PRIVACY NOTICE
Essilor International and your Personal Data
Understanding why and how Essilor International processes your Personal Data
1. INTRODUCTION
Essilor International, a public limited company under French law with its head office located at 147 rue de Paris, 94220 Charenton-le-Pont, FRANCE, registered in the Créteil Trade and Companies Register under number
439 769 654, as a part of EssilorLuxottica Group; EssilorLuxottica is a global leader in the design, manufacture and distribution of ophthalmic lenses, frames and sunglasses.
What is the purpose of this Privacy Notice?
We, our Affiliates and our Brands, attach particular importance to the processing, confidentiality and security of your Personal Data.
The purpose of this Privacy Notice is to inform you in a clear, simple and complete manner of the processing carried out on the Personal Data that you provide to us, or that each of our Affiliates/Brands can collect from the various contacts you may have with us (e.g. store, customer care, Sites, Services, events, social networks, etc.), their possible transfer to third parties as well as your rights and the options you have to control your information and protect your privacy, in accordance with the Applicable Legislation.
We may update this Privacy Notice at any time but if we do so, we will make available to you an updated copy of this Notice as soon as reasonably feasible.
We make available to you different or additional privacy notices in connection with certain activities, programs, and offerings.
We may also provide additional “just-in-time” notices that may supplement or clarify our privacy practices or provide you with additional choices regarding your Personal Data.
2. WHERE ARE THE PERSONNAL DATA COLLECTED FROM?
The Personal Data we collect depends on the point of contact through which you interact with us, as well as the purposes of this interaction as described in this Privacy Notice and are also limited to those which are relevant and appropriate for this interaction.
We use different methods and various sources to collect data from and about you. We collect and obtain information:
a) Provided directly by you: During the registration process, the creation of an account on the Sites and/or the Services, or when completing a purchase order or join our engagement programs, prize competitions and events and when you contact us for request, feedback or complaint. Under certain conditions, we also keep records of customer services calls and maintain a transcript of chats for quality assurance and quality management.
b) Using automatic tracking systems: We use some technologies (e.g. cookies and automatic tracking systems) that automatically collect certain items of information relating to the way in which you utilize the Sites and the Services. For further information on the use of Personal Data collected through automatic tracking systems, please read carefully our Cookie Policy available.
3. WHAT PERSONAL DATA MAY WE PROCESS ABOUT YOU?
The Personal Data we collect depends on the point of contact through which you interact with us, as well as the purposes of this interaction as described hereafter in this Privacy Notice and are also limited to those which are relevant and appropriate for this interaction.
Our Sites include links to websites and/or applications operated and maintained by third parties. Please note that we have no control over the privacy practices of websites or applications that we do not own. EssilorLuxottica encourages you to review the privacy notices of those third parties.
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Identification information
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Including such as name and surname, e-mail address, gender, date of birth, country of residence, postal address and phone numbers |
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Marketing and Communications Data |
Including your preferences in receiving marketing communications from us, your communication preferences and information contained in any correspondence or requests sent by you to us or asked to you by us if problems with the Sites, the Services or purchased products are reported. |
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Navigation information |
Including information regarding your interactions with our Sites, our Services, emails, products or advertisements and statistical data relating to these interactions. |
4. WHY DO WE PROCESS YOUR PERSONAL DATA?
We are required to use your data for purposes defined according to the nature of our relationship. Thus, depending on the context in which your data is collected, it may be used for one or more of the following purposes:
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Communication between us |
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Analyses purposes |
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Legitimate interests’ pursuit |
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5. HOW DO WE PROCESS YOUR PERSONAL DATA?
What modalities do we use to process your personal data?
The processing of your Personal Data is carried out, electronically and manually, only within the limits necessary to pursue the purposes outlined above.
We undertake to protect your Personal Data.
All Personal Data provided by you is kept on secure servers, adopting adequate security measures to protect Personal Data from non-authorized access, to maintain the accuracy of Personal Data and guarantee the proper use of information.
Furthermore, a secure system for authorizing credit card payments and identifying fraudulent activities is used. We use the standard SSL (Secure Sockets Layer) to protect the confidentiality of your Personal Data.
We share your Personal Data with other Affiliates of the Group
EssilorLuxottica is a global organization with offices and operations throughout the world and most of your Personal Data relating to is stored and processed within a range of global applications that is used globally by the Affiliates of EssilorLuxottica. The majority of the processing of your personal data is carried out through the concentrated services of two entities: Essilor International and Luxottica Group S.p.A.
