Privacy Policy

This Privacy Policy discloses the privacy practices for the Marwaha Group, LLC site [www.marwahagroup.com] and various related services (together referred to as the “site” or “Website”). Marwaha Group, LLC, the provider of the site (referred to as “us”, “we”, “Marwaha Group”, or “Company”), is committed to protecting your privacy online. Please read the information below to learn the following regarding your use of this site:

  1. What information do we collect from you?
  2. Where do we collect information from you and how do we use it?
  3. With whom do we share your information?
  4. How can you update, correct or delete your Personally Identifiable Information?
  5. What are your choices regarding collection, use and distribution of your information?
  6. What security precautions are in place to protect against the loss, misuse or alteration of your information?
  7. Do we use “cookies”?
  8. What should you know about privacy policies and data collection at any third party sites accessible from our site?
  9. What else should you know about your privacy online?

YOU ACKNOWLEDGE THAT THIS PRIVACY POLICY IS PART OF OUR SITE TERMS OF USE, AND BY ACCESSING OR USING OUR SITE, YOU AGREE TO BE BOUND BY ALL OF ITS TERMS AND CONDITIONS, AS WELL AS THIS PRIVACY POLICY. A COPY OF OUR TERMS OF SERVICE CAN BE FOUND AT www.marwahagroup.com/TOS.

BY SUBMITTING ANY PERSONAL INFORMATION TO Marwaha Group, AND/OR BY ACCESSING AND USING THIS SITE, YOU AGREE TO OUR COLLECTION, USE, AND DISCLOSURE OF SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THESE TERMS, PLEASE DO NOT ACCESS OR USE THIS SITE.

IN ADDITION TO CONSENTING TO THE WEBSITE PRIVACY POLICY, TERMS AND CONDITIONS, AS WELL AS ANY RELEVANT SUPPLEMENTAL POLICIES, YOU EXPRESSLY CONSENT TO Marwaha Group SHARING THE PERSONALLY IDENTIFIABLE INFORMATION THAT YOU HAVE PROVIDED TO Marwaha Group, AS DESCRIBED HEREINWITH THE SUBWAY® GROUP, FRANCHISE WORLD HEADQUARTERS, LLC, DOCTOR’S ASSOCIATES, INC.,ITS AFFILIATES AND/OR ITS THIRD-PARTY SERVICE PROVIDERS, SUCH AS INDEPENDENT PURCHASING COOPERATIVE, INC. (“IPC”)(COLLECTIVELY, THE “SUBWAY® GROUP”). THIS PRIVACY POLICY DOES NOT GOVERN THE PRIVACY PRACTICES AND PROCEDURES OF THE SUBWAY® GROUP OR INDEPENDENTLY OWNED AND OPERATED SUBWAY® RESTAURANTS AND FRANCHISEES.

We respect the privacy of the SUBWAY® Group, SUBWAY® customers, employees, franchisees, job applicants, and visitors of this Site who may choose to provide Personally Identifiable Information. We recognize the need for appropriate protections and management of the Personally Identifiable Information you provide to us. This Privacy Policy will assist you with understanding what types of personal information we may collect, how that personal information may be used, and with whom it may be shared.

We reserve the right to change this Privacy Policy at any time. Such changes, modifications, additions or deletions shall be effective immediately upon notice thereof, which may be given by means including, but not limited to issuing an e-mail to the e-mail address listed by registered users and posting the revised Policy on this page. You acknowledge and agree that it is your responsibility to maintain a valid e-mail address as a registered user, review this site and this Policy periodically and to be aware of any modifications. Your continued use of the site after such modifications will constitute your: (a) acknowledgment of the modified Policy; and (b) agreement to abide and be bound by the modified Policy. Doctor’s Associates Inc. (“DAI”), owns the trade name and service mark SUBWAY®, the recipes, formulas, food preparation procedures, business methods, business forms, and business policies.

What information do we collect from you?

In order to better provide you with our numerous services, we collect two types of information about our users: Personally Identifiable Information and Non-Personally Identifiable Information. Our primary goal in collecting information from you is to provide you with a smooth, efficient, and customized experience while using our site.

