Under this Privacy Notice, we, EssilorLuxottica, acting as a ‘data controller’, 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 are processing your personal data and how we are protecting your privacy.
Our contact details are: EssilorLuxottica, 147 rue de Paris, 94220 Charenton-le-Pont, France.
If you have any question regarding our use of your personal data, you can of course contact us at email@example.com.
WHAT PERSONAL DATA WE COLLECT
Data we collect when you visit and browse our website
When you browse our website, we automatically collect and store some of your IT data in our server logs and in cookies, which are small files we sent to your computer when you visit our website.
This IT data does not allow us to directly identify you; however, it records data related to your browsing on our website, such as the pages that you accessed, the date and time you accessed to 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.
Data we collect when you use the services offered on our website.
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, and we thank you for providing us with complete and accurate data, and also to 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 collect the following categories of your personal data:
- Identification data: including your name, company, job status / profile and e-mail address.
- IT data, including data related to your browsing on our website, such as the pages that you accessed, the date and time you accessed to these pages, your search queries, information on your device (hardware model, operating system version, unique device identifiers, Internet protocol address, hardware settings, browser type, browser language), the date and time of your request and referral URL.
HOW WE USE PERSONAL DATA WE COLLECT
We only use your personal data within the limits authorized by the laws and regulations. Sometimes, we shall use your personal data because the laws and regulations require us to do so. In any case, we do not make any automated decisions solely on automatic processing which may produce legal effects concerning you, or similarly significantly affect you.
We use your personal data for the following purposes:
- We use your identification data to enable you (i) to participate in initiatives and events via the website (for example: Annual Shareholders’ meeting webcast), (ii) to contact us via the website, (iii) to make any other request you may have. Such a process is based either on a contract executed between us or, if we are not in a contractual relationship, on your consent to our processing of your personal data.
- We use your IT data (i) to ensure the technical management of the website (including solving technical issues, ensuring technical security, improvement), (ii) for analytics and other statistical purposes. Such a process is based on your acceptance of our Cookies Policy.
HOW LONG WE KEEP PERSONAL DATA WE COLLECT
The period for which we store your personal data is shown in the table below:
|Category of data||Retention period|
|Identification data||Up to 5 years|
|IT data||13 months from collection|
Unless otherwise require by statutory retention laws.
PERSONAL DATA WE SHARE
We inform you that we may share your personal data with:
- Others companies of the EssilorLuxottica Group;
- Companies, organizations, public authorities or individuals outside of the EssilorLuxottica Group (e.g. hosting providers, market and analyst service providers, webcast providers, database management and maintenance services).
Some of these recipients of the data may be located in countries outside the European Union/European Economic Area.
For recipients located in the countries indicated at the following link (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en), the European Commission has decided that this country ensures an adequate level of protection by reason of its domestic law or of the international commitments it has entered to.
For recipients located outside the abovementioned countries, there is no adequacy decision by the European Commission; this means that the level of data protection in such country is not comparable with the level of data protection in the European Union. Therefore, we use as an appropriate safeguard to secure your personal data such as the EU Standard Contractual Clauses.
Companies and other organizations that process your personal data on our behalf are expressly appointed as Data Processor.
HOW WE PROTECT PERSONAL DATA
We have measures in place to protect your personal data against unauthorized access, use, or disclosure, including without limitation:
- We implement and maintain sophisticated technical measures to ensure that your personal data is recorded and processed in complete confidentiality and security.
- We implement and maintain appropriate restrictions on access to your personal data, and monitoring of the access, use, and transfer of personal data.
- All of our employees who have access to your personal data are required to enter into non-disclosure or similar agreements, which imposes obligations on them to comply with our data privacy and confidentiality requirements.
- We require any business partners and third party service providers with whom we may share your personal data to comply with any applicable data privacy and confidentiality requirements.
- We provide data privacy training on a regular basis to our employees and third parties who have access to personal data.
WHAT RIGHTS YOU HAVE
Under applicable data protection laws and regulations, you have right:
- Of access to, rectification of, and/or erasure of your personal data;
- To restrict or object to its processing;
- To tell us that you do not wish to receive marketing information;
- In some circumstances, to require certain of your personal data to be transferred to you or a third party
- To the extent our processing of your personal data is based upon your consent, to withdraw your consent, without affecting the lawfulness of our processing based on your consent before its withdrawal.
We are committed to enable you exercising your rights: to do so, you can contact us at the details set out at the beginning of this Privacy Notice. Please provide us with the following information, so that we can take your request with all due consideration:
- Your name and surname, and a photocopy of your identity card;
- Your specific petition (in other words, what rights you want to exercise); and
- The date of the application and your signature (if you sent your application by postal mail).
If you do not get satisfaction by contacting us, you can also lodge a complaint about our processing of your Personal Data with a data protection authority.
CHANGES TO THIS PRIVACY NOTICE
We regularly review our compliance with our Privacy Notice, in particular to make it compliant with new laws and regulations regarding data protection. But, even if this Privacy Notice may change from time to time, we will not reduce your rights under this Privacy Notice without your explicit consent.
© EssilorLuxottica 2021