Independent Purchasing Cooperative, Inc.
9200 South Dadeland Boulevard, Suite 800
Miami, Florida 33156
Technical Support: email@example.com
Independent Purchasing Cooperative, Inc. (“IPC”) is the host of and manages www.ipcoop.com and www.mysubwaycareer.com [PH1] (the “Websites”). IPC is an independent non-profit purchasing cooperative which is owned by and provides services to SUBWAY® Franchisees around the world (the “SUBWAY® Franchisees”).
IPC’s privacy practices are consistent with U.S. Department of Commerce Privacy Shield requirements regarding the collection, storage, use, and transfer of personal information from the European Economic Area, and it is Self-Certified under the Privacy Shield Framework.
B. Consent to Share and Disclose Information. By submitting Personal Information to IPC, and or/by accessing and using the Websites, you expressly consent to IPC sharing your Personal Information as follows:
IPC shares Personal Information with the following SUBWAY®-related entities and third-party agents or service providers who perform functions on our behalf:
(1) Value Pay Services LLC and other members of the IPC Group;
(2) SUBWAY® international purchasing cooperatives that are owned by SUBWAY® Franchisees and which provide services to the SUBWAY® Franchisees (the “Co-op Group”);
(3) the franchisor of the SUBWAY® line of restaurants Doctor’s Associates Inc. (“DAI”), and Franchise World Headquarters LLC (“FWH”), which provides core business-related services to DAI (the “SUBWAY® Group”); and
(4) SUBWAY® Group advertising entities that are members of the Subway Franchisee Advertising Fund Trust (the “FAF Group”).
All of these entities are “Third Parties”.
In addition, IPC may also share Personal Information, with companies that provide support services to it, such as credit card processors, mailing houses, web hosts, technical support providers, fulfilment centers, or other service providers, as well as companies involved in enforcing or investigating transactions or business operations, because these companies may need information about you in order to perform their functions. IPC limits the use of information shared with these companies to the purpose for which IPC hired them, but IPC does not control these companies. These companies are “Service Providers”. In this policy, both Service Providers and Third Parties are “Recipients”.
C. Consent to International Data Transfers. IPC and the Recipients are multi-national entities with operations throughout the world. In order for those entities to be able to provide you with suitable goods, services, and promotions, you expressly consent to your Personal Information being transferred and disclosed internationally, including within and outside the European Union. Some of these jurisdictions may have laws that provide less protection to your Personal Information than you receive under the laws in our own jurisdiction. IPC will ensure that any transfer or disclosure of Personal Information to or within such jurisdictions is in compliance with applicable law.
D. Consent to Electronic Notice If There is a Security Breach. If IPC or a Recipient is required to or wishes to provide notice of unauthorized access of their data security systems or unauthorized or unlawful access to or processing of your Personal Information, you agree that IPC and/or the Recipient may do so by posting notice on the Websites or sending notice to any email address which IPC or the Recipient has for you.
A. Personal Information. The term “Personal Information,” means any information concerning an identified or identifiable individual.
B. Sensitive Personal Information. The term “Sensitive Personal Information,” includes, but is not limited to, information revealing racial or ethnic origin, political opinions, religious or philosophical belief, trade union membership, sexual orientation, disabilities, health and veteran status.
IPC collects and uses your Personal Information in a fair and non-intrusive manner, as set forth in this section.
B. Other Details Relating to Website Use.
These cookies collect information in an anonymous form including the number of visitors to the site, how visitors reached the site and the pages visitors have visited.
BIGipServer and TS01
These cookies enable us to balance the workload by, for example, recording which server a user’s browsing session has been allocated to ensure they only deal with a single server for the duration of their session.
ASP.NET Session ID
These cookies help us recognize a visitor’s language preference.
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 disable all Cookies, you can adjust your internet browser settings to accomplish that. Please note that by disabling Cookies, you may not have access to some features available on the Websites.
C. Prospective and Actual SUBWAY® Franchisees. IPC collects and uses Personal Information from prospective and actual SUBWAY® Franchisees in order to provide services to them. IPC may collect this information from the SUBWAY® Franchisees directly or IPC may receive it from the Co-op Group, the SUBWAY® Group, the FAF Group, or other sources. IPC may use a prospective or actual SUBWAY® Franchisee’s Personal Information to respond to incoming service and support requests from such Franchisee, to communicate with such Franchisee regarding such Franchisee’s account(s), to calculate, determine, and distribute such Franchisee’s patronage dividend check, to collect Franchisee feedback, to conduct Franchisee satisfaction surveys, to offer promotions to such Franchisee, and to send other service informational mailings. IPC may also provide a SUBWAY® Franchisee’s Personal Information to a courier or freight forwarder in order to fulfil any order placed by such Franchisee.