Personally Identifiable Information: This refers to information that lets us know the specifics of who you are. When you engage in certain activities on this site, such as registering or submitting content, we may ask you to provide certain information about yourself by filling out and submitting an online form. Some of the information we may collect may include:

  1. Registration Information, such as name and email address
  2. Subscription Information
  3. Correspondence
  4. Job Applications, Performance, and Human Resources Information
  5. Social Security Numbers and/or Identification Number (“SSN/I.N.”)
  6. Home Address and Telephone Numbers
  7. Dates of Birth
  8. Background Verification Information
  9. Employment Reference Information
  10. Inventory and Store Information
  11. Franchisee Information

It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, we may ask that you provide us personal information, such as your first and last name, mailing address (including zip code), e-mail address, employer, job title and department, telephone and facsimile numbers, and other personal identifying information. When ordering services on the site, you may be asked to provide a credit card number. Depending upon the activity, some of the information we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.

Marwaha Group™takes measures to maintain the confidentiality of your SSN/I.N. to protect your SSN/I.N from unlawful disclosure, and to limit access to your SSN/I.N. We will not make your SSN/I.N available to the general public, print your SSN/I.N on any card, require you to provide your SSN/I.N to access any products or services, transmit your SSN/I.N over the Internet unless the connection is secure or your SSN/I.N has been encrypted, or requires the transmittal of your SSN/I.N to access our Website without requiring additional authentication.

Non-Personally Identifiable Information : This refers to information that does not by itself identify a specific individual. We gather certain information about you based upon where you visit on our site in several ways. This information is compiled and analyzed on both a personal and an aggregated basis. This information may include the Web site’s Uniform Resource Locator (“URL”) that you just came from, which URL you go to next, what browser you are using, and your Internet Protocol (“IP”) address. An URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the World Wide Web. Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the web, allowing web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet.

Sensitive Personal Information : Sensitive Personal Information is information that can include but is not limited to, an individual’s gender, racial or ethnic origins, politics, religion, trade union membership, veteran status, physical or mental health, disabilities, sex life, sexual orientation, or criminal (or alleged criminal) activities, proceedings or convictions. We will never collect Sensitive Personal Information except to comply with Affirmative Action data requirements or certain health information covered by the policy below.

This website is not targeted towards children under the age of thirteen (13). We do understand that children may try to contact us and in so doing may voluntarily provide Personally Identifiable Information on this website. If you are a child under the age of thirteen (13) PLEASE, DO NOT submit any Personal Information about yourself on this website. This website is not intended to be used by anyone under the age of thirteen (13).

Children’s privacy is very important to us. Our servers are located in the United States and we make all attempts to assure that our server hosting provider(s) adheres to the United States Children’s Online Privacy Protection Act (“COPPA”). The Federal Trade Commission (“FTC”) has the authority to issue regulations and enforce COPPA, which applies to websites and online services operated for commercial purposes that are directed at, and are collecting Personal Information from children under thirteen (13) years of age. COPPA explains what a website operator must include in their Privacy Statement, what responsibilities a website operator has to protect children’s privacy and safety online, including restrictions on marketing to those under thirteen (13) years of age, it also requires that we inform parents and/or legal guardians how we collect, use, and disclose Personal Information from children under thirteen (13) years of age, as well as, how to obtain verifiable consent from a parent in order for children to use certain features of on a website. We will not knowingly allow anyone under thirteen (13) years of age to provide us with any Personally Identifiable Information about themselves (such as their names, e-mail address, and phone number) over the Internet. If a child has provided us with Personally Identifiable Information without the consent of a parent, we ask the parent of that child to contact our Privacy Officer immediately at: privacy@marwahagroup.com. We will use all reasonable efforts to promptly delete the child’s information from our servers. Please note, that when we use the term “parent”, we mean to include legal guardians.

Health Related or Medical Information; HIPAA Notice. THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY. In connection with our services, we may be required to obtain and transmit certain medical or health-related information about you. Although we do not feel that we are a “covered entity” required to comply with Health Insurance Portability and Accountability Act of 1996 (HIPAA), therefore, we are not required to provide you with a HIPAA Privacy Notice; however, we will take all measures outlined in this Privacy Policy to protect this information.

Where do we collect information from you and how do we use it?

We do not collect any Personally Identifiable Information about you unless you voluntarily provide it to us. You provide certain Personally Identifiable Information to us when you:

  1. Register for our services and register your e-mail address with us;
  2. Connect our services to and exchange information with the SUBWAY® Group data API, including, but not limited to Subshop 2000 and SubwayPOS.
  3. Sign up for special offers from selected third parties;
  4. Sign up for special offers from selected third parties;
  5. Send e-mail messages, submit forms or transmit other information by telephone or letter; or
  6. Submit your credit card or other payment information when ordering and purchasing products and services on our site.

