Your privacy is important to us. So we’ve developed a Privacy Statement that describes how we collect, use, disclose, transfer, and store your information. It will also tell you about your rights with regard to your personal data.

1. ABOUT THIS STATEMENT

What this statement applies to.  This Privacy Statement applies to the personal information that Wingside Foods collects when you interact with the Wingside® brand online and offline.  This includes information collected through our websites, WiFi services or similar technology provided in Wingside® restaurants, branded pages on third party platforms (i.e. social networking services), mobile applications, and through our direct marketing campaigns or other communications, as well as, when you purchase our products, subscribe to our news and offers, enter into one of our promotions or contact customer support (collectively, “Wingside Services”).

What this statement does not apply to.  This statement does not apply to Wingside Services that show a different privacy statement. There may also be times we have a link to third party websites.  If you choose to visit those websites, we are not responsible for the privacy practices or the content of those websites.  We encourage you to review the privacy policies of those websites before submitting your personal information.  Some third parties may choose to share information about their users with us; that sharing is governed by that company’s privacy policy and not this Privacy Statement. 

Changes to this statement.  If we make a change to this statement, we will make previous versions available upon request so that you can see when changes occurred and what they are.  If we make any material changes to this statement, we will notify you by means of a notice on this site or by an email (sent to the email address specified in your account).  Where we are required by applicable data protection laws, we will also seek your consent to any material changes that affect how we use your personal information.  We encourage you to periodically review this page for the latest information on our privacy practices.

2. PERSONAL INFORMATION WE COLLECT

The personal information we collect falls into three categories: (a) information you provide us directly; (b) information we collect through automated methods; and (c) information we collect from third parties.

Information You Provide Directly

When you use Wingside Services, we may ask you to provide certain personal information to obtain our products or use our services.  The personal information we collect from you depends on the nature of your interaction with us or the Wingside Services you use, but may include the following:

• Contact Information.  We may collect personal and/or business contact information including your first name, last name, mailing address, telephone number, fax number, email address, and other similar data.

• Payment Information.  If you make a purchase online, you will be required to provide a credit/debit card number and related financial information (such as expiration date, security code and billing address), or other payment, depending on the form of payment you choose.

• Account Information.  We collect information such as your username and password when you create an account, access our online services, or buy our products.  Account information may also include how you purchased or signed up for Wingside Services, your transactions, billing and support history the Wingside Services you use and anything else related to the account you create.

• Usage Data.  This is the personal data we collect about you when you are using Subway Services, which may include information about the date and time of your logins and details of your use of third party applications and advertising you receive.

• Marketing and Communications.  We may also collect your preferences in receiving marketing from us and our third parties.

• Security Credentials.  We collect user IDs, passwords, email, and similar security information required for authentication and access to your Subway® accounts.

• Information through Social Media.  You may also be given the option to link to your Facebook or other social media accounts through Wingside Services.  Your use of these features may result in the collection or sharing of information about you, depending on the feature.  For example, these Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly.  They may also allow third-party social media services to provide us information about you, including your name, email address, and other contact information.  The information we receive is dependent upon your privacy settings with the social network.  We encourage you to review the privacy policies and settings on the social media sites you use to make sure you understand the information that is collected, used, and shared by those sites.

• Customer Service, Surveys & Promotions.  There may be times you provide us additional personal information when you interact online or by phone or mail with our customer support channels; when you participate in our customer surveys or promotions; or to facilitate delivery of Wingside Services or to help us respond to your inquiries.  Types of additional personal information may include voice recordings, photographs and videos.

• Information You Provide about a Third Party.  You may decide to provide us with another person’s information (such as their name, email, address or phone number) so that we may recommend or send products or services to that person.  Local law may require you to get the consent of that person to provide their information to the Wingside Group.  We may in turn use the information you provide in accordance with this Privacy Statement.

• If you fail to provide your personal information.  Where we need to collect your personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, in order to provide you with our products or services).  In this case, we may have to cancel the contract and notify you accordingly.

