YOUR PRIVACY IS IMPORTANT
Your privacy is important to us and Subway Vault Pty Ltd (Subway) is dedicated to protecting your personal information across all areas of its business. Personal information is information or an opinion about you.
It also contains information about how you can access the personal information Subway or Scantek holds about you, how you can ask Subway or Scantek to correct your personal information and how you can make a complaint if you have concerns about how Subway or Scantek managed your personal information.
You can find more information by contacting Subway (please refer to the “Contact us” section of this policy).
COLLECTION OF PERSONAL INFORMATION
Subway collects your personal information so that we can perform our functions or activities and offer our services to you.
Personal information includes things such as your name, image, date of birth, phone number(s), postal address and email address. The type of personal information we collect from you depends on your interaction with us.
Depending on the transaction, if Subway does not collect your personal information, we may not be able to provide you an offer or service.
Collection from you
It is Subway’s usual practice to collect your personal information directly from you. For example, you provide us your personal information when you visit the venue, purchase items from the online store, write to us, join a mailing list or make a private room reservation.
Collecting sensitive personal information
Sensitive personal information is information or an opinion about an individual’s racial or ethnic origin, political opinions or memberships, religious beliefs or affiliations, philosophical beliefs, sexual preferences, criminal record, health information, genetic information or membership of a trade union.
Subway’s general approach is not to collect, use or disclose sensitive information. However in limited circumstances, Subway will collect sensitive information where it is necessary for one of Subways' functions or activities and you have consented to the collection of that information.
Collecting information required by law
Subway also collects your personal information where we are required or authorised to do so by an Australian law or court or tribunal order, for example, pursuant to the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth).
USING AND DISCLOSING YOUR PERSONAL INFORMATION
We use and disclose your personal information that we collect (and share it with related companies) for a number of different purposes, including:
- to identify and contact you and manage our relationship with you;
- to tell you about things at Subway that you may be interested in;
- to manage and administer our services to you;
- to conduct and improve our businesses and improve the customer experience;
- to maintain security and safety in our venues;
- to prevent or investigate any actual or suspected misconduct, fraud or unlawful activity;
- to consider any concerns or complaints you may raise against Subway;
- to comply with our legal obligations as required by relevant laws, regulations and codes of practice.
Disclosing your personal information
We understand how important it is to keep your personal information private. We will use and disclose your personal information for the purposes we collected it as well as purposes that are related, where you would reasonably expect us to. We will also disclose your personal information when:
- you agree to the disclosure; or
- the disclosure is required or authorised by law.
To the extent permitted by law, we may also disclose information about you to:
- Subway's related companies;
- third parties who provide services to Subway from time to time such as mail-house providers, customer research agencies, debt collectors, advertising agencies and our advisers;
- government agencies as part of our statutory obligations; and
- other sauna operators.
Where applicable Subway will use your personal information to contact you via mail, SMS, email, telephone or online to tell you about news, special offers, products and services that you might be interested in. We do this where you have consented to receiving such information or it is related to the purpose for which we collected your personal information. You can contact us to update your marketing preferences at any time.
Private Room Reservation
Subway may collect your personal information in order to secure your reservation for a private room and for marketing purposes. If you do not provide this information you cannot reserve the room.
Subways venue is subject to CCTV and audio surveillance to maintain security and safety in our venues at all times. Details of suspected or actual illegal or improper conduct may be shared with the Victorian Commission for Gambling and Liquor Regulation and law enforcement bodies.
SECURITY OF PERSONAL INFORMATION
Subway takes steps to protect the personal information it holds against loss, interference, unauthorised access, use, modification or disclosure and against other misuse.
Your personal information is held on Subways premises and systems or offsite using trusted third party providers. Our employees and service providers are required to maintain the confidentiality of any personal information held by Subway. Our security safeguards include:
- staff training on their obligations with regard to your information;
- ensuring appropriate data handling and security arrangements are in place when we disclose information overseas or use third parties to handle or store data;
- system security such as encryption, firewalls and intrusion detection systems and surveillance;
- complex security such as CCTV and audio surveillance and our security and surveillance staff; and
- destroying personal information when no longer required.
ACCESS AND CORRECTION OF YOUR PERSONAL INFORMATION
Subject to some exemptions, you may ask Subway to provide you access to the personal information that we hold about you. To do so, please attend Subway with photo identification and speak to the manager.
Once Subway has collected your personal information it will provide you a copy of it in person at Subway subject to verifying your identity.
A copy of your information will generally be made available to you within 30 days unless we are not required to give you access to your personal information pursuant to an exception in the Privacy Act.
Where applicable, we will inform you in advance of any fees for Subway to find the information you have requested.
WEBSITES, DEVICES AND COOKIES
Where applicable, Subway will also collect the following information from you:
- where devices are enabled to connect to, or are identifiable by, the Subways infrastructure (for example Wi-Fi networks or bluetooth infrastructure), we and our third party providers may automatically collect data from those devices including usage, type of device, location within the complex and arrival and departure time;
- the fully qualified domain name from which you accessed our websites, or alternatively, your IP address;
- the web browser that you are using and the pages you accessed;
- device ID number (MAC address);
- the date and time you accessed each page on our websites;
- the URL of any webpage from which you accessed our websites or by using the Wi-Fi, and the details of any mobile Apps you have accessed from a device using the Wi-Fi;
- publicly accessible social media posts and any personal information you allow us to collect by linking your account on our website with a third-party social-networking site including but not limited to Facebook, Twitter, or Google+; and
- cookies which track your visits to the our web sites (see below).
Where applicable, we are collecting this information (and may use or hold this information) to provide, improve and develop our services to you and the customer experience.
Subway may use this anonymised data to inform our promotional and marketing strategies, as well as for research and profiling purposes including customer demographics, interests and behaviours based on personal information and other information provided to us. This research may be compiled and analysed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated information in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
Subway may connect information you provide to us for one purpose with other information for use for one or more of the above purposes. If you access or log-in to the complex Wi-Fi service, and we already hold other information (both personal or non-personal) that can be associated to you or the device on which you are accessing the Wi-Fi service (including, but not limited to a device ID number (MAC address)), then that information may be linked with personal information we hold about you as set out in this policy, and will be treated in the same manner as the personal information to which it has been linked.
Most web browsers are set to accept cookies, however, if you do not wish to receive any cookies, you may set your browser to refuse them. In some instances this will mean that you will not be able to take full advantage of parts of the website that provides you with improved service.
MAKING A PRIVACY COMPLAINT
Subway takes its obligations pursuant to the Privacy Act (the Act) seriously. Individuals may complain about a breach of the Act by Subway by submitting their complaint in writing to Subways Manager (using the address below).
Any complaint should set out in as much detail as possible, all the relevant particulars relating to the complaint, including why the individual says that Subway has breached the Act.
Upon receiving a written complaint, Subway will acknowledge receipt of the complaint in writing within 7 days. Subway will investigate the matters described in the complaint and then provide a substantive written response within 28 days from the date the written complaint was received by Subway.
HOW TO CONTACT SUBWAY
Telephone: +61 3 9620 7766
Vault 13, 397 Flinders Street
Facsimile: +61 3 9620 7766