INDEPENDENT PURCHASING COMPANY (AUSTRALASIA) LTD PRIVACY POLICY

Independent Purchasing Company (Australasia) Limited (IPC Asia Pacific) and its subsidiaries operating outside of Australia (“we”, “our” or “us”) respect and are committed to protecting the personal information we each collect. IPC Asia Pacific is bound by the Australian Privacy Principles in the Privacy Act 1988 (Cth) (the Privacy Act) and its subsidiaries may be bound by applicable legislation in other jurisdictions. Where appropriate we will handle personal information relying on the related bodies corporate exemption and the employee exemption in the Privacy Act.

Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.

This Privacy Policy discloses how we collect, protect, use and share personal information. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.

This Privacy Policy applies to all personal information gathered by us, whether in writing, verbally or electronically, through any website operated by us.  It does not govern the privacy practices and procedures of our affiliates or independently owned and operated Subway® restaurants we encourage you to review their respective privacy policies which discloses each entity’s privacy practices and procedures.

By submitting personal information to us and/or by accessing and using our website, you agree to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any terms and conditions as permitted or required by law.


INFORMATION WE COLLECT 
All personal information is collected in a fair and non-intrusive manner, with your voluntary consent. 

We may collect and process the following personal information about you:

  • Information that you provide by filling in our Confirmation of IPC Asia Pacific Shareholder Details and Shareholder Register forms including your names, telephone and mobile telephone numbers and email addresses;
  • Details regarding the contracts and arrangements you have entered into with Suppliers and/or Distributors sourced by IPC  Asia Pacific;
  • Certain details regarding your franchise with Subway Systems Australia Pty Ltd (SSA);
  • Geolocation information (where you use Subway® location-based products);
  • Personally identifiable information including without limitation name (full name or first initial and last name), maiden name, nickname, email address, home address, home postal code, home telephone number, mobile telephone number, date of birth, photographic images and video or voice recording, financial information, and pre-employment related information (such as may be found on resumes, applications, background verification information, or in employment references).

If you contact us, we may keep a record of that correspondence.

IPC Asia Pacific’s subsidiaries may collect like information about you (including any Franchisees) in the countries in which they carry on business.

As Franchisees are Members of IPC Asia Pacific, the Corporations Act 2001 (Cth) requires us to collect the name and address of current Franchisees and to include that information in a register of Members. If you do not provide any of the information we need to establish and administer your membership you will not be able to become a Member.

We also collect personal information about individuals who are, or are employees of, our Suppliers and service providers. For these people we usually only collect name and business or work contact details.

Sensitive information is health information or information about an individual’s racial or ethnic origin, political opinions or memberships, religious or philosophical beliefs or affiliations, professional or trade memberships or associations, sexual orientation or practices or criminal record.  We will not collect your sensitive information without your express or implied consent.

 

COLLECTION OF PERSONAL INFORMATION REGARDING CHILDREN

Our website is not targeted towards children under 13.  If you are a child under 13 please, do not submit any personal information about yourself on this website without getting permission from your parent(s) or guardian(s) first.

Children’s privacy is very important to us.  We work closely with Subway® Franchise World Headquarters (FWH), whose servers are located in the United States, and which adheres to the United States Children's Online Privacy Protection Act (COPPA). We will not knowingly allow anyone under thirteen (13) years of age to provide us with any personal information about themselves (such as their names, e-mail address, and phone number) over the Internet. If a child under 13 has done so without the consent of a parent or legal guardian, we ask the parent or legal guardian of that child to contact our Privacy Officer immediately using the contact details below 

We will provide parents or legal guardians notice by e-mail of any material changes in the way we intend to collect, use, and/or share their child’s personal information.  If you would like to review any personal information that we have collected online from your child (if any), have the personal information deleted, and/or request that there be no further collection or use of your child's personal information, or if you have questions about our privacy practices, you may contact our Privacy Officer using the contact details below.

