Subcard Australia Pty Ltd (ABN 81 623 161 026) (we, us and our) operates the Subcard® loyalty, gift and online ordering program in Australia (Subcard® Program). Subcard Australia Pty Ltd is a subsidiary of Independent Purchasing Company (Australasia) Ltd (IPC Asia Pacific). IPC Asia Pacific is an independent Subway® Franchisee owned and operated purchasing company.
The Subway Group. While we are working with the Subway Group to implement the Subcard® Program, the Subway Group is independent from Subcard Australia Pty Ltd and IPC Asia Pacific. The Subway Group is made up of a variety of companies that franchises and supports the Subway® restaurant concept worldwide. Subway® restaurants are independently owned and operated by franchisees.
The Subway Group includes Subway IP, Inc. (the owner of the Subway® trademark and the proprietary system for establishing and operating Subway® branded restaurants), FWH Technologies, LLC (the owner and licensor of the SubwayPOS® software for use in Subway® restaurants), Franchise World Headquarters, LLC (a service-oriented company that provides core business related services to other Subway Group entities), the Subway® franchisors (which offer and sell franchises worldwide), and the Subway® advertising entities (which administers national and local advertising on behalf of Subway® restaurants) along with other companies that support the Subway® brand. To see a list of the Subway Group entities that may come in contact with your personal information and to learn more about how the Subway Group may collect and use your information, please read the Subway Group Privacy Statement at https://www.subway.com/en-AU/Legal/PrivacyStatement-FWH
What is personal information?
"Personal information" is information or an opinion, in any form and whether true or not, about an identified individual or an individual who is reasonably identifiable. Examples include an individual's name, address, contact number and email.
The kinds of personal information we collect and hold
The kinds of personal information we collect and hold about you depends on the nature of your dealings with us and the circumstances of collection, including whether we collect the information from you as a member of the Subcard® Program, a guest on our Subway® online ordering platform, a representative of one of our suppliers, a Subway® franchise owner, or in some other capacity.
For example, if you register as member of the Subcard® Program, we collect and hold personal information such as:
- your personal details such as your name, email, date of birth, telephone number and gender;
- your Subcard® card number;
- your loyalty and/or gift balance/s;
- offers applicable to your membership of the Subcard® Program;
- details of purchases applicable to your membership of the Subcard® Program, including products purchased, date and location of purchase, gift dollars purchased or redeemed and reward dollars earned or redeemed; and
- information about the payment method you might use for your purchases through one of our websites (including www.subcard.com.au and www.order.subway.com.au) or the Subway® mobile application (Subway app).
If you make a purchase as a guest on one of our websites, we collect and hold personal information such as your name and phone number and details about the payment method you use for your purchases.
If you deal with us in some other capacity, we may collect your name and contact details and any other information you choose to provide to us. We may also collect details of the interactions you have with us.
We do not generally collect sensitive information (such as health information), and we will only collect sensitive information about you with your consent (unless we are otherwise required or authorised by or under law to do so).
How we collect and hold personal information
We collect personal information in a number of ways, including:
- directly from you (such as when you interact with us in writing, electronically or via telephone);
- when you register as a member of the Subcard® Program on one of our websites or through the Subway® app;
- when you make a purchase on one of our websites or through the Subway® app; and
- when you make a purchase using your Subcard® Program card in a participating Subway® restaurant.
The purposes for which we collect, hold, use and disclose personal information
We collect, hold, use and disclose personal information for a range of purposes, including:
- conducting and administering the Subcard® Program;
- administering the accounts of members of the Subcard® Program;
- supplying and promoting Subway® products to members of the Subcard® Program;
- responding to enquiries about our programs and services;
- processing payments made to us by franchise owners;
- for our administrative purposes and internal record keeping;
- performing research and analysis; and
- managing our relationships with Subway® franchise owners who participate in the Subcard® Program.
We may use and disclose your information for other purposes required or authorised by or under law (including purposes for which you have provided your consent).
If we are unable to collect personal information from or about you, we may not be able to provide our products or services to you, respond to your enquiries or engage in certain other dealings with you.
If you register for the Subcard® Program or make a purchase through one of our websites, the app or in a restaurant, we may use (and share with Subway Systems Australia Pty Ltd) your personal information so that we, Subway Systems Australia Pty Ltd or participating Subway® restaurants can contact you with information about Subway® products, special offers, promotions and events that may be of interest to you.
We may send these communications by email, mobile, SMS, push notifications or via a survey. You can let us know at any time if you no longer wish to receive these communications, by modifying the communication preferences for your Subcard® Program account at www.subcard.com.au or the Subway® app, or by using the opt-out/unsubscribe facility in our communications. Your consent will be deemed if you do not opt out when we offer you the opportunity to do so, and will remain current until you advise us otherwise.
Disclosure of personal information to third parties
We may disclose personal information we collect to third parties for the above purposes. These third parties include:
- Subway® entities, including Franchise Worldwide Headquarters, LLC and Subway Systems Australia Pty Ltd;
- our contracted service providers, including our information technology and loyalty program service providers and professional advisers; and
- financial institutions for payment processing.
Disclosure of personal information to overseas recipients
Some of our service providers and Subway® entities are located overseas and, as a result, personal information collected and held by us may be transferred overseas. In particular, Subway® headquarters are located in the US, and we use service providers located in the USA, Australia and New Zealand to store and process information about Subcard® Program members, guests and Subway® franchise owners on our behalf.
How we hold personal information, and quality and security of personal information
We generally hold personal information in computer systems, including computer systems operated for us by our service providers. We take reasonable steps to protect the personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. This includes taking appropriate security measures to protect electronic materials, and requiring our service providers to do so too.
We take reasonable steps to ensure that personal information we collect, use and disclose is accurate, complete, up to date and relevant. You can help by letting us know about any changes to your personal information (such as your address or phone number), for example by updating your Subcard® Program account details any time at www.subcard.com.au.
Access to and correction of your personal information
Please contact us (using the contact details at the end of this policy) if you would like to access or correct the personal information we hold about you. We will generally provide you with access to your personal information (subject to some exceptions permitted by law), but may charge an access fee to cover the cost of retrieving the information and supplying it to you.
Our websites (www.subcard.com.au and www.order.subway.com.au)
Collection of information other than personal information
Some of the information collected about your visit to our websites is not personal information, because it does not reveal your identity. For example, we may record your server address, the date and time of your visit, the pages you viewed, any documents you downloaded and the type of browser and operating system you used.
If collected, this information will be used and disclosed by us in anonymous, aggregated form only, for purposes including statistical analysis and web site development. You are not individually identified, however we reserve the right to use or disclose this information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with our websites, or where we are otherwise required or authorised by law to do so.
We may at some point also use similar data collection devices on the Subway® app.
Please contact us (using the contact details at the end of this policy) if you have any concerns or complaints about the manner in which we have collected or handled your personal information. We will inquire into your complaint and respond to you in writing within 30 days. If you are not satisfied with our response, you can contact us to discuss your concerns or lodge a complaint with the Australian Information Commissioner (www.oaic.gov.au).
Contact details and additional information