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Last updated: 10/04/2024
At EssilorLuxottica, we are committed to protect our clients’ Personal Data.
Upholding this commitment is essential to our success and reputation, and ultimately our ability to fulfil our mission of helping people see more, be more and live life to its fullest.
MyOptique Group Limited, with registered office at Level 2, The Kensington Building, 1 Wrights Lane, London W8 5RY United Kingdom, a company registered in England and Wales under company number 05139004, as part of EssilorLuxottica Group (hereinafter “Glasses Direct”)
Where Glasses Direct is the party that determines the purposes and the means of the processing, we are the Data Controller over your Personal Data.
Anyhow, in certain specified instances, Glasses Direct is joint controller with other entities over the processing of your personal data: this means that we are jointly responsible with them for deciding on the purposes and the means of the processing. In such instances, we conclude Joint Controllers Agreements and notify you about it in this Privacy Notice.
More specifically, we are in a joint controlling relationship over your Personal Data with Luxottica Group S.p.A., with registered office at Piazzale Cadorna no. 3 – 20123 Milan, Italy, as a part of EssilorLuxottica Group (“Luxottica”).
(hereinafter Glasses Direct and Luxottica are jointly referred to in as “EssilorLuxottica”).
For further details on the essence of the Joint Controlling Agreement in place with the above entity, you can contact us at the address set out in Section 8 of this Privacy Notice.
EssilorLuxottica, its Affiliates and its 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 can collect from the various contact you may have with us (e.g. 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 Notice at any time but if we do so, we will provide you with an updated copy of this Privacy Notice as soon as reasonably practical.
We may provide 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.
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 encourage you to review the privacy notices of those third parties before connecting.
Likewise, this Privacy Notice will apply to the following Data Subjects:
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:
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.
Certain categories of Personal Data we process for the purposes set out below, are qualified as “sensitive” Personal Data. This particularly the case of the Health, as described above, that we may process.
However, we only process such sensitive data because:
However, if you don’t grant your explicit consent to the processing of your Health Data, you will not be able to benefit from the services describe above in stores and through the Sites and the Services.
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:
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 Sites 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-authorised access, to maintain the accuracy of Personal Data and guarantee the proper use of information.
Furthermore, a secure system for authorizing credit & debit card payments and identifying fraudulent activities is used. We use the standard SSL (Secure Sockets Layer) to protect the confidentiality of your Personal Data.
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 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 law and/or in other circumstances with your consent.
We may also share your information for our internal business purposes.
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, payment, 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 and Article 28 of the UK GDPR as applicable, 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 Users Personal Data:
- in the event that we sell any business or assets, in which case we may disclose Users 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, Users 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) 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.
d) Other instance
Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Furthermore, we may ask if you would like to disclose your information with other third parties who are not described elsewhere in this Privacy Notice. 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 for 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. A complete list of data processors is available, upon request to us, through the modalities as per this Privacy Notice.
Given the presence of EssilorLuxottica in many countries around the world and in order to provide you with personalised 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, 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 and/or Articles 44 et seq. of the UK GDPR.
For further information with regard to 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.
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 Notice, 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 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 requirements(for example, the identity Data – including Ophthalmic Prescription and Medical Data – is retained for 10 years, in line with the requirements of the General Optical Council).
In any case, please note that, as general rule, within EssilorLuxottica, retention and archiving of Personal Data will not exceed ten (10) years overall calculated as of the first record, which is a maximum in EssilorLuxottica exception made for legal hold obligations.
In some circumstances we may anonymise 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.
EssilorLuxottica 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. EssilorLuxottica has taken steps to eliminate duplicate copies of data and to facilitate updating of data that may change over time.
EssilorLuxottica regards the protection of Personal Data as an essential priority.
In this respect, EssilorLuxottica has 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 trainings. 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.
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 Notice, 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 Notice, 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 have been deleted.
f) Right to data Portability
Upon request and when possible and where applicable by local laws, we can provide to 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 Privacy Notice, 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 responds 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 refer to the following e-mail address: dpo@myoptiquegroup.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.
The Data Controller of the processing of your Personal Data is Glasses Direct, with its registered office at Veale Wasbrough Vizards, Narrow Quay House, Bristol BS1 4QA United Kingdom.
Should you have questions or comments on this Privacy Notice or on any data processing carried out by Glasses Direct, Glasses Direct may be contacted to the postal address above and through the e-mail address available in the previous paragraph.
Glasses Direct has appointed a Data Protection Officer, who can be contacted at the following email address dpo@myoptiquegroup.com.
You can also send an email to the above email address in case of any question related to this document.
For legal and/or organizational reasons, this Privacy Notice may undergo changes. We suggest, therefore, to check this Privacy Notice 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 Notice.
In any case, an updated version of the Privacy Notice will be always available on the Sites and the services, and we will provide additional notice to you if we make any changes that materially affect your privacy rights.
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