Our mission is to help Subway® Franchisees be more profitable and competitive – today and for the future.

IPC Europe Privacy Policy & Confidentiality Notice


European Independent Purchasing Company Limited (trading as IPC Europe), a company whose members are comprised of Subway® Franchisees (‘Members’), recognises the importance of protecting information gathered from our Members. This Privacy Policy sets out, how in compliance with Directive 95/46/EC of the European Parliament (the ‘Directive’), and the UK’s Data Protection Act 1998 (the “Act”), IPC Europe collects, protects, uses and shares personal data (as defined under the Act and as described below) (‘Personal Data’).

Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.

By visiting and using this site (EXTRA) you are accepting and consenting to the practices described in this policy.

Data Controller
For the purpose of the Act, the data controller responsible for Personal Data collected and stored under this Privacy Policy is European Independent Purchasing Company Limited of 40 Oxford Road, High Wycombe, Buckinghamshire, HP11 2EE. UK.

IPC Europe’s data protection registration number is Z9356412.

 

Personal Data we collect
IPC Europe may collect and process the following data about you:
- Information that you provide by filling in our My Account form in the IPC Europe extranet site (‘EXTRA’), 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 Europe
- Certain details regarding your Franchise with Subway® International B.V;
- Information provided to us from Subway® International B.V;
- If you contact us, we may keep a record of that correspondence. 

We also collect data about your visit to the site and any links you access or data you enter whilst using the site.

Where we store your Personal Data
Personal Data that IPC Europe collects from Members may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"), as long as it is in a country that is deemed ‘adequate’ in line with European Union standards to transfer Personal Data to/from the EEA, such as the United States of America (“USA”).

Further information about the EEA and the countries falling within can be found at:  HTTP://WWW.EEAS.EUROPA.EU/EEA/

Personal Data may also be processed by staff operating outside the EEA who work for IPC Europe or for one of its suppliers. This would include staff who, for example, are engaged in the provision of support services. Prior to any transfer of Personal Data to or from IPC Europe to any third parties, IPC Europe will ensure such parties have adequate security protections in place for the protection and secure transmission and storage of any Personal Data, including, but not limited to, being certified under the EU-US Privacy Shield for parties situated in the United States of America. Where third parties are not situated within the United States of America, IPC Europe will check their procedures and safeguarding and security measures to ensure they are adequate pursuant to the Act and Data Protection Regulations before transmitting any Personal Data to them.    

By submitting Personal Data, Members consent to its transfer, storage and processing by IPC Europe. IPC Europe will take all steps reasonably necessary to ensure that Personal Data is treated securely and in accordance with this Privacy Policy and as permitted by the Act and related legislation from time to time.

Disclosure and use of your Personal Data

Franchise World Headquarters LLC, Milford, Connecticut, USA (‘FWH’) is an affiliated company of, and service provider to, Subway IP Inc., Plantation, Florida, USA (“DAI”), which owns the Subway® Restaurant System, and the Subway® Group. The Subway® Group includes Subway International B.V, Prisengracht, Amsterdam, a Netherlands limited liability company (“SIBV”).

We may disclose your Personal Data to FWH, and SIBV and to affiliates and subsidiaries of FWH and SIBV and to third parties that are a party to agreements with FWH or SIBV.

Both FWH and SIP Inc. are deemed to have adequate security measures in place for the receipt and transmission of Personal Data in line with European Union standards to transfer Personal Data to and from the EEA and are both certified under the EU-US Shield.

We may also disclose your information to suppliers or other third parties offering goods or services which we think may be of interest to you. 

IPC Europe may use information held about you for the following purposes (“Purposes”):
- To provide Members with information, products or services requested from IPC Europe or which interest Members. You hereby consent to be contacted for such purposes. However, you have a right to opt out of this use of your Personal Data for marketing purposes and you may email/ contact EIPC in writing to exercise your right.
- To carry out obligations arising from any contracts entered into between IPC Europe and Members.
- IPC Europe may also use Personal Data, or permit selected third parties to use such data, to provide Members with information about goods and services which may be of interest.
- Personal Data may be provided and disclosed by IPC Europe to selected persons of third party providers, their staff or other agents, employees or workers, who are engaged by IPC Europe in the provision of services to IPC Europe (whether for administrative or other functions) or who are offering a service which is considered to be of benefit to IPC Europe or its Members.
- To notify you about any changes to our services, terms, policies or other arrangements with you.

Retention of Personal Data 
IPC Europe will retain your Personal Data securely for as long as is reasonably necessary in order use it for the purposes or in accordance with any applicable laws or regulations. IPC Europe will update, archive or securely delete Personal Data if it goes out of date. Personal Data that is no longer needed for the Purposes will also be securely deleted.

