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Under this Privacy Notice, we, Essilor Ltd, inform you what personal data of yours we collect when you visit our website or use our services, why we collect it, and what we do with it.
Your personal data means any information relating to you, in particular your name and contact details such as your home address, your telephone number or your email address. Please take the time to read this Privacy Notice carefully. It is very important that you fully understand how we process your personal data and how we protect your privacy. If you have any questions regarding our use of your personal data, you can of course contact us using the contact details provided below.
Our contact details are:
The contact details of our Data Protection Officer are:
When you access our website, we automatically collect and store some of your data in our server logs and in cookies, which are small files we send to your computer when you visit our website.
This data does not allow us to identify you directly. However, we do record data related to your browsing on our website, such as the pages that you accessed, the date and time you accessed these pages, your search queries, information on your device (hardware model, operating system version, unique device identifier, Internet protocol address, hardware settings, browser type, browser language), the date and time of your request and referral URL.
The provision of your personal data is not required if you only want to visit our website. This means that you may refuse to accept cookies by configuring your web browser accordingly (for more information, refer to the ‘help’ section of your web browser). However, refusing cookies is likely to disrupt your navigation on our website, in particular by preventing you from accessing certain parts of it.
Some of the services offered on our website require you to sign up. If you want to use these services, we will ask you to provide us with personal data. Please provide us with complete and accurate data, and also inform us if your data needs to be updated. If you do not provide us with complete and accurate data, or if you do not inform us that your data needs to be updated, we may not be able to provide you with the services you requested.
We only use your personal data within the limits authorised by the laws and regulations. Sometimes, we may use your personal data because the laws and regulations require us to do so. In any case, we do not make any automated decisions based solely on automatic processing which may produce legal effects on you, or similarly significantly affect you.
We use your personal data for the following purposes:
TYPE OF DATA
The period for which we store your personal data is shown in the table below:
Please note that we may share your personal data with companies, ECP’s partners, organisations, public authorities or individuals outside of Essilor Ltd. If some of the recipients are outside the EU/EEA: some of the recipients of the data are located in countries outside the European Union/European Economic Area.
CATEGORY OF RECIPIENTS
We have measures in place to protect your personal data against unauthorized access, use, or disclosure including, without limitation, the following measures:
Under applicable data protection laws and regulations, you have the right to:
We are committed to enabling you to exercise your rights and, to do so, you can contact us using the contact information set out at the beginning of this Privacy Notice. Please provide us with the following information, so that we can act on your request with all due consideration:
If you are not fully satisfied with our response, you can also complain about our processing of your personal data to the relevant data protection authority.
We regularly review our compliance with our Privacy Notice, in particular, to ensure that it complies with new laws and regulations regarding data protection. But, although this Privacy Notice may change from time to time, we will not reduce your rights under this Privacy Notice without your explicit consent.
For Eye Care Professionals (« ECPs ») :
For consumers :
Legal reminder: the controller is the person who determined the means and purpose of the processing. The processor is a person collecting personal data for the use of the controller. The processor acts under the authority and control of the controller and on the basis of its instructions.
The controller for the personal data is :
Whether it is a controller or a processor, Essilor Ltd takes appropriate measures to ensure the protection and confidentiality of the Personal Data it holds or processes.
We do not collect any Sensitive Category of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
For ECPs :
Essilor Ltd relies on your consent to process your personal data. You do not have to provide your consent and you can withdraw your consent at any time.
We need your consent in the following cases:
If you do not provide your consent for Essilor Ltd to process your personal data for a specific service that is offered under the lawful basis of your consent then we might not be able to provide that service to you in full.
Where Essilor Ltd is relying on your consent to process your personal data, you have the right to withdraw your consent at any time. If you are unsure how to withdraw your consent please contact the following address: firstname.lastname@example.org
You can only withdraw your consent for data processing operations for which Essilor Ltdrelies on consent to process the data. You have the following different rights regarding the personal data that may be processed:
If you wish to exercise your rights please contact the following address: email@example.com
Essilor UK_Exhibit Essilor affiliates appointment-tool.pdf
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You can ask us or third parties to stop sending you marketing messages at any time by emailing us. You can also manage your email preferences and unsubscribe at any time by clicking unsubscribe at the bottom of our emails.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service experience or other transactions.
We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
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. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for [six] years after they cease being customers for [tax] purposes.
