Subway DIGITAL

Enterprise Technology Stack & Vendor Relationships

• Subway’s sale to affiliates of Roark completed on 30 April 2024, and Roark’s current portfolio identifies Subway as a current investment.^{1, 2}

• A 2026 Subway Franchise Disclosure Document (FDD) identifies Doctor’s Associates LLC (DAL), a Delaware LLC doing business as Subway through affiliates, as the Subway franchisor.³

• The FDD states that Underground Purchaser, LLC acquired all equity interests in Subway Worldwide System Holdings, LLC on 30 April 2024; Underground Purchaser is owned by investment funds managed by Roark Capital Management, LLC or its affiliates.³

• The FDD describes DAL as a wholly owned subsidiary within a chain running through Subway Funding LLC, Subway Funding Holdco LLC, Subway US Holdings LLC, and Subway Worldwide System Holdings LLC.³

• Florida and West Virginia entity records list Subway Funding LLC as DAL’s member, while a Wisconsin franchise filing registered DAL/Subway as a Delaware LLC on 30 April 2026.^{4, 5, 6}

• The FDD records that, at a 20 June 2024 U.S. securitization closing, specified U.S. trademarks, intellectual property, and SubwayPOS software transferred from Subway IP LLC and/or FWH Technologies, LLC to Subway US IP Holder LLC, which licensed the relevant U.S. rights to DAL for use and sublicensing to franchisees.³

• Subway Group privacy materials identify FWH Technologies, LLC as owner and licensor of SubwayPOS outside the United States and Subway US IP Holder LLC as owner and licensor in the United States; the privacy materials should not be treated as a complete post-securitization U.S. IP-ownership map.^{7, 8, 3}

• The FDD states that Franchise World Headquarters, LLC became DAL’s manager at the 20 June 2024 securitization closing and provides, or may delegate, support and services to DAL, affiliates, and franchisees.³

• Subway selected PAR EverServ POS hardware and PAR deployment and lifecycle-support services for a worldwide in-store technology programme in 2009; this historical announcement does not establish that the arrangement remains current.⁹

• Subway named NCR an approved POS provider in March 2006, with NCR RealPOS hardware offered to franchisees through Subtotal POS Systems; this establishes approved-vendor availability, not deployment at every restaurant.¹⁰

• NCR did not acquire Israeli retail-software company Retalix until February 2013.¹¹

• No public evidence identified that Subway used or still uses Retalix software or another Retalix-derived NCR product; the chronology and cited records do not establish such use, while also not proving that no individual franchisee ever deployed one.^{9, 10, 11}

• Subway’s North American loyalty and personalised-offer programme uses Adobe Journey Optimizer, Adobe Campaign, and Adobe Target following a 2023 relaunch.¹²

• Adobe describes the programme as unifying customer data from email, mobile-app, and web channels, with A/B testing used for offer and conversion optimisation.¹²

• Subway has used UserTesting for mobile-ordering personalisation and loyalty research, including video interviews with more than 800 representative customers.¹³

• Merkle describes work for Subway spanning guest strategy, data enablement, technology orchestration, analytics, and optimisation.¹⁴

• No public evidence identified of a Subway licensing, subscription, integration, or deployment relationship with Check Point, Wiz, SentinelOne, CyberArk, NICE, Verint, Claroty, Palo Alto Networks, or another identified Israeli-origin enterprise-technology vendor.^{12, 14, 8}

• No public evidence identified that a named Subway systems integrator mandated, recommended, or deployed Israeli-origin technology for Subway.^{14, 8}

Surveillance, Biometrics & Retail Technology

• Subway’s documented retail technology includes POS, digital ordering, loyalty communications, personalisation, and customer-experience research rather than a publicly identified biometric or surveillance deployment.^{9, 12, 13, 8}

• No public evidence identified of Subway’s use of Israeli-origin facial recognition, biometric identification, gait analysis, behavioural analytics, or frictionless-checkout products from Trigo, BriefCam, AnyVision/Oosto, Trax, or comparable identified vendors.^{12, 13, 8}

