the SUBWAY® trademarks and System and("DAI"), an affiliate of SRS, 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 - Individuals must be informed that their data is being collected and about how it will be used;
  • Choice - Individuals must have the ability to opt out of the collection and forward transfer of the data to third parties;
  • Onward Transfer - Transfers of data to third parties may only occur to other organizations that follow adequate data protection principles;
  • Security - Reasonable efforts must be made to prevent loss of collected information;
  • Data Integrity - Data must be relevant and reliable for the purpose for which it was collected;
  • Access - Individuals must be able to access information held about them, and correct or delete it if it is inaccurate;
  • Enforcement - There must be effective means of enforcing these rules.

Further information regarding the Safe Harbor principles and certification process can be found at www.export.gov/safeharbor. SIBV, while not self-certified with Safe Harbor, acknowledges the principles of Safe Harbor and strives to meet these requirements.
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. SRS is located in Spain, however, the servers that make our websites available are located in the United States. 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 phone at (202) 382-4357.

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.

REVISED: SRS 10/09

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