D. Prospective SUBWAY® Restaurant Employees. IPC collects and uses Personal Information from prospective SUBWAY® Restaurant employees for the purpose of enabling them to be considered for employment at SUBWAY® Restaurants of their choosing. This information includes name, address, home or mobile telephone number, email address, SSN/I.N., employment history, other employment-related information, and personal references. IPC shares this information with SUBWAY® Franchisees selected by the user for the purpose of enabling the user to be considered for employment at SUBWAY® Restaurants. IPC may also share this information with third party service providers, such as credit agencies, in order to perform background checks on the user in connection with his/her application for employment at SUBWAY® Restaurants.
E. Customers of SUBWAY® Restaurants. IPC collects and uses Personal Information from SUBWAY® Restaurant customers in order to provide services to such customers. Personal Information collected from SUBWAY® Restaurant customers includes SUBWAY® Card and PIN numbers, and credit card information (for purchases of goods and services), products and services offered and purchased, enquiries and feedback.
A. Storage, Security, and Integrity of Personal Information. IPC uses commercially reasonable efforts to ensure that your Personal Information is safeguarded against loss, misuse, unauthorized access, disclosure, alteration, and destruction. IPC will endeavour to protect your Personal Information by using technical and organizational security measures appropriate to the sensitivity of the information in its control. These measures include safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, modification, and destruction.
The IPC-hosted Websites utilize a variety of different security measures designed to protect Personal Information by users both inside and outside of IPC, including the use of encryption mechanisms, such as Secure Socket Layers or SSLs, password protection, and other security measures to help prevent unauthorized access to your Personal Information.
IPC also takes commercially reasonable steps to ensure that Personal Information is relevant for the purposes for which it is to be used, and is accurate for its intended use.
C. Retention of Personal Information. IPC and the Recipients will retain your Personal Information only for as long as necessary to fulfil the purpose(s) for which it was collected and to comply with applicable laws and regulations. Your consent to IPC’s and the Recipients’ use of your Personal Information for such purposes(s) remains valid after termination of IPC’s relationship with you.
IPC will not knowingly allow anyone under thirteen (13) years of age to provide IPC with any Personal Information. Children under thirteen (13) years of age are required to obtain the express permission of a parent or guardian before submitting any Personal Information about themselves to the Websites. If a child under thirteen (13) years of age has provided IPC with Personal Information without the consent of a parent or guardian, the parent or guardian of that child should contact IPC’s Privacy Officer at firstname.lastname@example.org. IPC will use commercially reasonable efforts to promptly delete such child’s Personal Information from its servers.
Under California law, California residents can now ask companies with whom they have an established business relationship to provide certain information about such companies’ sharing of personal information with third parties for direct marketing purposes during the past year.
IPC’s policy is to share your Personal Information for direct marketing purposes only with your informed consent. With your consent, from time to time, IPC may share your Personal Information with the Recipients for the purpose of marketing and/or promoting goods, services, and programs to you. If you previously provided IPC with such consent but no longer want your Personal Information to be shared, please contact the IPC Privacy Officer at as set out in Section XII below and request a change in your preference and/or opt-out of communications without charge.
IPCs privacy practices are consistent with U.S. Department of Commerce Privacy Shield requirements regarding collection, storage, use, and transfer of personal information from the European Economic Area, and it is certified under the Privacy Shield Framework, for more information please see our Privacy Shield Statement and/or our registration details https://www.privacyshield.gov/list.
Canada has enacted federal privacy legislation, the Personal Information Protection and Electronic Documents Act (“PIPEDA”), which incorporates ten (10) “Fair Information Principles” regarding your Personal Information. IPC adheres to these Fair Information Principles for Personal Information collected and/or transferred from Canada, which are as follows:
If you have any questions or complaints about IPC’s privacy practices, or you wish to access, correct, or delete your Personal Information, please contact the IPC Privacy Officer. The IPC Privacy Officer can be reached by mail, telephone, facsimile, or email, as follows:
IPC Privacy Officer
Independent Purchasing Cooperative, Inc.
9200 South Dadeland Boulevard, Suite 800
Miami, FL 33156
Telephone: (888) 445-9239
Facsimile: (305) 670-4465
The IPC Privacy Officer will endeavour to investigate and attempt to resolve any complaints within 45 days.
Reserved for future use.
Revised October 25, 2016