• No public evidence identified of Israeli-origin predictive-policing, sentiment-monitoring, social-media-monitoring, or workforce-surveillance tools used by Subway.^{12, 14, 8}

• No public evidence identified that such technologies reach Subway indirectly through a named managed-service provider or bundled platform.^{12, 13, 14, 8}

Cloud Infrastructure, Data Residency & Sovereign Cloud Participation

• Subway states that it collects personal information through its websites, restaurant Wi-Fi or similar technologies, branded third-party-platform pages, mobile applications, direct marketing, purchases, delivery and carry-out services, support interactions, and franchise applications.^{15, 8}

• Subway’s current privacy statement identifies contact, account, payment, transaction, device and online-activity, demographic, shopping-habit, loyalty, and lifestyle-preference information among its data categories.⁸

• Subway states that it combines information from its services, devices, offline sources, affiliates, service providers, public databases, data aggregators, marketing partners, and purchasing organisations.⁸

• Subway states that it may use service providers for hosting and operating Subway services, payment processing, delivery, data processing and IT, research and analytics, customer-experience management, and personalisation.^{15, 8}

• Subway states that personal information may be transferred to and processed in the United States and other countries.⁸

• Subway identifies Franchise World Headquarters, LLC, Doctor’s Associates LLC, FWH Technologies, LLC, Subway IP LLC, Subway Payment Services, LLC, and Subway US IP Holder LLC as U.S.-based entities certified under the EU–U.S., UK Extension, and Swiss Data Privacy Frameworks.⁸

• The cited privacy materials do not identify a cloud-hosting provider, data-centre location, Israeli data centre, Israel-specific data-routing arrangement, Israel-based subprocessor, or jurisdiction-specific subprocessor list; the omission does not establish where all data are processed.^{15, 8}

• No public evidence identified that Subway operates, leases, or co-locates data-centre infrastructure in Israel, participates in Project Nimbus or another Israeli government-cloud programme, or provides data-sovereignty or resilience services to Israeli state or military institutions.^{8, 16}

Defence, Intelligence & Security Sector Technology Relationships

• No public evidence identified of Subway contracts, partnerships, or service agreements with the Israeli Ministry of Defence, IDF, intelligence agencies, or other Israeli state-security bodies.^{16, 17, 18}

• No public evidence identified that Subway’s POS, loyalty, mobile-ordering, or customer-experience technology is deployed by Israeli military, intelligence, or law-enforcement bodies.^{9, 12, 8}

• No public evidence identified that Subway develops, sells, licenses, or maintains offensive-cyber tools or digital weapons systems.^{12, 8}

• Subway operates through independently owned and operated franchise restaurants; Roark describes Subway as having nearly 37,000 restaurants, so individual outlets should not automatically be treated as directly corporate-operated locations.^{19, 2}

• No public evidence identified in the reviewed corporate sources of an Israeli subsidiary, Israeli corporate office, Israeli franchisee legal entity, or Israel/occupied-territory location operated by DAL, Subway International B.V., Subway IP LLC, Underground Purchaser, Subway Worldwide System Holdings, or Subway Funding entities.³

• The FDD’s master-franchise-country enumeration does not name Israel, but that enumeration does not establish the absence of every possible Subway commercial arrangement in Israel or the occupied territories.³

AI, Algorithmic & Autonomous Systems

• Subway’s documented real-time personalisation and A/B testing concern customer offers, loyalty communications, and website conversion optimisation.¹²

• The cited customer-experience materials do not identify Israeli state, military, or security customers for Subway’s personalisation or optimisation systems.^{12, 14}

• No public evidence identified of Subway providing AI or machine-learning, computer-vision, or autonomous decision-support systems to Israeli state, military, or security bodies.^{12, 16, 18}

• No public evidence identified that Subway models or platforms were trained on, or given access to, Israeli or occupied-territory civilian, communications, or surveillance-derived datasets.^{12, 8}

• No public evidence identified of Subway provision of autonomous target generation, automated threat detection, or autonomous tracking systems to Israeli forces.^{12, 16, 18}

Technology Ecosystem & R&D Footprint

• Subway appointed Donagh Herlihy as Global Chief Digital and Information Officer in May 2021, describing the role as supporting worldwide digital transformation.²⁰