Time of the contractual relationship
3 months after the end of the survey
In some circumstances you can ask us to delete your data: see [your legal rights] below for further information.
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
If you wish to exercise any of the rights set out above, please contact the following address: firstname.lastname@example.org.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. Giving your consent means that is any free, specific, informed and unambiguous manifestation of your will by which you accept, by a declaration or by a clear positive act, that personal data concerning you may be processed.
Public interest mission means that data processing is carried out by public authorities for the purpose of carrying out their tasks.
Safeguarding the vital interests of the person means that the processing is necessary to protect the vital interests of the data subject or of another natural person, in the event that the data subject is physically or legally incapable of giving his consent.
Internal Third Parties refer to other companies in the Essilor Group acting as joint controllers or processors and who are based in France and provide IT and system administration services and undertake leadership reporting.
External Third Parties refer to :
Postal address: Essilor Ltd, Cooper Road, Thornbury, BS35 3UW, UK You have the right to make a complaint at any time to the Court of England and Wales.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Luxottica uses an augmented reality application feature on your device to show you the right fit and look of the frames you select. Any information gathered will be stored on your device and will not be shared nor stored by Luxottica.
FOR USERS IN THE EUROPEAN UNION (“EU”)
Under the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), individuals in the EU are afforded specific rights with respect to their “Personal Data” as defined under the GDPR. For the purposes of this Policy, Luxottica Group S.p.A (“Luxottica,” “we,” “our,” or “us”), with a registered office in Piazzale Luigi Cadorna, 3, 20123 Milan, Italy, operates as a data controller.
We have appointed a Data Protection Officer that can be contacted at the email address: email@example.com.
This Policy describes how the websites that link to this Policy (collectively “Sites”), as well as the Face Scanning App (“FSA”), or our in-store Face-Scanning Kiosk (“Kiosk”) and certain other technological services aimed at providing you with a customized experience (e.g. Frame Advisor, Size Advisor) as described below (collectively, the “Platforms”) collect, use, and generally process data about you.
It is understood that the Virtual Mirror ("VM") experience is excluded from the abovementioned Platforms. The experience does not involve any processing of personal and/or special data (including biometric data), as it takes place exclusively on the user's device in real-time mode. Therefore, to participate in the VM experience, consent to processing is not required and any information uploaded to the user's personal device will not be shared with Luxottica.
We process your Personal Data, which is collected directly from you, whether you access the Platform through one of our websites, the mobile application, or an in-store kiosk. The Personal Data you provide is outlined in the categories of personal data listed below:
i. Personal Data provided during the Platform experience (first and last name, email address, phone number, face shape, face dimensions, and other information directly provided by you);
ii. Your image that is provided when you take part on the virtual technology features of our Platforms;
iii. Data derived from your image or from your Biometric Data (face shape, eye color, hair, skin tone);
Hereinafter, point a), b), c) will be referred to as “Personal Data”
iv. “Biometric data” means anything that relates to the measurement of your physical features and characteristics (in particular, your face measurement, starting from your interpupillary distance);
Hereinafter, Personal Data and Biometric Data will be jointly referred to as “Data”.
We process your Personal Data for the following purposes, based on the following legal basis:
a) The Platforms allow you to use an online service capable of simulating lenses and eyeglasses onto photos. Your image will be uploaded and then, based on the characteristics of your facial shape, the Platforms will provide you recommendations with your image results (the “virtual technology feature”). Such data processing activities are performed to provide you with the products and services required (including any registration of such Personal Data within your online account if you require us to do so). The legal basis for the data processing aforementioned is the execution of a contract pursuant to art. 6 par. 1 lett b). If you do not want your Personal Data to be processed for such purposes, it will not be possible for us to provide the required products and services.
b) To provide you with the services required, we could process your Biometric Data, derived from the scanning of your face through one of our Platforms. Such Platforms will detect your interpupillary distance and consequently derive from it the other facial measurements. Any collection of biometric identifiers and biometric information is for the sole purpose of providing you with the frame suggestions (Suggestions) based on your facial features, assisting you in viewing how certain eyeglasses may look on your face. We will not disclose or disseminate any biometric information to any entity, other than those contracted parties that assist us in providing this service to you.
