PRIVACY POLICY
What is the purpose of this Privacy Policy?
EssilorLuxottica, its Affiliates and its Brands, attach particular importance to the processing, confidentiality and security of your Personal Data.
The purpose of this Privacy Policy 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. can collect from the various contact 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 Personal Data and to protect your privacy, in accordance with the applicable legislation.
We may update this Privacy Policy at any time but if we do so, we will provide you with an updated copy of this Privacy Policy as soon as reasonably practical.
We may provide different or additional Privacy Policy 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.
Our Website may 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. Sunglass Hut encourages you to review the Privacy Policy of those third parties before connecting.
What is this Privacy Policy about? Key definitions
AFFILIATES
Means subsidiaries of EssilorLuxottica Group, its ultimate holding company and its subsidiaries, or companies that it controls, are controlled by or under common control, and its service providers and strategic business partners
BRANDS
The brands owned by the companies belonging to EssilorLuxottica Group
DATA CONTROLLER
Means the natural or legal person, department or organisation, alone or jointly with others, determines the Purposes and means of the Processing of Personal Data
DATA PROCESSOR
Means a natural or legal person, department or other body which processes personal data on behalf of and on the instructions of the Data Controller
ESSILORLUXOTTICA GROUP (OR, SIMPLY, ESSILORLUXOTTICA OR GROUP)
EssilorLuxottica as global organization, i.e. jointly EssilorLuxottica (as ultimate holding company) and all its Affiliates
GDPR
Regulation (EU) 2016/679 (General Data Protection Regulation)
PERSONAL DATA (OR SIMPLY DATA)
Any information about an individual (the Data Subject) from which that person can be identified (name, contact details, identification number, etc.). The categories of Personal Data that we may process are enumerated in this Privacy Policy.
PROCESSING (OF PERSONAL DATA)
Any action conducted concerning your Personal Data such as, the collection, recording, organization, storage, modification, transfer, deletion, access, consultation, etc. of such data.
PURPOSE
Refers to the Purpose of the Processing. In other words, the reasons for which the Personal Data is collected.
RECIPIENTS (OF THE PERSONAL DATA)
A natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not.
Likewise, this Privacy Policy will apply to the following Data Subjects:
CLIENTS
Clients who purchase products or services offered by Sunglass Hut.
WEB USERS
Users who access the website www.sunglasshut.com (the “Website”).
REGISTERED USERS
Users who have registered and created a personal account on the Website.
EYESIGHT CHECKS USERS
Users who have undergone an eyesight check (where the service is active).
MARKETING COMMUNICATION USERS
Users who have subscribed to receive marketing communications from Sunglass Hut.
SOCIAL MEDIA USERS
Users who voluntarily follow Sunglass Hut activity on social media.
Where are the personal 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 Policy 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 Website and/or the services, or when completing a purchase order or joining our engagement programs, prize competitions and events and when you contact us for request, feedback or complaint. We also record customer service calls and maintain a transcript of chats for quality assurance.
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 Website and the services. For further information on the use of Personal Data collected through automatic tracking systems, please read carefully our Cookie Notice available here.
C) THROUGH STORES VISITS AND OTHER OFFLINE TECHNOLOGIES
When you visit our stores, information may be collected during the purchase process, the adjustment of purchased products and eyesight checks that can be carried out in stores. We also use CCTV in our stores for safety, security, fraud, loss, prevention, and operational purposes.
D) FROM SOCIAL NETWORK PROFILE
If public and if you decide to log into the Website and/or the services through social network applications or to link your account to your public profiles available on social networks and share your actions through the Website and/or the services on those channels via the corresponding plug-ins (e.g., Facebook Connect, I like, fb share, etc.). The use of the said plug-in entails sharing the corresponding actions and information on the related social networks.
E) FROM OTHER SOURCES
We may obtain information about you from other sources, such as data analytics providers, marketing or advertising service providers, fraud prevention service providers, vendors that provide services on behalf of us, or publicity available sources. We create also information based on our analysis of the information we have collected from you.
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 Policy and are also limited to those which are relevant and appropriate for this interaction.