Security Precautions

IPC Europe will do its best to ensure security measures are in place to protect against the loss, misuse and alteration of the Personal Data under its control. Our policies and procedures incorporate appropriate measures of security for Personal Data including:
- physical and technological security; and
- management and organisational security.

Unfortunately, the transmission of information via the internet is not completely secure. Whilst IPC Europe will do its best to protect your information, we cannot guarantee the security of your data transmitted to the site; any transmission is at your own risk. 

Contact information

Our Privacy Officer is Ben Norris. Contact details are set out below.

You may contact the Privacy Officer if you have any queries or complaints about this Privacy Policy or the treatment of your Personal Data. You may contact the Privacy Officer to access, correct or delete your Personal Data. If necessary, the Privacy Officer will contact another employee to assist in completing your requested task.
 
The Privacy Officer can be reached as follows:
- by telephone on: +44 (0)1494 511620;
- by email at: SUPPORT@IPCEUROPE.ORG;
- by post at: The Privacy Officer, IPC Europe, 40 Oxford Road, High Wycombe, Buckinghamshire. HP11 2EE. United Kingdom.;

The Privacy Officer will address your query or complaint and attempt to resolve any issues that may arise.

Your rights
Members have the right to ask us not to process Personal Data for marketing purposes or where such use is likely to cause damage or distress. If you do not want us to use your Personal Data in these circumstances, or to pass your Personal Data on to third parties, Members have the right to opt out. You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice by contacting us at IPC Europe, 40 Oxford Road, High Wycombe, Buckinghamshire, HP11 2EE. UK.

Access to information
The Act gives you the right to access Personal Data held about you.  At your request, and subject to (a) payment of a fee (£10) and (b) provision of evidence of your identity, we must provide you with any Personal Data held about you.

IPC Europe may withhold such Personal Data to the extent permitted by law.

Online

In our online presence at WWW.IPCEUROPE.ORG IPC Europe uses various tools to make the service easier for you to use, including "cookies", "refers", "IP addresses" and "environment variables".
- Cookies - A "cookie" is an element of data that a website can send to your browser, which may then store it on your system. It can then be used to provide you with tailored information. We may only use cookies if you have provided us with your consent. Where consent is provided cookies may be used to better personalise the content that you and other users will see. IPC Europe may use the information to research and understand how Members habits are similar or different so that we can enhance your experience on our site. We do not match cookie data to any personal identification. Our revised Terms and Conditions will ask you for your consent upon your registering with extra (Members who are existing users of extra will be informed of this change and asked to provide their consent to the new terms);
- Referrers - A "referrer" is the information passed along by a web browser that references the Web URL you linked from, and it is automatically gathered by our web server. This information is used by IPC Europe to identify broad demographic trends that may be used to provide information tailored to your interests.
- IP address data -  IP addresses are automatically gathered by our web server. Your IP address is a number that is used by computers on the network to identify your computer so that data (such as the web pages you request) can be sent to you. You will not be personally identified from this information.  Your IP address may also be used to assist in the detection of fraud and IPC Europe may pass this information to the Police.
- Environment variables - Environment variables we gather include time, type of web browser being used, the operating system/platform, and CPU speed. This information is used only for broad demographic information. This information is used by us in identifying broad demographic trends and may be used to provide information tailored to your interests. 

Additionally, the IPC Europe website and extranet may contain links to other sites. IPC Europe is not responsible for the privacy practices or the content of third party sites.  You should read those web sites’ privacy policies independently.

Changes to our Privacy Policy
This Privacy Policy may be reviewed by IPC Europe from time to time, and IPC Europe shall be entitled on giving reasonable notice to the Member to effect any change to these provisions which it considers necessary in the interests of IPC Europe and Members.

 

CONFIDENTIALITY NOTICE

Non-disclosure of Information within EXTRA

In accordance with paragraph 5.n. of the SIBV Franchise Agreement (‘Franchise Agreement’) Members are under a duty not to disclose or publish any Confidential Information (as defined under the Franchise Agreement) or designated as confidential by SIBV or its affiliates.

In accordance with paragraph 7.00 of the SIBV Development Agent Agreement (‘DA Agreement’), DAs are under a duty not to disclose or publish any Conditional Information (as described under the DA Agreement) or designated as confidential by SIBV or its affiliates.

Some or all of the information contained on extra is Confidential Information as defined by Paragraph 5.n and/ or Paragraph 7.00 in the respective Agreements. Accordingly, Members/Development Agents must comply with the duties of confidentiality and non-disclosure set out under their respective Agreements including when granting access to employees and field consultants.
 
This Privacy Policy was last updated on 31st August 2017.
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