 

HOW WE COLLECT PERSONAL INFORMATION

Generally, we collect personal information directly from you, such as when you submit information to us either personally, by phone, electronically or in any other manner.  We may also collect your personal information when we provide a service to you.

From time to time, you may provide us, and we may collect from you, personal information of a third party.  You are responsible for the disclosure to us of such third party personal information and confirm that you have the right to provide that third party personal information to us.  Where you provide such third party personal information, it is also your responsibility to ensure that those persons are aware of this Privacy Policy, understand it and agree to accept it.

We also collect personal information through:

  • publicly available records and social networking and media sites;
  • our affiliates; 
  • third party service providers;
  • service companies; and
  • our business partners

We may combine information you have provided to us with information that we or others have collected about you.

You may use a referral feature (either on a web page, in an e-mail, from a banner ad or other communication) to inform a friend about one of our web pages or promotions. You are solely responsible for the disclosure to us of such third party personal information and confirm that you have the right to provide that third party personal information to us.  Where you provide such third party personal information, it is also your responsibility to ensure that those persons are aware of this Privacy Policy, understand it and agree to accept it.  


HOW WE STORE AND PROTECT YOUR PERSONAL INFORMATION

We regard the security of your personal information as a priority and implement a number of industry-standard physical and electronic practices to protect your personal information from misuse, interference and loss, and unauthorised access, modification or disclosure, including the use of encryption mechanisms (e.g., Secure Socket Layers or SSLs), password protection, and other security measures. We remind you, however, that the Internet is not a secure environment and although all care is taken, we cannot guarantee the security of information you provide to us via electronic means.

We take reasonable steps to destroy or permanently de-identify personal information when we no longer need it.

Phishing-Identity theft and the practice currently known as “phishing” are of great concern to us. Accordingly, safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, or government identifiers in a non-secure or unsolicited e-mail or telephone communication.

We take all reasonable steps to ensure that your personal information is accurate, up-to-date, complete, and relevant. 

If we are required to provide notice of a privacy breach, you agree that we may do so when required or voluntarily by posting notice on our website or sending notice to any email address we have for you, at our discretion. You agree that notice to you will count as notice to any other individual for whom you are acting and agree to provide the notice to any such individual.

 

DISCLOSURE AND USE OF YOUR INFORMATION

We do not sell personal information to third parties, and personal information is not accessible to anyone outside the specific function(s) and related purposes for which it is collected.  

We may disclose your personal information to:

  • SSA, affiliates, subsidiaries and third parties that are a party to a service agreement with SSA; 
  • Promotions and advertising entities;
  • consultants
  • service companies;
  • couriers and freight providers;
  • Franchise World Headquarters (FWH);
  • appropriate Subway® Group’s area Development Agents and Franchisees; 
  • third party service providers (including but not limited to credit card processors, mailing houses, web hosts, technical support providers, telecommunications carriers and carriage service providers, fulfillment centers, and enforcement and/or investigative entities; and
  • any regulatory or other body if required to do so by law.

We may use Google Analytics (or a similar tool) to help us better serve our customers through improved products, services, and revisions. 

We may use information held about Franchisees in the following ways:

  • To provide Franchisees with information, products or services requested from Us.
  • To carry out obligations arising from any contracts entered into between IPC Asia Pacific and its Franchisees.
  • To comply with our legal obligations.

We may also use Franchisee personal information, or permit selected third parties to use such personal information, to provide a Franchisee with information about goods and services which may be of interest unless the Franchisee asks us not to.

IPC Asia Pacific may share personal information with its subsidiaries and IPC Asia Pacific's subsidiaries may share information with IPC Asia Pacific.  All subsidiaries of IPC Asia Pacific handle personal information in accordance with this Privacy Policy which effectively provides the same level of protection as if they were bound by the Privacy Act. 