CATEGORIES OF PERSONAL DATA
CATEGORY OF DATA | TYPES OF DATA | DATA SUBJECT |
Identifiable information | Including such as name and surname, e-mail address, gender, date of birth, country of residence, postal address and phone numbers | Clients, Web Users, Registered Users, Eyesight Checks Users, Marketing Communication Users and Social Media Users |
Payment information | Including such as data related to your credit card for the purchase of products through the Websites and the services (payments are made via a secure platform, supplemented by control measures, including encryption of contact details) and details products which you have purchased from us | Clients and Registered Users |
Profile and Commercial data | Including such as account name, password, Personal Data published on your social network, billing and delivery addresses, details products and services which you have purchased from us (in store or online, including your order, tracking and invoices, amount and type of purchase) and your interests, preferences, feedback and survey responses | Clients and Registered Users |
Marketing and Communications Data | Including such as your preferences in receiving marketing 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 Website, the services or purchased products are reported | Registered Users, Clients and Marketing Communication Users |
Health and Medical Data (where applicable) | Including such as ophthalmic prescription, eye examinations, measurements (optical correction, pupillary distance, etc.), adaptations and information having an impact on your visual health and eyesight checks | Clients, Eyesight Check Users |
Data related to your care (where applicable) | Including such as the name of the complementary organization and the management platform, information related to the health coverage, the rate of care | Clients, Eyesight Check Users |
Device information | Including such as the IP address or other unique code of your device (computer, mobile or other devices), identification as registered user or not (login data), technical information that may include the URL from where you originate, time zone setting and location, browser information and language | Web Users and Social Media Users |
Navigation information | Including such as information regarding your interactions with our Website, our services, emails, products or advertisements and statistical data relating to these interactions | Web Users and Social Media Users |
Processing of Special Personal Data
Certain categories of Personal Data we process for the purposes set out below, are qualified as “sensitive” Personal Data, as they fall within the definition of special categories of Personal Data provided for by art. 9 of the GDPR (“Special Personal Data”). This is particularly the case of the Health and Medical Data and the Data related to your care, as described above, that we may process.
However, we only process such sensitive data because:
where it is required or allowed under local applicable legislation,
while implementing adequate safeguards to ensure the protection of such Special Personal Data, and when one of the alternative conditions set out at Article 9 of the GDPR is fulfilled.
However, please note that, when your explicit consent is required to process your Health and Medical Data and the Data related to your care and you don’t grant it to us, you will not be able to benefit from the services described above.
Why do we process your personal data?
We are required to use your data for purposes defined according to the nature of our relationships. Thus, depending on the context in which your data is collected, it may be used for one or more of the following purposes:
PURPOSES | DETAILS | LEGAL BASIS |
Follow-up and execution of your orders in shop and online, the after-sales services and supplementary services management | · Formalise a quotation | EXECUTION OF A CONTRACT |
Transaction and potential unpaid invoices management | · Carry out secure online and in-store payments (with reference to invoicing obligations) | EXECUTION OF A CONTRACT |
Account creation and management | · Allow you to register to our Website and create your own account | EXECUTION OF A CONTRACT |
Inscriptions management | · Permit you to join our engagement programs, including the loyalty program; receiving commercial and promotional communications in the context of the loyalty program | CONSENT |
Communication and interactions between us | · Send you commercial and promotional communications and periodical updates (e.g., via e-mail, phone, SMS/MMS, WhatsApp and/or any other messaging tool from mobile, postal service, web platforms and social network and newsletter) related to our products, services, initiatives and events | CONSENT |
Eyesight checks performance | · Allow you to benefit from the eye examination service provided by your optician (manage the scheduling of appointments, prescriptions, etc.) and carry out all the eyes and/or face measurements needed for the manufacture and supply of the products | CONSENT |
Virtual eyewear trial software use | · Offer you virtual try on services whereby you can virtually try on its sunglasses or eyeglasses through your computer, mobile or other devices, even the ones in our stores, by digitally adding frames to your image in real-time or to photos or videos of your face. | CONSENT |
Legal obligations compliance | · Comply with the requirements of the laws, regulations, protocols and national and EU legislation (including target medical device legislation) | LEGAL OBLIGATIONS |
Legitimate interests’ pursuit | · Send you commercial communications via e-mail on similar products, events and services already provided to you, unless you object to such a processing at the time of the collection and on the occasion of each communication | LEGITIME INTEREST |
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.