Information Collected Automatically

Whenever you visit or interact with Wingside Services as well as any third party advertisers and/or service providers, we may use a variety of technologies that automatically or passively collects information about your online activity.  This information may be collected in the following ways:

• Device & Technical Data.  We collect technical information when you visit our websites or use our mobile applications or services.  This includes information such as you Internet Protocol (IP) address, your login data, the type of mobile device you use, your device operating system and browser type, time zone setting and location, language, a unique device identifier, the address of a referring website, the path you take through our websites, and other information about your session on our websites.

• Cookies and Other Technologies.  We and our third party service providers use technologies such as cookies, web beacons, unique advertising identifiers, and mobile device identifiers to collect information about the use of our websites and mobile services.  This includes, for example, information from public databases or data aggregators that may include your demographic information, media consumption, previous purchases, shopping habits, loyalty program information or lifestyle preferences.  For more information, including the types of cookies found on Wingside® websites and how to control cookies, please read Wingside Foods Cookie Policy and the “Targeted Advertising” section below.

• Geolocation Data.  We may collect information about your location when your device is set to provide location information. To assist us in providing proximity based marketing and other location based services we utilize our Service Provider Google’s Maps API per Google’s Terms of Service which you consent to. For most mobile devices and computer systems, you are able to withdraw your permission for us to collect this information by using your browser or device settings. To withdraw your Google Maps API permission setting please follow the procedures in Google’s Terms of Service.  If you have any questions about how to prevent us from collecting exact information about your location, we recommend you contact your mobile-device provider, the device manufacturer, or your web-browser provider.  Some online services and in-restaurant technology may not work properly without information about your location.

Information Received from Third Parties

We may collect information about you from other companies and organizations, including public databases, social media platforms, our third party marketing partners or various independent purchasing organizations established for the benefit of Wingside®.

We may also collect information that is publically available.  For example, we may collect public information about your when you interact with us through social media.  By collecting additional information about you, we can correct inaccurate information, enhance the security of your transactions, and give you product recommendations and special offers that are more likely to interest you.

Combined Information

We may combine the information we receive about you, including information you provide directly to us and information we automatically collect through Wingside Services, as well as information collected across other computers or devices that you may use, from other online or offline sources, and from third parties.  If we combine your personal information and non-personal information, we will treat the combined information as personal information in accordance with this Privacy Statement.

Anonymous and Aggregated Information

Anonymized and aggregated information does not identify a specific person and is not personal information.  We use this type of information for a variety of functions, including measuring users’ interest in and use of Wingside Services, conducting internal analysis, data analytics and research.  We may also share anonymized or aggregated information with third parties for our or their purposes, but none of this information can be used to identify you or determine anything else personal about you.

3. LAWFUL BASIS FOR HOW WE USE YOUR PERSONAL INFORMATION

We may use the information we collect in the following ways.

To provide our services and contract with you:

• carry out your requests, fulfill orders, and process payments for our products and services;
• communicate with you about your orders, purchases or accounts with us, including handling any requests, questions or comments you may have;
• provide online services to you, which includes our websites and/or mobile applications; and
• provide customer support, including processing any concerns about our services.

To market to you, improve our services, and the following legitimate business interests:

• tell you about our products and services, competitions, offers, promotions or special events that we believe may interest you when you are part of a Wingside® Wing Club program;
• personalize your experience in our restaurants and on our online services;
• verify your identity or communicate with you about your activities with respect to Wingside Services;
• manage our business, including developing new products and services, conducting consumer and operations research, and assessing the effectiveness of our sales, marketing and advertising;
• use analytics and profiling technology to personalize your experience; deliver content (including advertising) tailored to your interests and let you know how to use Subway Services (see “TARGETED ADVERTISING” below for more information);
• link or combine with information we receive from others to help understand your needs, use for interest-based or targeted advertising or re-targeting on your computers or other devices;
• ensure the security of our networks and systems, including to help diagnose technical and service issues, troubleshoot issues, bugs or defects related to your account or activities;

To comply with applicable law:

• protect against fraud and other crime, claims and liabilities;
• comply with legal obligations and our policies;
• establish or defend a legal claim; and
• monitor and report compliance issues.