We may also collect information from you at other points on our site that state that such information is being collected.

In addition, we may also collect, or our third party ad server and/or content server may collect, certain Non-Personally Identifiable Information. This information is ultimately stored in the form of store categories, and, in some cases, specific URLs. We use your IP address to diagnose problems with our servers, software, to administer our site and to gather demographic information. Our third party ad servers will also provide us with summary, but not individual, reports that will tell us how many ads were presented and clicked upon at our site.

We will primarily use your Personally Identifiable Information to provide our services to you, as required by our agreements with you. We will also use Personally Identifiable Information to enhance the operation of our site, fill orders, improve our marketing and promotional efforts, statistically analyze site use, improve our product and service offerings, and customize our site’s content, layout, and services. We may use Personally Identifiable Information to deliver information to you and to contact you regarding administrative notices. We may also use Personally Identifiable Information to resolve disputes, troubleshoot problems and enforce our agreements with you, including our Site Terms of Use and this Private Policy.

Marwaha Group™ may not provide any Personally Identifiable Information to any third party without prior written consent from the SUBWAY® Group. All Personal Information is collected in a fair and non-intrusive manner, with your voluntary consent. Personal Identifiable Information is not accessible to anyone outside the specific function for which it is collected.

You may submit Personally Identifiable Information via your cell phone, smartphone, and tablet. If you use any location-enabled products, you may be sending us location information. We do not store or use this information other than to provide the service you requested. Location-enabled features are opt-in and you have control over your participation and can turn these services off at any time.

With whom do we share your information?

We do not sell, trade, or rent your Personally Identifiable Information to others.

In order for our service to work, we must share your information with the SUBWAY® Group, DAI, and its affiliates. We are required to comply with the SUBWAY® Group’s privacy policies, data protection policies, and principles. A copy of these policies and principles can be found at www.subway.com. The SUBWAY® Group, its affiliates, third party service providers, and SUBWAY® DA’s may share and exchange Personally Identifiable Information in order to administer the SUBWAY® franchise system, and protect the integrity of the SUBWAY® franchise system and trademarks. Personally Identifiable Information may be provided to a courier or freight forwarder to fulfill an order, which may have been requested from us. SUBWAY® DA’s and other service providers are prohibited from using Personally Identifiable Information for any purpose other than to provide assistance to DAI and its affiliates within the SUBWAY® Group. DA’s are required to protect Personally Identifiable Information disclosed by us and to comply with the general privacy principles described in their Privacy Statement.

We will require any other service partners to adopt and post privacy policies. However, the use of your Personally Identifiable Information by our service partners is governed by the privacy policies of those service partners, and is not subject to our control. Any Personally Identifiable Information may not be disclosed to these third party providers without the express written consent of the SUBWAY® Group.

Occasionally we may be required by law enforcement or judicial authorities to provide Personally Identifiable Information to the appropriate governmental authorities. We will disclose Personally Identifiable Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

We may also provide Non-Personally Identifiable Information about our customers’ sales, traffic patterns, and related site information to third party advertisers, but these statistics do not include any Personally Identifiable Information. s

How can you update or correct your Personally Identifiable Information?

We believe you should have the ability to access and edit the Personally Identifiable Information that you have provided to us. You may change any of your Personally Identifiable Information in your account online at any time by linking to your account in accordance with instructions posted elsewhere on this site. You may also access and correct your personal information and privacy preferences by writing us at:

Marwaha Group, LLC
Attn: Privacy Compliance Officer
2551 Woodland Drive
Anaheim, CA 92801

Please include your name, address, and/or e-mail address when you contact us.

We encourage you to promptly update your Personally Identifiable Information if it changes. You may ask to have the information on your account deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions on this site. In addition, it may be impossible to completely delete your information without some residual information because of backups.

What are your choices regarding collection, use, and distribution of your information?

We may, from time to time, send you e-mail regarding our products and services. In addition, if you indicated upon registration that you are interested in receiving offers or information from us and our partners, we may occasionally send you direct mail about products and services that we feel may be of interest to you. Only Marwaha Group™ (or agents working on behalf of Marwaha Group™ and under confidentiality agreements) will send you these direct mailings and only if you indicated that you do not object to these offers. If you do not want to receive such mailings, simply tell us when you give us your personal information. Or, at any time you can easily edit your account information to no longer receive such offers and mailings.

