Subway is considered to be a tout sheet. At one time it didn't make proper disclosure, and was sued by the SEC for that.
Promoters occupy a middle ground: often they're the "third party" that pays touts like Subway. The promoter is, of course, hired by the company.
And then we have frontrunners like Green Baron. They buy stock and when they've established a position, they hype it. This is a sort of gray area; sometimes the SEC goes after people for frontrunning (Jonathan Lebed is one example) and sometimes they don't.