For the public interest:

• we may use your personal information if we reasonably believe that there is an inherent security or product issue that we must either disclose to you or the authorities and the use of your information will prevent or potentially minimize the danger to you or others.

With your consent (where required by applicable law), we may use the information we collect for the following purposes:

• to send you emails or text messages about the products and services, competitions, offers, promotions or special events we believe may interest you;
• to send you emails or text messages about the products and services of our business partners;
• provide location-based services;
• use cookies and similar technologies.

We may use the information we collect about you in other ways, which we will tell you about at the time we collect it and for which we will seek your consent if required by law.

4. SHARING YOUR INFORMATION

We do not sell any of your personal information including your name, address, email address or credit card information to any third party.

Legal Disclosures.  We may disclose your information if we believe that the disclosure is required by law, a subpoena or other legal process, if we believe that the disclosure is necessary to enforce our agreements or policies, or if we believe that the disclosure will help us protect the rights, property or safety of  Wingside Foods or our customers or partners.

When You Consent.  We may share your information with other companies if you give us permission or direct us to share the information.

Wingside Foods remains responsible for the personal information that we share with third parties for processing on our behalf in connection with the operation of our business, and we remain liable under this privacy statement if our third parties process your personal information in a manner inconsistent with the Privacy Shield Principles, unless Wingside Foods proves that it is not responsible for the matter giving rise to the damage.

5. TARGETED ADVERTISING

We use third parties’ analytics and tracking tools, such as Google Analytics, Adobe Marketing Cloud, Facebook Customer Audience and others, to help us track, segment and analyze usage of Wingside Services, and to help us or those third parties serve more targeted advertising to you on Wingside Services and across the Internet.  Those tools may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or other technologies to collect and store non-personal information.

At our request, these third parties collect, and share with us, usage information about visits to our websites, measure and research the effectiveness of our advertisements, track page usage and paths followed during visits through our websites, help us target our Internet banner advertisements on our websites and on other sites, and track use of our Internet banner advertisements and other links from our marketing partners’ sites to our websites. They may also combine information they collect from your interaction with Wingside Services with information they collect from other sources.

We do not have access to, or control over, these third parties’ use of cookies or other tracking technologies.  To learn more about your advertising choices in relation to the collection and use of your information, please see the Subway Group’s Cookie Policy.  You can also visit the Adobe website for more information on cross-device tracking and/or to unlink your devices.

6. OPTING OUT

Cookies and Other Technologies

To learn how to opt-out of these services, please see Wingside’s Cookie Policy.

Marketing Communications

If you have agreed to receive marketing communications from us, you can later opt out by following the opt-out instructions in the marketing communications we send you or you can also contact us by using the contact details provided under the “How to Contact Us” section above.  Depending on the Wingside Services you use, you may also have the ability to change your communication preferences in the profile section of the online services that you use or in your device settings.  Where our mobile applications allow for the delivery of “push notifications”, you can also opt out of receiving these notifications by going into your mobile phone settings and toggling the “Notifications” switch within our mobile application to “off”.

If you do opt out of receiving marketing communications from us, we may still send communications to you about your transactions, any accounts you have with us, and any contests, competitions, prize draws or sweepstakes you have entered.  Opting out of one form of communication does not mean you’ve opted out of other forms as well.  For example, if you opt out of receiving marketing emails, you may still receive marketing text messages if you’ve opted in to receiving them.

Loyalty Program

Nigeria.  Participation in the Wingside® Wing Club program is voluntary; you may end your participation in the Wingside® Wing Club program by contacting us, in which case any data gathered through the program will be deleted except what we are legally required to keep.  Please note that data originating through other non-program interactions may remain with us.

App Tracking Preferences

Opt Out By Deletion. You may opt out of all information collected via our app(s) by uninstalling it.  You may use the standard uninstall, application, and data management processes available through your mobile device.  Once you have uninstalled the app, all the information that is stored in the app is deleted, including any preferences you previously set for location permissions and whether you have allowed us to send you push notifications.  Once the app is uninstalled and preferences are deleted, push notifications from the app will stop.  You may also refrain from using application features that collect specific types of data.