You also have choices with respect to cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of our site may not work properly in your case.

What security precautions are in place to protect against the loss, misuse, or alteration of your information?

At our site you can be assured that your Personally Identifiable Information is secure, consistent with current industry standards. The importance of security for all Personally Identifiable Information associated with our user is of utmost concern to us. Your Personally Identifiable Information is protected in several ways. Access by you to your Personally Identifiable Information is available through a password and unique customer ID selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone. In addition, your Personally Identifiable Information resides on a secure server that only selectedMarwaha Group™ personnel and contractors have access to via password. We encrypt your Personally Identifiable Information and thereby prevent unauthorized parties from viewing such information when it is transmitted to us.

You are responsible for all actions taken with your customer/user ID and password for this site, including disclosure of Personally Identifiable Information and all actions taken with your account. Therefore we do not recommend that you disclose your password to any third parties. If you lose control of your password, you may lose substantial control over your Personally Identifiable Information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password.

Personal information that you provide that is not Personally Identifiable Information also resides on a secure server and is only accessible via password. Since this information is not accessible from outsideMarwaha Group™ you will not be asked to select a password in order to view or modify such information.

Marwaha Group is certified by the U.S. Department of Homeland Security (“DHS”) and Social Security Administration for web-integrated e-verification or employment eligibility. If we are providing these services to you pursuant to a subscription, during the web-integrated e-verification process, Personally Identifiable Information will be transmitted securely to DHS servers. Marwaha Group takes no responsibility for the security of DHS servers or any data loss or misuse that may occur by DHS or their affiliates or contract service providers.

If we are providing these services to you pursuant to a subscription, we connect to and exchange data through the SUBWAY® Group and its affiliates or service providers. Marwaha Group takes no responsibility for the security of the SUBWAY® Group’s servers or any data loss or misuse that may occur by the SUBWAY® Group or its affiliates or contract service providers. A copy of the SUBWAY® Group’s privacy policies can be found at www.subway.com.

If we are providing these services to you pursuant to a subscription, we also may connect to and exchange data through background check service providers, such as www.backgroundchecks.com SUBWAY® Group and its affiliates or service providers. Marwaha Group takes no responsibility for the security of the SUBWAY® Group’s servers or any data loss or misuse that may occur by the SUBWAY® Group or its affiliates or contract service providers or the accuracy of the information provided.

If we are providing these services to you pursuant to a subscription, we also may connect to and exchange data through DocuSign, Inc., its affiliates or service providers. Marwaha Group takes no responsibility for the security of the DocuSign, Inc. servers or any data loss or misuse that may occur by DocuSign, Inc., its affiliates or contract service providers. A copy of DocuSign, Inc.’s privacy policy is located at https://www.docusign.com/company/privacy-policy.

In order to most efficiently serve you, credit card transactions and order fulfillment are handled by established third party banking, processing agents and distribution institutions. They receive the information needed to verify and authorize your credit card or other payment information and to process and ship your order.

If we are providing these services to you pursuant to a subscription, we may connect to, exchange, and view security or other closed circuit camera footage. By sharing this footage with us, you represent and warrant that we have the right to view and, if required by law, disclose this footage. We do not warrant or represent that your use of cameras or surveillance equipment complies with local privacy and other laws and regulations. We will not be held liable for any breach of privacy or other laws arising out of your use or our viewing of such footage. You represent and warrant to us that you are not using any concealed cameras in any areas where there is a reasonable expectation of privacy or in a way that may otherwise violate the law

If we are providing these services to you pursuant to a subscription, we may connect to and view bank account data in connection with reconciliations. Marwaha Group™ takes no responsibility for the security of your servers or that of your bank.

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.

If Marwaha Group™ is required to provide notice of unauthorized access of certain security systems, you agree that we may do so when required or voluntarily by posting notice on the Website or sending notice to any email address we have for you, in the good faith discretion of Marwaha Group™.You agree that notice to you will count as notice to any other individual for whom you are acting and agree to provide the notice to any such individual.

Do we use “cookies”?