Where the privacy laws of any country in which an IPC Asia Pacific subsidiary operates require any action be taken in addition to the requirements of the Privacy Act, or are otherwise directly inconsistent with the requirements of the Privacy Act, the relevant IPC Asia Pacific subsidiary will comply with the requirements of such privacy laws.

We require our agents, affiliates and service providers to agree in writing to maintain the confidentiality and security of personal information they maintain on our behalf and not to use it for any purpose(s) other than the purpose and related purpose for which we collected it. We also require any third parties we retain to protect personal information disclosed by us in accordance with all applicable privacy requirements and the general privacy principles described in this Privacy Policy.

The personal information you provide to us is considered a company asset and may be disclosed and/or transferred 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 us or of any of our business assets or shares or a division thereof. 

We may also use your personal information:

  • to enforce our policies or contracts;
  • to collect amount owed to us;
  • for security purposes;
  • to protect users of our sites from fraudulent or abusive use;
  • during emergencies when safety is at risk; and
  • where permitted by law

 

OVERSEAS DISCLOSURE OF PERSONAL INFORMATION

We may disclose your personal information to our affiliates, advertising entities service companies, leasing affiliates and third party service providers in India, Indonesia, Taiwan, the United States, Singapore, New Zealand, China, South Korea, Philippines, Vietnam, Malaysia, Sri Lanka, Thailand and Hong Kong.

Some of these countries may not have the same or substantially similar privacy laws as those set out in the Australian Privacy Principles.  We may not require organisations in those countries to comply with similar privacy laws, and accordingly your personal information may not receive the same protections that it would in Australia.  By providing your personal information to us you consent to our disclosure of your personal information to organizations in those countries.  Please contact us if you do not consent to such disclosure, as we may not be able to provide certain services to you.

 

MARKETING AND YOUR RIGHTS

We will use and disclose your personal information to send direct marketing to you from us and third parties who provide services to us by a range of means, including by phone or email or in any other manner permitted by law.

The direct marketing may relate to: 

  • our products and services;
  • the products and services of our affiliates, Franchisees, service companies, business partners and Franchise World Headquarters (FWH);
  • the products and services of other parties; and
  • new developments we believe may be of interest to you.

You may opt-out of receiving this direct marketing through the unsubscribe function that will be made available to you with each direct marketing communication, or by contacting our privacy officer using the contact details below.

You have the right to ask us not to use your personal information for direct marketing purposes. If you do not want us to use your personal information, or to pass your personal information on to third parties so they can use it, to tell you about products and services which may be of interest to you then please tell us using the contact details below.

 

LINKS TO THIRD PARTIES

Our website may contain links to other websites for your convenience and information.  We do not control those websites or their privacy practices, which may differ from this Privacy Policy. We do not endorse or make any representations about third-party websites. The personal information you choose to give to unrelated third-parties is not covered by this Privacy Policy. Some third-parties may choose to share personal information with us; that sharing is governed by that third-party company’s privacy policy, not this Privacy Policy. Our Privacy Policy cannot and does not apply to third parties.

Use of third party social networking websites, such as, Twitter and Facebook, are governed by the privacy practices of those websites.  We do not capture or store your login information or any other personally identifiable information for such social networks. If you participate in any advertising or marketing promotions the information that you provide will be handled in accordance with the privacy policy specific to said promotion.

We may use third-party platforms including, but not limited to, Facebook, Twitter, and YouTube that are not exclusively operated or controlled by us or our affiliates.  The amount of personal information displayed when interacting with will depend on your privacy settings. 

Neither we nor any of our affiliates collects, maintains, discloses or shares any personal information about people who interact with the Subway® Group’s presence on those websites. 

Subway® Franchisees may have the opportunity to sponsor their own social networking accounts. Those accounts are governed by that Franchisee’s privacy policy, not this Privacy Policy. Our Privacy Policy cannot and does not apply to such Franchisee social networking accounts.