Location Opt Out.You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings.  Please note your location may be derived from your WiFi, Bluetooth, and other device settings.  See your device settings for more information.

7. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under applicable data protection laws in relation to your personal information.  You have the right to:

Access Your Personal Information.  You can request access to your personal information.  This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.  You may reasonably access your personal information by contacting the Wingside Privacy Office regarding the accuracy of your personal information. Please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information we have about you.

Your right to access the personal information that we hold about you is not absolute.  There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information we hold about you.  In addition, the personal information may have been destroyed, erased or made anonymous.  If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Modify or Update Your Personal Information.  We aim to ensure that personal information in our possession is accurate, current and complete.  If you believe that the personal information about you is incorrect, incomplete or outdated, you may request the revision or correction of that information.  We will use reasonable efforts to revise it and, if necessary, to use reasonable efforts to inform agents, service providers or other third parties, which were provided with inaccurate information, so records in their possession may also be corrected or updated.  However, we reserve the right not to change any personal information we consider accurate.

Erasure of Your Personal Information.  You may ask us to delete or remove personal information where there is no legal reason for us to continue using it.  You also have the right to ask us to delete or remove your personal information where you successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with law.  Please note that we may not always be able to comply with your request of erasure for specific legal reasons which we will notify you, if applicable, at the time of your request.

Object to Processing Your Personal Information. You may have the right to object to us processing your information in certain circumstances.  This right applies when we are processing your personal information based on a legitimate interest (or those of a third party), which you may challenge if you feel it impacts your fundamental rights and freedoms.  You also have the right to object where we are processing your personal information for direct marketing purposes.  However, in some cases, we may demonstrate that we have compelling legitimate ground to process your information or legal obligations which override your rights and freedoms.

Data Portability.  You may request the transfer of your personal information to you or a third party.  We will provide to you, or a third party you have chosen, your information in a structured, commonly used, machine-readable format.  Please note this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Please note that if you opt out of receiving marketing communications from us, we may still send communications to you about your transactions, any accounts you have with us, and any contests, competitions, prize draws or giveaways you have entered.  Opting out of one form of communication does not mean you’ve opted out of other forms as well.  For example, if you opt out of receiving marketing emails, you may still receive marketing text messages if you’ve opted in to receiving them.

If you wish to exercise any of the rights set above, please contact us.  We will need you to provide specific information to help us confirm your identify.  This is a security measure to help ensure that your personal information is not disclosed to someone that does not have the right to receive it.

8. HOW LONG WE KEEP YOUR INFORMATION

To the extent permitted by applicable law, we retain your personal information as long as (1) it is needed for the purposes for which we obtained it and in accordance with this Privacy Statement or (2) we have another lawful basis, stated in this Privacy Statement or at the point of collection, for retaining that information beyond the period for which it is necessary to serve the original purpose for obtaining the personal information.  If the lawful basis for processing that data is based solely on consent, we will delete the personal information if that consent is revoked.

9. CHILDREN’S PRIVACY

Our services are not intended for use by children under the age of 13 or equivalent minimum age depending on the jurisdiction.

If you are a parent or legal guardian and believe we may have collected information about your child, please contact us.

If we learn that we have inadvertently collected the personal information of a child under 13, or equivalent minimum age depending on the jurisdiction, we will take steps to delete the information as soon as possible.

10. OUR SECURITY

We recognize the importance of maintaining the security of your personal information.  We protect your information using security measures, including physical, administrative, and technical safeguards to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of your information.

While we have employed security technologies and procedures to assist safeguarding your personal information, no system can be guaranteed to be 100% secure.  Please note that we cannot ensure or warrant the security of any information you transmit to us.  You use Wingside Services and provide us with your information at your own risk.

Thank you for reading our Privacy Statement.  If you have any questions about this Statement or about how we process personal information, please contact us by using the contact details provided under  “How to Contact Us”, which is located at the top of this document.

If we are unable to resolve your concerns, you have the right to contact a data privacy supervisory authority in the country where you live or work, or where you consider that the data protection rules have been breached or seek a remedy through the courts.