• Subway appointed Jonathan Fitzpatrick as CEO effective 28 July 2025.²¹

• Subway’s current leadership page identifies Asher Perlmutter as Chief Technology and Commercial Officer.²²

• The cited digital-transformation announcement and current leadership materials do not identify an Israeli R&D, engineering, innovation, or accelerator operation.^{20, 22}

• Roark describes itself as an Atlanta-based private-equity firm focused on consumer and business-service companies.²³

• Roark identifies Neal Aronson as founder, managing partner, and an Investment Committee member, and identifies Stephen D. Aronson as Managing Director, General Counsel, and an Investment Committee member.^{24, 25}

• Roark’s current team page identifies Max Mudd as involved in Roark’s Subway investment and identifies Roark-level IT/CISO and cybersecurity-architect roles; these disclosures do not establish that Roark cybersecurity staff operate Subway systems or that Subway uses a particular security vendor.²⁵

• Forbes reported in March 2026 that Neal Aronson remains Roark’s majority owner; this is third-party reporting rather than a Roark ownership filing and does not disclose ownership percentages or governance rights in the Roark-managed funds that own Underground Purchaser.²⁶

• Subway is privately held through Roark-managed investment funds; no Subway public-company 10-K, 20-F, proxy statement, or SEC beneficial-ownership filing was identified.^{1, 3}

• No public evidence identified of Subway or Roark acquisitions of Israeli technology companies, investments in Israeli technology startups or funds, or patent or co-development arrangements with Israeli-domiciled entities or research institutions.^{3, 23, 2, 25}

• No public evidence identified, in the bounded research, of equity stakes, board roles, or personal investments by Subway’s named executives, Neal Aronson, Stephen D. Aronson, or identified Roark personnel in Israeli surveillance, cyber, AI, SIGINT, or military-technology firms.^{24, 26, 25}

• Subway’s public materials identify Subway IP LLC as an owner of globally registered Subway trademarks and describe Franchise World Headquarters, LLC as a provider of core business services to Subway Group entities.⁷

• Subway International Holdings B.V. is identified in Subway Australia’s 2023 modern-slavery statement as part of the global Subway group, while the document alone does not independently confirm the current ownership status of the local Australian entity.²⁷

Civil Society Scrutiny & Regulatory History

• The supplied document-scoped pre-scan reported no Subway hit in the specified OHCHR settlement-database iterations, A/HRC/59/23, and identified NGO and company-list materials; this does not establish database-wide absence.^{16, 17, 18}

• The 2023 OHCHR database update covers a review period from 1 August 2019 through 31 December 2022 and assesses the activity categories set out in Human Rights Council resolution 31/36; its scope does not support treating a no-hit as proof of no settlement nexus outside that period and those activities.¹⁶

• The BDS Movement’s 30 November 2024 priority-target guide was among the supplied full-text-checked materials and provides no Subway-specific technology allegation in that edition; this is a source-scoped finding only.¹⁷

• The supplied review found no Subway mention in the specified Don’t Buy Into Occupation reports, and no underlying primary source was identified linking Subway, Roark, or a named Subway group entity to the settlement activity addressed by those reports.¹⁶

• No public evidence identified of an NGO, academic, or UN publication specifically documenting Subway technology provision to the Israeli state or operations in occupied territories.^{16, 17, 18}

• No public evidence identified of technology-specific boycott or divestment campaigns, regulatory inquiries, legal challenges, export-control actions, or sanctions-related investigations concerning Subway services to Israeli state entities or occupied territories.^{16, 17, 18}

• No public evidence identified of post-19 July 2024 or post-November 2024 continuation of a verified Subway technology provision to Israeli state bodies, settlements, or occupied territories; this conclusion is limited to the relationships documented in the reviewed materials.^{16, 17, 18}

• Subway’s available public disclosures identify selected customer-experience, POS, and research vendors but do not disclose its current infrastructure architecture, cloud providers, hosting locations, data-residency controls, security-vendor inventory, subprocessor list, or the processing arrangements of independently owned franchisees.^{9, 12, 13, 14, 8}