We may share your Personal Data with certain Affiliates or Brand of the EssilorLuxottica group, based on your preferences and interests about these Affiliates or Brand, for the purposes set out in this Privacy Notice, in each case in or outside your country, as permitted and required by Applicable Legislation and/or in other circumstances with your consent.
Is your Personal Data transferred to third parties?
We may also disclose your Personal Data:
a) Sale or merger
– in the event that we sell any business or assets, in which case we may disclose your Personal Data to the prospective purchaser of such business or assets; or
– if we sell, buy, merge with, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, your Personal Data may be among the transferred assets.
We may share all the information we collect in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sales, or in the unlikely event of bankruptcy.
b) Legal process
We may disclose your Personal Data to any authority, court, administrative body, or other authorised third party (including, without limitation, counsel), where the disclosure of Personal Data is required by law, regulation or court order or where such disclosure is necessary for the protection and defense of our rights.
c) Other instance
We may ask if you want to disclose your information with other third parties not described elsewhere in this Privacy Notice. Furthermore, we do not sell, rent, or lease your Personal Data to third parties.
The abovementioned recipients will process your Personal Data as data controllers, data processors or persons in charge of processing, depending on the circumstances.
A complete list of data processors is available, upon request to us, through the modalities as per this Privacy Notice.
Is your Personal Data transferred across the border?
Given the presence of EssilorLuxottica in many countries around the world and in order to provide you with personalized service worldwide, some of your data may be collected, accessible or stored outside your country of residence.
Due to the above, your Personal Data may be accessed and/or transferred to countries which do not have equivalent data protection laws to those required within the European Economic Area (EEA).
In such cases, EssilorLuxottica ensures that, at all times, appropriate safeguards are implemented to ensure that your Personal Data is processed in accordance with Applicable Legislation. In this respect, where your Personal Data is processed by another EssilorLuxottica entity, the safeguards are based on the commitments taken on the basis of (ii) a dedicated transfer agreement binding upon the EssilorLuxottica entity involved in the processing and (ii) a set of common rules applicable through the EssilorLuxottica Group Data Protection Policy.
Where your data is processed by EssilorLuxottica entities or third parties located outside the European Economic Area, EssilorLuxottica ensures that specific contractual protection is implemented to ensure that this requirement is addressed in accordance with the applicable legislation as per Articles 44 et seq. of the GDPR.
For more information about the appropriate or suitable safeguards and the means by which to obtain a copy of them, you can contact us with the modalities as per this Privacy Notice.
For how long do we retain your Personal Data?
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For as long as necessary to carry out each of the purposes mentioned in this Privacy Notice, including for the purposes of satisfying any legal, accounting, or reporting requirements.
We keep your data safe, updated and accurate. We have a responsibility for the security and accuracy of the Personal Data that we process about you and also for keeping data up to date. We have taken steps to eliminate duplicated copies of data and to facilitate updating of data that may change over time.
6. HOW DO WE PROTECT YOUR PERSONAL DATA?
We regard the protection of Personal Data as an essential priority.
In this respect, we have implemented appropriate measures and safeguards to protect the Personal Data it processes.
This is reflected in EssilorLuxottica’s procedures described in the EssilorLuxottica Group Data Protection Program, guidelines and policies and in the actual measures implemented throughout the Group.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality. These measures range from technical security measures that protect IT systems to the physical security measures employed at EssilorLuxottica sites. EssilorLuxottica also requires its staff to participate in information security and Data Protection training. Details of these measures may be obtained from the Group Information Security Department.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. YOUR RIGHTS
You can exercise any of the following rights, subject to verification of your identity where necessary:
a) Right of Information and Access
b) Right to Rectification
c) Right to Restriction of the Processing
d) Right to Object to the Processing
e) Right to Erasure
f) Right to data Portability
g) Right to Withdraw your Consent
h) Right to lodge a complaint with the relevant data protection supervisory authority
To exercise your rights, please contact:
[privacy@essilorluxottica.com]
8. HOW CAN YOU KEEP TRACK OF CHANGES TO THIS PRIVACY NOTICE?
For legal and/or organizational reasons, this Privacy Notice may undergo changes. We suggest, therefore, checking this Privacy Notice regularly and referring to the latest version of it, we will post the date it was last updated at the top of this Privacy Notice.
In any case, an updated version of the Privacy Notice will be always available on the Sites and the Services, and we will make available additional notices to you if we make any changes that materially affect your privacy rights.