We encourage you to view your country’s Subway® privacy policy at www.subway.com. To view your country’s privacy policy please go to: http://www.subway.com/subwayroot/exploreourworld.aspx. At the top of the page, please click on CHANGE, which brings you the EXPLORE OUR WORLD page. To choose your Country click on the Country name, then go to the very bottom of the Country’s page and click the PRIVACY STATEMENT link to view the website privacy policy specific to your country.

 

COOKIES, INTERNET PROTOCOL (IP) ADDRESS, AGGREGATE INFORMATION

Cookies - We use data collection devices such as "cookies" on certain web pages to help analyze our web page flow and measure promotional effectiveness. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site and services.

A few important things you should know about cookies are that: 

  • we offer certain features that are available only through the use of cookies;
  • we use cookies to better your web experience;
  • most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session; and
  • you may encounter cookies from third parties on certain pages of the sites that we do not control, for example if you view a web page created by another user, there may be a cookie placed by that web page.​

Disabling/enabling cookies - You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our site if cookies are disabled.

Web Beacon - Also called a web bug or a pixel tag or a clear GIF. We use pixels tags or transparent GIF files to help manage our online advertising and promotions. 

With both cookie and tag technology, the information that we collect and share is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address.

Internet Protocol (IP) Address - We may use your IP address to help diagnose problems with our server, to administer our website(s) and to maintain contact with you as you navigate through the website(s). We do not link IP addresses to any personal information.

Aggregate Information – is used to measure the visitors’ interest in, and use of, various areas of our website(s) and the various programs that we administer.  Although we may share this aggregate information with third parties, none of this information will allow anyone to identify you, or to determine anything else personal about you.

 

INTEREST-BASED/ONLINE BEHAVIORAL ADVERTISING 

On some pages of our site we may allow third-party advertising partners to set web tracking tools to collect anonymous, non- personally identifiable information regarding your activities on those pages. We may also share such information we have collected with third-party advertising partners, who may use this information for purposes of delivering future targeted advertisements to you when you visit other (non-Subway®) sites within their networks. 

While you may in some cases be able to opt-out of such uses, we may still collect non-personally identifiable information regarding your site activities and use it for non-interest-based advertising purposes as described in this Privacy Policy. 

 

"DO NOT TRACK"

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, however we do not recognise or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. To find out more about "Do Not Track," you may wish to visit http://www.allaboutdnt.com.


ACCESS TO INFORMATION

The Privacy Act gives you the right to access most personal information held about you. Please contact the Privacy Officer using the contact details below to ask for access to your personal information or if you have a complaint concerning your information privacy. To protect your privacy, we will take all reasonable steps to help verify your identity before granting access or making any changes. 

At your request, we will provide you with a copy of any personal information which we hold about you, unless an exception under the Privacy Act 1988 applies. We may charge a fee for retrieving this information, in which case we will inform you of the fee and obtain your agreement to that fee before providing the information.

We will promptly acknowledge and investigate any complaint about the way we manage personal information.

CHANGES TO OUR PRIVACY POLICY

We may update this Privacy Policy occasionally.  If we do so, we will also revise the "Last reviewed" date below. If there are any material changes to this Privacy Policy we will notify you by means of a notice on our home page.  Any changes to this Privacy Policy are effective immediately after we posted them.

We encourage you to review this Privacy Policy periodically to be informed of how we protect your personal information and to be aware of any changes to it. Your continued use of the site or our services after the posting of any amended Privacy Policy will constitute your agreement to be bound by any such changes. This Privacy Policy is incorporated into any terms and conditions governing the various websites and any programs or services operated or managed by us. 


CONTACT US
If you would like more information about our approach to privacy, please contact IPC Asia Pacific's Privacy Officer by:

  • writing to PO Box 1028, North Sydney, NSW 2059 Australia
  • email to privacy@ipca.biz or 
  • calling +61 2 8908 7900​

Last reviewed: 17/11/17

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