Strictly Necessary:  These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

A preference cookie is required to maintain a record of your Do Not Track preferences, so that we may respect them for future visits.

Functionality (such as language preference):  These cookies help us customize our Website content based on a user’s preferences. They remember the user’s choices, their language, the country pages visited, and any changes the user makes to text size or other parts of our Website pages. The information these cookies collect may be anonymized and they cannot track browsing activity on other websites.

Performance cookies (such as those used for Google Analytics):  These cookies collect information on how users use our Website, in order to help us fix technical issues or errors, and highlight areas such as navigation where we can improve our Website. For example, Google Analytics uses cookie identifiers to track the number of visitors to the Website, providing us with the volumes and sources of web page traffic.  This allows us to analyze web traffic patterns and run tests to optimize web pages and visits against key metrics.

The information collected by Google Analytics itself is anonymous, but if you respond to a marketing email, then a random ID is generated for Google Analytics which we can use along with your email address to manually identify you from other information we already hold in your customer profile. We may then use this information to generate potential sales leads or advertising.

You can find more information about how Google Analytics safeguards your data at:
https://www.google.com/intl/en/analytics/privacyoverview.html.

Interest-Based Advertising / Targeting (such as those used by advertising platforms we may use, such as Facebook or Twitter):  These cookies may be set through our site by our advertising partners. They can be used and shared by those companies to build a profile of your interests and show you relevant adverts on other sites. This is based on uniquely identifying your browser and internet device. The website or domain owner can then use the information to try and draw certain conclusions about you, such as, what you might be interested in.  For example:  after reviewing the information that was sent to the website or domain owner, they might conclude that you are a football fan, a health and fitness enthusiasts, or a person who loves to travel.  If you do not allow these cookies, you will experience less targeted advertising.

For more information about digital advertising visit AdChoices at: https://www.youradchoices.com.

Social Media:  We allow users to share our Website on social media such as Facebook and Twitter through the use of their cookies. These cookies are not within our control. Please refer to the respective privacy policies of the social media provider for how their cookies work.

To find out more about cookies and your privacy on the web, visit the online resource All About Cookies.

How long will cookies stay on my device?

The length of time a cookie will stay on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted.

HOW TO OPT OUT

First Party Tracking.  To opt out of first party tracking (that is, tracking with cookies placed by Subway) on our websites, you may be able to opt out by adjusting the appropriate settings in your browser.  Each browser is different, but many common browsers (Internet Explorer, Chrome, Firefox, and Safari) have preferences or options that may be adjusted to allow you to either accept or reject cookies and certain other technologies before they are set or installed or allow you to remove or reject the use or installation of certain technologies altogether.  If you want to learn the correct way to modify your browser settings, please use the Help menu in your browser.

Third Party Tracking.  To opt out of third party tracking (that is, tracking with cookies placed by persons other than Subway), you can:

• Click here to visit the Network Advertising Initiative site or click here to visit the Digital Advertising Alliance to set preferences and opt out of third party targeting programs
• Click here to opt out of the Google Ad Network (DoubleClick,  AdSense)
• Click here to opt out of Google Analytics
• Click here to opt out of Adobe Site Services

To learn more about advertisers’ use of cookies and how to opt-out the following links may be helpful to our visitors:

• European Interactive Digital Advertising Alliance (EU)
• Internet Advertising Bureau (US)
• Internet Advertising Bureau (EU)

Adobe Flash Player Technology.  We allow Adobe to set and enable special cookies that are necessary to deliver video content for Adobe Flash Player. You cannot remove Flash cookies simply by changing your browser settings. If you would like to limit the websites that can store information in Flash cookies on your device, you must visit the Adobe website: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

“Do Not Track” Technology.  Some newer web browsers have a “Do Not Track” preference that transmits a “Do Not Track” header to the websites you visit with information indicating that you do not want your activity to be tracked. However, we currently do not respond to browser “Do Not Track” signals.

Other helpful resources

Browser manufacturers provide help pages relating to cookie management in their products. Please see below for more information:

• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Android Browser
• Opera
• Opera Mobile

For other browsers, please consult the documentation that your browser manufacturer provides.