To make suggestions and recommendations to you and other users of the Website about goods or services that may interest you or them

Vital interests

Privacy Policy

1. WHO WE ARE
IPC International is made up a number of companies including but not limited to IPC International Ltd, IPCI UK Ltd, IPCI UK2 Ltd, IPCI Australia Pty Ltd, IPCI Singapore Pte. Ltd, IPCI Korea Ltd, European Independent Purchasing Company Limited, IPC Europe Ltd or any Affiliate of any one of these companies. References to IPC International in this Privacy Notice are to the group unless a company has been expressly stated.

2. INFORMATION WE COLLECT AND WHAT WE DO WITH IT
IPC International collects and processes Personal Data from a number of different sources lawfully, fairly and transparently. We use the following bases for processing your Personal Data:

a. Contractual basis: we process your Personal Data where the processing is necessary for the performance of a contract, this includes the IPC Terms and Conditions. For this reason, we may send you notifications or contact you regarding relevant provisions in relation to the contract between us. You are unable to opt out of having Personal Data processed by us where we process your Personal Data on the basis of it being necessary for the performance of our contractual relationship.

b. Legitimate interest: we may collect, hold and process your Personal Data on the basis of legitimate interest where it is necessary for us to fulfil our needs as a business and to be able to provide you with our Services. We may also rely on this basis to process Personal Data where we believe that such processing is in your legitimate interest.

NOTE: If you do not want to be contacted on the above basis, you can opt-out at any time by contacting our Support Desk via email: support@ipcinternational.com. Please be aware that this may have an adverse impact on the range and effectiveness of services provided to you.

c. Vital interest: in certain limited circumstances we may use your Personal Data to contact you if we reasonably believe that there is any urgent safety or product issue that we need to communicate to you where there is no other applicable lawful basis.

d. Legal Obligation: on occasion it may be necessary to process your Personal Data in order to comply with our own legal obligations such as complying with money laundering legislation, for financial reporting.

e. Consent: where consent is relied upon you will be provided with enough information to enable you to make an informed decision on whether to provide or withhold consent prior to the processing activity taking place. You can request to cancel your access to a Secure Area at any time and for your details and information to be deleted. Should you wish to do so, please contact Us at SUPPORT@IPCINTERNATIONAL.COM. Please be aware that this will have an adverse impact on the range and effectiveness of Services provided to you.
Personal Data is collected and processed from a variety of sources; directly from you, automatically and from third parties.

Information collected directly:
Where IPC International has direct interactions with you, we collect personal data directly from you. This includes information you have provided to IPC International:

to carry out any obligations arising from any agreement or contract with you;

you access, register, post or upload onto a Technology Platform including any Secure Area including completing forms or respond to a survey;
you contact IPC International either by email, phone or by submitting information onto or through a Technology Platform;
you post or upload Personal Data to a Technology Platform
you contact us through our Support Desk regarding a query or complaint and we may keep a record of that correspondence.
to seek your view or comment on the services IPC International or any of its Affiliates provides;
to send you information that may be of your interest;

to send you information about our new deals and/or services including new ways of working or new routes to market;
to respond to your request or queries;

you have contacted us directly.

When you provide Personal Data to us, please do not supply any additional Personal Data unless we prompt you to do so. We will never ask for your bank account details or passwords including in any Secure Area of a Technology Platform. We shall not be responsible for any information that you voluntarily send us without being required to do so.

Information collected automatically:
Each time you visit a Technology Platform we will automatically collect the following information:

technical information, including the internet protocol (IP) address used to connect your computer and/or device to the internet, your login information, browser type and version, device type and operating system, time zone setting, browser plug-in types and versions, operating system and platform;
information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from the Technology Platform (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page;
data on visits and the visitors to the Technology Platforms. We track visitors using ‘cookies’ (see our Cookie Policy for more details);
to allow you to participate in interactive features of our Services when you choose to do so;
we may carry out market research or surveys for your views and opinions. Unless you are advised to the contrary any answers to market research surveys that you give will be anonymised. Participation in research is entirely voluntary.

Information we may receive from and share with third parties:
We may share information from a number of different third parties, including:

information with Subway® including details of a Franchisee in a Territory as well as details of prospective suppliers;
you are an employee of a Franchisee and the Franchisee has provided us with your details;
you obtain goods and/or services from suppliers and/or distributors or other third parties that we engage and manage;
third party Affiliates including Technology Platforms or the platforms of IPC International’s service providers;
use or permit selected third parties to use your Personal Data to provide you with information which may be of interest;
where we are required and as permitted by applicable law to provide information to regulators, courts, tax authorities or similar agencies government agency websites such as Companies House and Orbis, screening providers, for example in relation to financial sanctions checks, credit screening, Sedex, or other organisations to manage supply chain operations. This data is shared only where such disclosure is lawful and necessary, and only following a proportionality assessment;
with our professional advisers and consultants, including insurers, auditors, accountants;
with suppliers, distributors, service providers, agents, subcontractors and other associated organisations for the purpose of completing tasks and operating our business;
third-party suppliers, prospective suppliers and distributors;

We will not sell or rent your information to third parties. We will not share your information with third parties for marketing purposes other than as set out above, unless we have your prior consent.