We advise that the password is one of the protection mechanisms of the account. Therefore, you are invited to use a password sufficiently secure and stored in a safe place, limiting access to it on their own computers and browsers, disconnecting it after having visited the Website and/or the services.
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 Policy, in each case in or outside your country, as permitted and required by applicable law and/or in other circumstances with your consent.
We may also share your information for our internal business purposes.
IS YOUR PERSONAL DATA TRANSFERRED TO THIRD PARTIES?
a) Service provider
We may disclose your Personal Data with our third parties service providers entrusted with processing activities that provide services or assistance and advice to us, with special – but not exclusive – reference to technology, accounting, administrative, legal, insurance, IT, marketing, customer service, data subjects requests management, data analysis matters.
Each service provider will act as a data processor, on behalf of and in accordance with the instructions received from us, by virtue of a specific agreement in place per Article 28 of the GDPR, which sets out its obligations and guarantees the implementation of appropriate technical and organizational measures to respect the Applicable Legislation and the protection of your rights.
We require that any such third-party provider is subject to strict control and implements appropriate guarantees of security and confidentiality of your Personal Data.
b) Sale or merger
We may also disclose your Personal Data:
- 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 of the information we collect in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
c) Third Party Social Network Service Providers
If you decide to log into the Website and/or the services through social network applications or to link your account to your public profiles available on social networks, and share your actions through the Website and/or the services on those channels via the corresponding plug-ins (e.g. Facebook Connect, I like, fb share, etc.), these third-party services may be able to collect information about you, including information about your activity on the Website or/and the services, and they may notify you connections on the third-party services about their use of the Website and/or the services. Their use of your Personal Data is not governed by this Privacy Policy but in accordance with their own data protection policies.
d) 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 defence of our rights.
e) Other instance
We may ask if you would like to disclose your information with other third parties who are not described elsewhere in this Privacy Policy. Furthermore, we do not sell, rent, or lease your Personal Data to third parties but we may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, without your consent, your Personal Data would not be transferred to the third party.
The abovementioned recipients will process your Personal Data as data controllers, data processors or persons in charge of processing, depending on the circumstances.
More info on the categories of data processors is available on request. Find out how to contact us.
IS YOUR PERSONAL DATA TRANSFERRED ACROSS THE BORDER?
Given the presence of EssilorLuxottica Group 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.
As a result of 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, Sunglass Hut 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, Sunglass Hut 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 further information regarding the appropriate or suitable safeguards and the means by which to obtain a copy of them, you can contact us. Please specify the type of data pertaining to your request.
FOR HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
We retain all or part of your Personal Data for the time strictly necessary for the reason:
(a) to meet applicable statutory requirements for data retention,
(b) to meet and comply with our legal and/or contractual obligations,
(c) for as long as necessary to carry out each of the purposes mentioned in this Data Protection Privacy Policy, including for the purposes of satisfying any legal, accounting, reporting requirements.
To determine the appropriate retention period for Personal Data, we consider jointly the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized 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.
In particular, we hereby specify that your Personal Data will be retained for a period of 10 years for our invoicing and accounting purposes, save for the circumstances in which applicable laws may provide for different retention requirements.
Furthermore, if you have consented to the processing of your Personal Data for marketing activities (e.g., commercial and promotional communications, commercial newsletters, personalized offers, periodical updates related to our products, services initiatives and events, etc.), such a Data will be retained for 10 years as from the last interaction as for customers and for 2 years from the last interaction as for prospects. Last interaction is defined as the last contact you made and that is traceable by our systems or salespersons.
In any case, please note that, as general rule, within EssilorLuxottica Group, retention and archiving of Personal Data will not exceed 10 (ten) years overall calculated as of the first record and/or consent renewal and/or any other relevant interaction, exception made for further legal hold obligations.
In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you, such as to carry out statistical analysis, monitor and/or enhance our medical devices, for R&D purposes, train AI models, etc.
For any additional information on the retention of your Personal Data, please feel free to contact us.