When you use our site we will store cookies on your computer in order to facilitate and customize your use of our site. A cookie is a small data text file, which a Web site stores on your computer’s hard drive (if your Web browser permits) that can later be retrieved to identify you to us. Our cookies store randomly assigned user identification numbers, the country where you are located, and your first name to welcome you back to our site. The cookies make your use of the site easier, make the site run more smoothly and help us to maintain a secure site. You are always free to decline our cookies if your browser permits, but some parts of our site may not work properly in that case.

We may use an outside ad serving company to display banner advertisements on our site. As part of their service, they will place a separate cookie on your computer. We will not provide any third-party ad server with any of your Personally Identifiable Information or information about your purchases. We and our third party ad server will collect and use Non-Personally Identifiable Information about you, such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server and whether you responded to a particular ad. Other advertisers may also place banner ads on our site in the same manner as above, but we will not disclose any Personally Identifiable Information to them.

Phishing-Identity theft and the practice currently known as “phishing” are of great concern to us. Accordingly, safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, and Social Security Number or National Identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website at: http://www.consumer.ftc.gov/articles/0003-phishing.

What should you know about privacy policies and data collection at any third party sites accessible from our site?

Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. Other sites accessible through our site have their own privacy policies and data collection, use and disclosure practices. Please consult each site’s privacy policy. We are not responsible for the policies or practices of third parties. Additionally, other companies which place advertising on our site may collect information about you when you view or click on their advertising through the use of cookies. We cannot control this collection of information. You should contact these advertisers directly if you have any questions about their use of the information that they collect.

What else should you know about your privacy online?

You must be at least 18 years old to have our permission to use this site. Our policy is that we do not knowingly collect, use or disclose Personally Identifiable Information about visitors that are under 18 years of age.

California Privacy Rights (As provided by California Civil Code Section 1798.83). A California resident who has provided Personally Identifiable Information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California customer”) is entitled to request information about whether the business has disclosed Personally Identifiable Information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of Personally Identifiable Information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom Personally Identifiable Information was disclosed in the preceding calendar year, as well as a list of the categories of Personally Identifiable Information that were disclosed. However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its Privacy Statement) a policy of not disclosing customer’s Personally Identifiable Information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this policy. Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of Personally Identifiable Information and providing a cost free means to exercise that right.

U.S. – EU and the U.S. – Swiss Safe Harbor Compliance. Marwaha Group™, is in compliance with the U.S. Department of Commerce Safe Harbor requirements regarding the transfer of Personal Information from the European Economic Area (“EEA”) or Switzerland to the United States. The Safe Harbor requires compliance with the U.S. – EU and the U.S. – Swiss “Safe Harbor” Frameworks Privacy Principles which are:

Notice – Marwaha Group™, is in compliance with the U.S. Department of Commerce Safe Harbor requirements regarding the transfer of Personal Information from the European Economic Area (“EEA”) or Switzerland to the United States. The Safe Harbor requires compliance with the U.S. – EU and the U.S. – Swiss “Safe Harbor” Frameworks Privacy Principles which are:

Choice – Individuals must have the ability to opt out of the collection and forward transfer of the data to third parties;

Onward Transfer (Transfers to Third Parties) – ITransfers of data to third parties may only occur to other organizations that follow adequate data protection principles;

Security – Reasonable efforts must be made to prevent loss of collected information;

Data Integrity – Data must be relevant and reliable for the purpose for which it was collected;

Access – Individuals must be able to access information held about them, and correct or delete it if it is inaccurate;

Enforcement – There must be effective means of enforcing these rules.

Further information regarding the “Safe Harbor” Frameworks privacy principles and certification process can be found at: www.export.gov/safeharbor.

You should also be aware that when Personally Identifiable Information is voluntarily disclosed (i.e. your name, e-mail address, etc.) in any discussion forums or other public areas on this site or any other site, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this Policy does not apply to such information. Ultimately, you are solely responsible for maintaining the secrecy of your password and/or account information. Please be careful and responsible whenever you’re online.

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us by sending a letter to:

Marwaha Group, LLC
Attn: Privacy Compliance Officer
2551 Woodland Drive
Anaheim, CA 92801 You may also contact us by e-mail info@marwahagroup.com

The Terms and Conditions located at: http://www.marwahagroup.com/Termsandconditionsgovern your use of the Marwaha Group™ website: www.marwahagroup.com. The provisions therein apply to any disputes that may arise in relation to this Privacy Statement and the collection, use and disclosure of your Personally Identifiable Information, and are of the same force and effect as if they had been reproduced directly in this Privacy Statement.