We are committed to protecting the privacy of your personal information. This privacy policy explains how we collect, use, disclose and hold personal information and how to contact us if you have any queries about our management of your personal information.
Subcard NZ Ltd (NZBN 9429034906958) (we, us and our) operates the Subcard® loyalty, gift and online ordering program in New Zealand (Subcard® Program). Subcard NZ 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.
All personal information is collected in a fair and non-intrusive manner, with your voluntary consent. Subcard NZ Ltd respects the privacy of Subcard® and Subway® customers, and other visitors to our websites who may choose to provide personal information. We recognise 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.
The Subway Group. While we are working with the Subway Group to implement the Subcard® Program, the Subway Group is independent from Subcard NZ 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.
The Subway Group includes Subway IP LLC (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-NZ/Legal/PrivacyStatement-FWH
By using or accessing the website https://order.subway.com/en-nz, (Websites), the Subway® App and/or any of ourservices you are deemed to have agreed to be bound by this privacy policy. If you do not want your personal information to be collected, please do not submit it to us. Please note that if you elect not to provide certain personal information to us, we, and Subway®, may not be able to provide you with the services, products or information you require.
When you provide personal information to Subcard NZ about a third-party individual, you agree that you have that individual's permission to provide their personal information to Subcard NZ, for Subcard NZ's collection, storage, use and disclosure in accordance with this privacy policy.
This privacy policy is governed by New Zealand law and is subject to (and must be read in conjunction with) the Terms and Conditions on the https://order.subway.com/en-nz websites and the Subway® App.
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 https://order.subway.com/en-nz 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 may also keep a record of any information that you acquire from 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);
- directly from you or from third parties acting on your authority or who you authorise us to make contact with about you in the course of conducting customer due diligence;
- publicly available information searches as part of the provision of our products or services to you;
- from the agents and service providers that we may engage to assist us with fulfilling any of the purposes recorded in this policy;
- from third parties connected with the substance of the matter(s)/purposes(s) for which you have engaged us;
- 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;
- for verifying your identity, performing customer due diligence and for other administrative purposes;
- processing payments made to us by franchise owners;
- for our administrative purposes and internal record keeping;
- performing research and analysis;
- for complying with any legal requirements, including any applicable law or requirements of a regulator; and
- managing our relationships with Subway® franchisees 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.
Direct marketing
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® and its affiliates) your personal information so that we, Subway International BV 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, social media 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 https://order.subway.com/en-nz 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
In providing our products and services to you, or in carrying out any of the other functions mentioned in this privacy policy, we may also disclose your personal information to our contractors or agents, and other organisations including, but not limited to:
- Subway® entities, including Franchise Worldwide Headquarters, LLC and Subway International BV Ltd (who may use your information to facilitate and promote their products and services to you);
- our contracted service providers, including our information technology and loyalty program service providers and professional advisers;
- financial institutions for payment processing;
- identification verification and screening agencies (who may temporarily hold such information for the purposes of process audit and error checking);
- any document issuer, official record holder, credit bureau and authorised third parties’ data providers for the purposes of customer due diligence (who may retain a record of the fact that we or an intermediary has requested a data comparison);
- credit reporting agencies (who may retain the personal information we share with them on their databases for use in the provision of their credit reporting services); and
- regulatory and enforcement agencies.
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® franchisees 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 https://order.subway.com/en-nz
We note that no data transmission over the internet can be guaranteed as completely secure. Accordingly, we cannot warrant or guarantee the security of information transmitted from or to you.
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 website https://order.subway.com/en-nz
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.
Cookies
We use data collection devices such as "cookies" on certain web pages to help analyse our web page flow and measure promotional effectiveness. Cookies are pieces of information a website sends to an individual’s browser while they are viewing the website. Cookies allow the website to remember important information that will make your visit to the site more useful and allows a registered Subcard member to login. We use cookies to help improve your future visits. If you do not wish to receive a cookie or if you wish to set your browser to warn you each time a cookie is being sent, or if you wish to turn off all cookies, use the options on your browser to assist you. The Help option on your browser may assist you in changing your cookie preferences. Please note that by turning cookies off, you will not have access to many features available on our website.
We may at some point also use similar data collection devices on the Subway® app.
Children and Data Collection
We care about the safety of children. We will not knowingly allow anyone under 18 to provide us any personally identifying information unless the following steps have been complied with. Children under 18 years of age are required to obtain the express permission of a parent or guardian before submitting any personal information about themselves (such as their names, email addresses, and phone numbers) over the Internet, including by uploading this information into the Subway® App or Websites.
Complaints
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 Office of the Privacy Commissioner ( https://www.privacy.org.nz/).
Changes to this privacy policy
We may amend this privacy policy from time to time at our discretion. Amended versions will be posted at https://order.subway.com/en-nz
Contact details and additional information
If you would like more information about our approach to privacy, or if you wish to contact us regarding the information set out in this privacy policy, please contact us:
- By phone: 0800 782 273
- By email: subcardnz@ipcasiapacific.com
- By post: Director of Marketing & Commerce, IPC Asia Pacific, 3/65 Berry St, North Sydney, NSW 2060, Australia