Other sources of information:

to keep our Technology Platforms safe and secure;
to administer the Technology Platforms and for internal operations including troubleshooting, data analysis testing research statistical and survey purposes (anonymised operations)
to improve the Technology Platforms to ensure that the content is presented in the most effective manner for you
we may use and analyse the information we collect so that we can manage, administer, support, improve and develop our business.
manage your relationship with distributors, suppliers and Franchisees;
to contact you about any IPC International governance activity such as but not limited to elections or voting;
to provide you information about suppliers, distributors or Franchisees;
to help you to buy new products and/or services at better prices and/or with improved services;
to provide you with new IPC services for Franchisees benefit;
to comply with statutory requirements and/or requirements of local authorities in relation to the services we provide to you including compliance with General Data Protection Regulation 2016, Data Protection Act 2018 and Australian Privacy Act 1988.

Types of Personal Data:

name, surname, address, telephone number, mobile number, personal email address, date of birth (if required);
store and/or commercial details including store number, Franchisee unique identifier , address, phone number, email where such information may identify an identifiable individual
details regarding the contracts and arrangements you have entered into with suppliers and/or distributors sourced by IPC International, including but not limited to commercial details for example deals with services providers and trading history where such information may identify an identifiable individual
when you contact IPC International through a Technology Platform regarding any query or complaint, we may keep a record of that correspondence. Please do not supply any additional personal data unless we prompt you to do so. We will never ask for your bank account details or passwords to any Secure Area of a Technology Platform. We shall not be responsible for any information that you voluntarily send us without being required to do so.

We may use and share anonymised and aggregated information relating to groups of Franchisees, without identifying individuals. This type of information is not ‘Personal Data’ because the individuals are not traceable, and any personal details are not kept. We use this information to learn more about your behaviour and find ways of enhancing our service.

3. SHARING YOUR DATA
We transfer your Personal Data between the IPC International companies around the world to enable us to provide Services to Franchisees and to operate our business as efficiently as possible.
The Personal Data that is collected from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) as long as it is in a country which has been assessed by the European Commission and/or ICO as ensuring an adequate level of protection for Personal Data.

Personal Data may also be processed by staff operating outside the EEA who work for IPC International, its Affiliates or the Subway® Group. 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 International to any third party, they will take all reasonable steps to ensure that 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 EEA, IPC International will check their procedures, safeguards and security measures to ensure they are adequate pursuant to the data protection legislation before transferring and/or exporting any Personal Data to them; such transfer or processing shall be made in accordance with the standard contractual clauses or such alternative transfer mechanism as permitted in the laws of the Territory.

IPC International will take all reasonable steps necessary to ensure that Personal Data is treated securely and in accordance with this Privacy Policy and as permitted by data protection legislation and related legislation.

4. WHERE DATA MAY BE PROCESSED
Personal Data may be collected and processed across the Territories.

5. HOW LONG CAN WE KEEP YOUR DATA
We will only retain your Personal Data as long as it is deemed necessary for the purposes for which it was collected, to comply with applicable laws or regulations and your consent.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the Purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. We may retain your basic information for longer periods if so required by law.

6. GENERAL
Third Party Links – The Technology Platforms may include links to third party websites. We are not responsible for the content of those sites or the privacy practices. If you choose to visit those sites, we advise you to review the third-party’s terms and conditions and privacy notice when you first access them and before submitting your personal information. We do not accept any liability for the contents of any third-party websites.

Security Precautions – IPC International has appropriate technical and organisational measures in place to protect against the loss, misuse and alteration of the Personal Data under its control. Unfortunately, the transmission of information via a Technology Platform is not completely secure. Although IPC International does its best to protect your Personal Data, we cannot guarantee the security of your data transmitted to any Technology Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. It is your responsibility to keep your password confidential. If you believe that your password has been compromised, then you should contact our Support Desk immediately on support@ipcinternational.com.

Minors – The Secure Area is for Secure Users only and is not designed or intended to collect Personal Data from users below the minimum employment age in the Territory. IPC EMEA does not knowingly collect Personal Data from anyone below the minimum employment age. If you believe a user below the minimum employment age has provided IPC EMEA with Personal Data without consent, please contact our Support Desk.

Jurisdiction – The terms of this Privacy Policy are governed by the Laws of England and Wales and are subject to the exclusive jurisdiction of the English Courts.

7. DEFINITIONS
Affiliates means a subsidiary of IPC International Ltd and/or any other organisation that directly or indirectly controls or is controlled by, of is under common control of it.

Employee means any employee of Subway®, Subway® Franchisees and the employees of IPC International.

Franchisee(s) are the IPC franchisee members operating in a Territory who have entered into a franchise agreement with Subway® and other Subway® franchisee’s, including master franchisees who have been granted territorial exclusivity.

Personal Data means any information about an identifiable person.