WE KEEP YOUR DATA SAFE, UPDATED AND ACCURATE
Sunglass Hut has a responsibility for the security and accuracy of the Personal Data that it processes about you and also for keeping data up to date. Sunglass Hut has taken steps to eliminate duplicate copies of data and to facilitate updating of data that may change over time.
How do we protect your personal data?
Certain categories of Personal Data we process for the purposes set out below, are qualified as “sensitive” Personal Data, as they fall within the definition of special categories of Personal Data provided for by art. 9 of the GDPR (“Special Personal Data”). This is particularly the case of the Health and Medical Data and the Data related to your care, as described above, that we may process.
However, we only process such sensitive data because:
where it is required or allowed under local applicable legislation,
while implementing adequate safeguards to ensure the protection of such Special Personal Data, and when one of the alternative conditions set out at Article 9 of the GDPR is fulfilled.
However, please note that, when your explicit consent is required to process your Health and Medical Data and the Data related to your care and you don’t grant it to us, you will not be able to benefit from the services described above.
Your rights
You can exercise any of the following rights, subject to verification of your identity where necessary:
A) RIGHT OF INFORMATION AND ACCESS
You may request the confirmation of the existence of your Personal Data and to be informed of its content and source and obtain a copy of those Personal Data which our databases currently contain.
B) RIGHT TO RECTIFICATION
You may request to rectify what Personal Data our 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.
C) RIGHT TO RESTRICTION OF THE PROCESSING
When applicable, you may restrict the processing of your Personal Data. When such restrictions are not possible, we will advise them accordingly. You can then choose to exercise any other rights under this Privacy Policy, including withdrawing your consent to the processing of your Personal Data.
D) RIGHT TO OBJECT TO THE PROCESSING
When applicable, you have the right to object to the processing of your Personal Data on grounds relating to your particular situation, if the processing is based on our legitimate interest. In addition, you have the right to object at any time to processing where Personal Data are processed for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing.
When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Policy, to include withdrawing your consent to the processing of your Personal Data.
E) RIGHT TO ERASURE
If you should wish to have your Personal Data deleted, then you may submit a request. Upon receipt of such a request for erasure, we will confirm receipt and confirm once your Personal Data has been deleted.
F) RIGHT TO DATA PORTABILITY
Upon request and when possible and where applicable by local laws, we can provide you with copies of your Personal Data. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Policy, including withdrawing your consent. Where applicable, we will ensure such changes are shared with any trusted third parties.
G) RIGHT TO WITHDRAW YOUR CONSENT
Where processing is based on consent, you may withdraw his/her consent at any time to the processing of your Personal Data. Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your Personal Data.
H) RIGHT TO LODGE A COMPLAINT WITH THE RELEVANT DATA PROTECTION SUPERVISORY AUTHORITY
If you are not satisfied with the way we process your Personal Data and/or respond to a request to exercise the rights you have exercised, you can lodge a complaint with the relevant data protection competent supervisory authority.
In order to exercise your rights, please use this Privacy Form.
Alternatively, you may also contact us at privacy@luxottica.com
Furthermore, we offer tools to you to update and amend your Personal Data. Indeed, every registered User may access his/her own information and update it (e.g., through User account).
Besides, it is also possible for you to modify and update your preferences on how you wish to receive e-mails or other communications from us. You may also request that your information on your account is deleted.
How can you contact us?
CONTACT OF THE DATA CONTROLLER
The Data Controllers over the processing of your Personal Data are set out in this section of the Privacy Policy.
Should you have questions or comments on this Privacy Policy or on any data processing carried out by us, we may be contacted at the postal address set out in this section above and/or at the email address specified in the section “Your Rights”.
CONTACT OF THE DATA PROTECTION OFFICER
Luxottica has appointed a Data Protection Officer which can be contacted at the following email address dpo@luxottica.com or through the contact methods provided above.
How can you keep track of changes to this privacy policy?
For legal and/or organizational reasons, this Privacy Policy may undergo changes. We suggest, therefore, checking this Privacy Policy regularly and to refer to the latest version of it, we will post the date it was last updated at the top of this Privacy Policy.
In any case, an updated version of the Privacy Policy will be always available on the Website and the services, and we will provide additional notice to you if we make any changes that materially affect your privacy rights.
