Privacy Policy

1. Who we are?
    

   Vision Direct Europe Ltd, with registered office at The Kensington Building, 1 Wrights Ln, London W8 5SF as part of EssilorLuxottica Group. 

   Where Vision Direct is the party that determines the purposes and the means of the processing,  EssilorLuxottica Group is the Data Controller over your Personal Data. 

   Anyhow, in certain specified instances, Vision Direct is a 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 Controller 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 a registered office at Piazzale Cadorna no. 3 – 20123 Milan, Italy, as a part of EssilorLuxottica Group (“Luxottica”; hereinafter Vision Direct and Luxottica jointly “EssilorLuxottica”); 

   For further details on the essence of the Joint Controlling Agreements in place with the above entities, you can contact us at the address set out in Section 8 of this Privacy Notice.

2. What is the purpose 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 Affiliate 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 Notice at any time. If we do so, we will provide you with an updated copy of this Privacy Notice with reasonable notice. 

   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 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. EssilorLuxottica encourages you to review the privacy notices of those third parties before connecting. 

3. What is this Privacy Notice about? Key definitions

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:  

1. 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 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.  
    
2. Using automatic tracking systems 
    
   We use some technologies (e.g. cookies and automatic tracking systems) that automatically collect certain items of information relating to how you utilise the Sites and the services. For further information on the use of Personal Data collected through automatic tracking systems, please read our Cookie Policy available  here on the website in the appropriate website.  
    
3. 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. 
    
4. From social network profile  
   
   If you decide to log into the Sites 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 Site and/or the Services on those channels via the corresponding plug-ins  (e.g. Facebook’s ‘Connect’, ‘Like’ or ‘Share’ functions etc.). The use of the plug-in entails sharing the corresponding actions and information on the related social networks.
    
5. 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. 

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. 

1. Categories of Personal Data
    

   CATEGORY OF DATA	TYPES OF DATA
   Identifiable information	Including data such as name and surname, e-mail address, gender, date of birth, country of residence, postal address and phone numbers.
   Payment information	Including data related to your credit card for the purchase of products through the Sites and the Services (payments are made via a secure platform, supplemented by control measures, including encryption of contact details) and details of products which you have purchased from us.
   Profile and Commercial data	Including account name, password, Personal Data published on your social network, billing and delivery addresses, details of 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.
   Marketing and Communications Data	Including 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 Sites, the Services or purchased products are reported
   Health and Medical Data	Including ophthalmic prescription, eye examinations, measurements (optical correction, pupillary distance, etc.), adaptations and information having an impact on your visual health and eyesight checks that can be carried out in our stores.
   Data related to your care	Including social security number only for querying your rights as an insured person, the quotation and the social care, the edition of the care sheets and the tele-transmission to the compulsory and complementary health insurance funds; the name of the complementary organisation and the management platform, information related to the health coverage, the rate of care.
   Device information	Including such as the IP address or other unique code of your device (computer, mobile or other devices), identification as a 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.
   Navigation information	Including information regarding your interactions with our Sites, our Services, emails, products or advertisements and statistical data relating to these interactions.

2. Processing of Sensitive data 
   
   Certain categories of Personal Data we process for the purposes set out below are qualified as “sensitive” 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: 
    - where it is required or allowed under local Applicable Legislation  
   -  while implementing adequate safeguards to ensure the protection of such “sensitive” Personal Data, and;  
   -  where you give us your prior explicit consent  

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:  

1. 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. 

   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 your own devices and browsers, and 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-authorized access, to maintain the accuracy of Personal Data and to guarantee the proper use of information.  

   Furthermore, a secure system for authorising 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. 

2. We share your Personal Data with other Affiliates of the Group 

   EssilorLuxottica is a global organisation 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 are 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 portfolio, 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. 

3. Is your Personal Data transferred to third parties? 
   
   a) Service provider

   We may disclose your Personal Data with our third-party 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 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, which sets out its obligations and guarantees the implementation of appropriate technical and organisational 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) Third Party Social Network Service Providers 
   
   If you decide to log into the Sites 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 Site 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 Sites or/and the services, and they may notify you connections on the third-party services about their use of the Sites and/or the services. Their use of your Personal Data is not governed by this Privacy Notice 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 instances 
   
   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. 

4. 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. 

   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. 

   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.

5. 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 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.  
   
   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 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.  

6. We keep your data safe, updated and accurate 
   
   EssilorLuxottica is responsible for the security and accuracy of the Personal Data that it processes about you and 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:

1. 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.  
    
2. Right to Rectification 
   
   You may request to rectify the Personal Data our databases currently contain regarding yourself. 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.  
    
3. 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. 
    
4. 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, including withdrawing your consent to the processing of your Personal Data.  
    
5. 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.  
    
6. 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 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. 
    
7. 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.
   
     
8. 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 case of the User’s death, the above-mentioned rights may be exercised by another person entitled (the "Successor") who has its own interest or acts as User’s mandatory or family reasons that need to be protected exist. Users may expressly avoid the exercise of some of the above-mentioned rights by the Successor submitting a request to the e-mail address indicated below. Users may, in any time, withdraw or modify such declaration with the same modalities. 

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. 

1. Contact of the Data Controller 

   The Data Controller of the processing of your Personal Data is Vision Direct 

   Should you have questions or comments on this Privacy Notice or on any data may be contacted to the postal address above and through the link available in the previous paragraph. 

2. Contact of the Data Protection Officer 
   
   Vision Direct has appointed a Data Protection Officer, which can be contacted at the following email address: privacy@essilorluxottica.com or at the address provided for in section “HOW CAN YOU CONTACT US?” of this Privacy Notice. 
   
   You can also send an email to dpo@luxottica.com in case of any questions related to this document.  

For legal and/or organisational 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 provide additional notice to you if we make any changes that materially affect your privacy rights.