Secure Area means signing up to, registering and/or accessing any secured part of a Technology Platform using Personal Data;

Secure User means any Franchisee, employee of a Franchisee, supplier, distributor or prospective supplier who by accessing a Secure Area is agreeing to this Privacy Policy.

Services means any direct information that you may provide to us and all information on our Technology Platforms.

Store means the Subway® Franchisee’s store(s) located in a Territory.

Subway® means the global Subway® group organisation, including Doctor’s Associates LLC, Subway International BV and any other organisation connected with or operating for the purpose of establishing and maintaining the Subway® brand and franchise network. A full list of Subway® companies processing Personal Data is in the Subway® Group Privacy Notice: https://www.subway.com/en-SG/Legal/PrivacyStatement-FWH

Support Desk means IPC International support desk including TechNet.

Technology Platform means all of IPC International’s technology platforms including (but not limited to) all websites www.ipcinternational.com and https://europa.ipcinternational.com (“Website”), electronic platforms such as myipcinternational.com (“MyIPC Platform”) and any portals.

Territory/Territories means Europe and the United Kingdom and Middle East as well as Australia, Singapore, South Korea or such other countries or regions as IPC International may add from time to time.

8. DATA CONTROLLERS
The data controller is the organisation that decides the purposes for which and the means for which Personal Data is collected. The data controller is ultimately responsible for the use of your Personal Data. IPC International’s registered data controllers are listed at the end of this Policy.
When you interact with IPC International, the relevant legal entity that is providing Services to you or otherwise liaising with you will be the controller of your Personal Data. The registered data controllers are listed at the end of this Policy.

IPC International Ltd

IPCI UK Ltd

IPCI UK2 Ltd

IPCI Australia Pty Ltd

IPCI Singapore Pte. Ltd

IPCI Korea Ltd

European Independent Purchasing Company Limited

IPC Europe Ltd

The address for the above data controllers is 40 Oxford Road, High Wycombe, Buckinghamshire, HP11 2EE, United Kingdom.

Contact details for IPCI Australia Pty Ltd are set out in section 13 below.

9. COOKIE POLICY
Cookies are tiny text files stored on your computer when you visit certain some pages or perform certain online actions. Our Technology Platforms use cookies to distinguish you from other users and maintain settings and actions that might be important to you.

For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

10. YOUR RIGHTS
For personal data that we have about you, you can:

Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

For a full explanation of your data rights, go to WWW.ICO.ORG.UK or the equivalent authority in your country. Australian Data Subjects go to www.oaic.gov.au for information about your rights under the Privacy Act.

11. CONTACT
If you have a query, concern or complaint relating to your Personal Data, please contact support@ipcinternational.com

You may also raise your concerns with your local data protection authority directly, without contacting us first. However, we would encourage you to contact us in the first instance as we aim to promptly, efficiently and satisfactorily resolve any concerns or complaints you may have.

12. COUNTRY SPECIFIC INFORMATION
Australia
For Australian operations, we are subject to the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) contained at Schedule 2 of the Privacy Act. This Privacy Policy applies to the collection, use and disclosure of personal information from Australian Data Subjects in accordance with the Privacy Act.

For Australian Data Subjects, we collect, use and disclose personal information in accordance with the APPs under the Privacy Act. We collect personal information for the primary purposes outlined in Section 4 of this Privacy Policy and will only use or disclose your personal information for those purposes or related secondary purposes that you would reasonably expect, unless we have your consent or disclosure is otherwise permitted by law. If you do not provide all or some of the personal information requested, we may not be able to effectively manage some aspects of Our relationship with you.

For Australian Data Subjects, we will only hold your personal information for as long as is reasonably necessary to fulfil the purposes for which it was collected or to comply with legal obligations.

If you are an Australian Data Subject, under the Privacy Act, you have the right to:

request access to personal information We hold about you;
request correction of your personal information if it is inaccurate, out-of-date, incomplete, irrelevant or misleading; and
make a complaint about a breach of the Privacy Act.

To exercise these rights, contact our Support Desk at support@ipcinternational.com We will respond to such requests and investigate and respond to any complaint within a reasonable time, generally within 30 days after we receive the request or complaint. Should We not be able to respond to your request or complaint within thirty (30) days, we will inform you in writing within thirty (30) days of the time by which we will be able to respond.

If you are dissatisfied with our response to your complaint, you may contact the OAIC to make a complaint.

For Australian operations, the terms of this Privacy Policy are governed by the Laws of New South Wales, Australia and are subject to the exclusive jurisdiction of the courts of New South Wales, Australia and the OAIC for privacy matters.

The address for IPCI Australia Pty Ltd as data controller is Level 22, 25 Martin Place, Sydney NSW 2000

Last updated July 2025

IPC International © July 2025

2. WHO WE ARE
IPC International is made up a number of companies including but not limited to IPC International Ltd, IPCI UK Ltd, IPCI UK2 Ltd, IPCI Australia Pty Ltd, IPCI Singapore Pte. Ltd, IPCI Korea Ltd, European Independent Purchasing Company Limited, IPC Europe Ltd or any Affiliate of any one of these companies. References to IPC International in this Privacy Notice are to the group unless a company has been expressly stated.