It is important for you to know how we collect, store and use the personal data that you give to us. The Privacy Notice explains how we use personal data to run our website and mobile apps, show you relevant ads and serve you over the phone, by delivery and in our stores. It also explains the rights you have over your personal data – to opt-out of marketing, to ask us for a copy of your data, to object to our use of it, and, occasionally, to ask us to delete it.
SCOPE OF THIS NOTICE
We're registered under the name Subs at Hougang Mall Private Limited, but you probably know us as Subway Delivery or Subdelivery. We are franchisees of 5 Subway outlets at Harbourfront Centre, VivoCity, Hougang Mall, Shaw Tower and ITE College Central. To keep things simple, in this Notice we call ourselves "we", "us" or "Subway Delivery". We are responsible (the data controller in technical lingo) for our website, mobile app, any newsletters and marketing you've signed up for, and some Subway stores in Singapore, which we own and operate. This Notice describes how we use your data to do this.
Not our franchisees. Other stores are run by franchisees, who are independent business owners and also data controllers (yep, technical terms again). As a result, each franchisee is responsible for its own data protection compliance. If you would like to talk to any of the franchisees about their privacy practices, please contact that them directly.
WHAT DATA DO WE COLLECT AND HOW DO WE USE IT?
To serve you sandwiches and other delicious menu items. When you place an order with us, whether on our website, by mobile app, over the phone or at one of our stores, we collect the data we need in order to process your order. It shouldn't surprise you that we'll ask for contact details, payment details and delivery location as needed to get your food to your doorstep.
We also manage delivery and collection on behalf of other franchisees. So, if you place an order online and the closest Subway location is operated by one of our fellow franchisees, we'll automatically relay with them so they can serve you.
To run and improve our website and mobile app. We use your data to operate and improve your experience on our website and mobile app.
For some of the features on our website and mobile app to work, we need to remember you. For example, when you're browsing our menu to order, we need to remember what you've already selected so that we don't just give you the last item you picked. As this is an inherent part of what you ask us to do when you order online, we don't ask your consent.
If you use our 'find my nearest Subway' feature, you can agree to share your location so that we can help you find the most convenient Subway location for you.
We also keep track of visitors to our website and mobile app to help us understand how they use the services so we can make them work smoothly. For example, we keep track of which pages are visited most, how long visitors spend on our site, what websites they visit before and after ours, and where our visitors come from.
We're able to do this by using cookies and other technical information your device automatically sends to us. Except for the uses that are inherent to the service, we ask your consent to collect this information.
WiFi and CCTV in our stores. We provide WiFi services in some stores. If you use our WiFi, we obtain information about you connection and device, such as the type of phone you use and your IP address, which we use for our legitimate interests of better understanding our customers. If you consent, we also receive your email address to send you promotional material. We collect email, mobile number, first name, surname and postal code from you and we use it for data analysis.
We also use CCTV in stores to protect our facilities, assets and personnel, and to investigate and prevent any type of incident, like theft or vandalism, accidents, fires, floods and other emergency situations. We balance your privacy rights against our interests by restricting access to the footage and placing cameras in prominent locations.
From social media. If you interact with our Facebook page, Twitter page, Instagram, or other social media presence, we use the information you provide to respond to questions or comments you leave us. We also use these social media services to show you advertising and special offers via social media, which, in some cases, will be targeted to you based on your interests and online browsing (including our website).
For marketing. We use data you give us to promote our delicious recipes and let you know about special offers. We collect your email address and other contact details when you create an account or sign up for newsletters, competitions and other promotional events so we can send you promotions and other marketing by email, SMS or by push notifications from our mobile app. We always ask your consent to receive our promotional material and give you the chance to unsubscribe.
We also store information about your preferences, like whether you've decided to opt-in to marketing emails, what types of products you seem to be interested in and how often you open the emails we send to further our interest in providing you the most relevant advertising.
Responding to enquiries. If you contact us for any reason, we will use the data you provide us to respond to your question. We see good customer service as a necessary part of the Subway experience.
We also want to learn from your feedback so that we can keep getting better. We use information for these legitimate business purposes, provided that we don't do this in a way that infringes on your data protection rights.
For legal and standard business reasons. Okay, here comes the legal jargon. We've lumped it all into one section because most of this only happens occasionally or in exceptional circumstances.
Where the law requires it or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use personal data in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
We also use personal data for safety and security, to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of our policies.
WHO SUBDELIVERY.COM.SG SHARE MY INFORMATION WITH?
Your personal data will be shared with companies providing services under contract to us for all the reasons described above, such as payment processing providers (e.g. WiredCard), data analysts and online advertisers (Google) who help to give us an insight into how we can better serve you and all of our other customers, professional advisors, and information technology providers.
Your personal data will be processed in or accessed from Singapore by some of the third parties to whom we share your personal data. Where we transfer personal data to countries that do not have equivalent data protection laws, we rely on European Commission-approved contracts, the EU-U.S. Privacy Shield and/or Binding Corporate Rules to keep your data safe. We rely on the EU-U.S. Privacy Shield Framework to transfer your personal data. For further information, please contact us as described in the Contact Us section below.
HOW CAN I STOP RECEIVING NOTICES ABOUT FUTURE OFFERS?
If you no longer want to receive communications from us, please inform us by using the unsubscribe link inside the email or SMS or in the Contact Us section on the website.
WHAT OTHER RIGHTS DO I HAVE?
You have the right to ask us for a copy of your personal data; to correct, delete or
restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement or compelling interest).
Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to us processing your data, this will not affect any processing which has already taken place at that time.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to the data protection authority in the country you reside, where you work, where you think the alleged breach is located.
HOW LONG DO YOU KEEP MY DATA FOR?
We will retain your personal data only for as long as we need it for our legitimate interest in accordance with applicable law, after such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible. Below, we describe how long we keep it:
- Marketing information: If you have elected to receive marketing from us, we will retain information about your marketing preferences for three years from the date that you last express interest in our products and services, such as when you last open an email from us. We will retain information derived from cookies and other tracking technologies for 13 months from the date such information was created.
- In-store purchases and online orders: We retain individual records about
purchases in our stores for six years after the purchase.
- Customer service: We retain records from any interactions you have with us or our customer service representatives for 6 years from when you last interact with us. If the information you provided us relates to health and safety, we may retain it for longer as required by law.
- Mobile app: We retain information we collect from your use of our mobile app for three years from when you disable your account. If you stop using the app but do not disable your account, we will disable it for you after four years from the last time you sign on.
HOW TO CONTACT US
Subs at Hougang Mall Pte. Ltd. (Licensee of Subway)
195 Pearl’s Hill Terrace
Attention: Data Protection Officer