Biometric data can be processed by us only with your prior explicit consent pursuant to Article 9 par. 2 lett. a) of the GDPR. However, if you do not grant your explicit consent to the processing of your biometric data for this purpose, you will not be able to use the virtual technology feature and you will only be able to access the recommendations based on the answers you provided us with.
c) Except for Biometric Data. We process, with your prior consent, your Personal Data, for the following marketing purposes: (i) to send you the image and the product recommendations via email; (ii) to send commercial and promotional communications and periodical updates through the communication channels you provided us with related to our products, services, Platforms, initiatives, and events.
d) We will process your Personal Data to: (i) exercise or defend legal claims in court proceedings or in an administrative or out-of-court procedures relating to the rights of Luxottica, of its group companies and/or of their representatives, shareholders, officers and directors; (ii) enable the technical management of the Website and its operational functions, including solving any technical problems, to perform tests, updates and upgrades that cannot be performed through non-personal data; (iii) prevent or identify fraudulent activities or misuses of the Website or against the Luxottica group and/or the users of the Website; (iv) complete a potential merger, sale of assets, transfer of all or a material part of its business, or financing transaction by disclosing and transferring the Personal Data to the third party or parties involved in the transaction as part of the transaction; (v) conduct, surveys and market researches relating to Luxottica’s products and services by post, telephone or e-mail; (vi) anonymize Personal Data in order to perform statistical analysis.
The processing of your Data is carried out electronically and manually, and only within the limits necessary to pursue the purposes outlined above. All Data provided by users is kept on secure servers, adopting adequate security measures to protect Data from non-authorized access, to maintain the accuracy of Data and guarantee their proper use.
Your Data will be accessed by our service providers (hosting and infrastructure service providers, etc). Each service provider will act as a data processor, by virtue of a specific agreement in place per Article 28 of the GDPR. We will process your Personal Data in countries outside the European Union, when necessary to provide you with the services mentioned above and will ensure that the data transfer complies with Article 48 of the GDPR.
We retain your Data for the time strictly necessary to achieve the purposes for which they was collected and further processed, including any retention period required under applicable laws, including GDPR.
With specific regard to the Biometric Data, they will be deleted within 24 hours from the time of the collection. However, in case you ask us to save your experience, suggestions and/or the image in your account, we will retain your Biometric Data for six months from the last access or until you delete your take or the online account.
Please understand that when you request your image via email through the virtual technology feature, and you did not previously asked us to save that image into your profile, we will only temporarily store your image to provide your chosen service.
For marketing and profiling purposes, Personal Data will be processed for seven years from the last purchase and/or from the last contract with you (e.g. subscription to a prize competition, participation to an event, opening of a newsletter), notwithstanding the right to withdraw the consent provided or object to the processing at any time.
You can exercise any of the following rights, subject to verification of your identity, by submitting a request on https://privacy.luxottica.com
a) Access: You may request a copy of the Personal Data our Platform databases currently contain.
b) Automated Processing & Decision-Making: You may request that we stop using your Personal Data for automated processing, such as profiling. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, including withdrawing your consent to the processing of your Personal Data.
c) Correction or Rectification: You may request to correct what Personal Data our Platform databases currently contain. We may not accommodate a request to change Personal Data if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.
d) Restrict Processing: When applicable, you may restrict the processing of your Personal Data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, including withdrawing your consent to the processing of your Personal Data. Where applicable, we will ensure such changes are shared with trusted third parties.
e) Object to Processing: When applicable, you have the right to object to the processing of your Personal Data. When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your Personal Data. Where applicable, we will ensure such changes are shared with trusted third parties.
f) Portability: Upon request and when possible, we can provide you with copies of your Personal Data. When such a request cannot be honoured, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, including withdrawing your consent. Where applicable, we will ensure such changes are shared with any trusted third parties.
g) Withdraw Consent: At any time, you may withdraw your consent to our processing of your Personal Data through the Platforms. Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your Personal Data. Where applicable, we will ensure such changes are shared with trusted third parties.
h) Erasure: If you should wish to cease use of our Platforms and have your Personal Data deleted from our Platforms, then you may submit a request. Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your Personal Data has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties.
The Data Controller of your Personal Data is Luxottica Group S.p.A., with a registered office in Piazzale Luigi Cadorna, 3, 20123 Milan, Italy.
Should you have questions or comments on this Policy, or any data processing carried out by Luxottica, you may contact Luxottica at firstname.lastname@example.org.
Last modified: 09/02/2023