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PRIVACY POLICY

This Privacy Policy was last modified and is effective as of October 1st, 2018.

This Privacy Policy forms part of your legal agreement with Essilor Group Canada Inc. and certain of its affiliated entities (“Essilor”, “We” or “us”) under Essilor’s Terms of Use. This Privacy Policy applies to information collected on or through the Essilor Digital Services to which it is posted. Please read our Privacy Policy carefully to be sure you understand how Essilor collects and uses information and under what circumstances Essilor shares information about you. Capitalized terms not defined herein have the meaning ascribed to them herein and in the Terms of Use.

Any person accessing, browsing or otherwise using the Digital Services, either manually or via an automated device or program, shall be considered a “User.” All Users are bound to the terms of this Privacy Policy and to any specific Terms of Use. Your use of these Digital Services means you consent to the collection, use and disclosure of your personal data as described in this Privacy Policy.

1.        Essilor Can Modify This Privacy Policy

Essilor reserves the right to modify this Privacy Policy at any time pursuant to the terms and conditions of the Terms of Use. We encourage you to review this Privacy Policy each time you use the Digital Services so you remain aware of the terms and conditions that apply.

2.        Information Essilor Collects

Anonymous information: Our Digital Services capture certain non-personal common technical information automatically. This information may include your Internet protocol (IP) address, browser type and computer operating system, device type, application software, time and date you visit or use the Digital Services, and traffic patterns and usage data, such as the pages you access, the address of the website that directed you to the Digital Services or the website you visit when you leave the Digital Services. Essilor uses this information to understand patterns of site activity, including aggregated user demographics, and to improve the Digital Services so they are more useful for you.

Personal Information: The types of personally identifiable information (“PII”) that may be collected on or through the Digital Services include your name, your status (such as whether you are a consumer, student or journalist), mailing address, email address, title or occupation, and telephone number. Additional PII that may be collected on or through the Digital Services includes, but isn’t limited to:

-        If you are purchasing a product or service, your credit card number, expiration date and security code.

-        If are entering a sweepstake, contest, giveaway or other promotion (each a “Promotion”), your age or birth date.

-        If you are applying for employment, your work authorization information, visa status, desired salary, academic level, employment history including salary, and any other information you include on the resume you upload to the Digital Services. You may also choose to provide optional information such as race, gender, or whether you are disabled.

-        If you are participating in a survey, we may ask your gender and age, income, ethnicity, family size and marital status.

-        If you are sharing an article or page of the Digital Services with a third party, the third party email address will also be collected.

-        If you are using a service, information necessary to provide the service you have requested.

Location Information: We may collect information about your location when you access or use the Digital Services. We may collect information regarding your general location using your IP address. If you access or use the Digital Services from a mobile device, we may collect more precise geolocation information from your mobile device. This information may be used to customize certain features of our Digital Services and to provide you with location-based services. This information may also be used to send push notifications, which appear on the display of your mobile device in the form of a badge, alert or banner, and allow mobile applications to send information to your mobile device even when the application is not in use. For information on how to disable geolocation services and/or push notifications on a mobile device, see Section 7 below regarding your Opt-Out Choices.

Retention Period: Essilor will retain your PII for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

3.        Purposes of PII Collection

We request PII to provide a service, product or information about Essilor’s products or services or to complete a transaction. Examples include subscribing to newsletters, emailing a friend an article from the Digital Services, entering a Promotion, participating in training, finding an eyecare professional or doctor, distributor, store or sales consultant, providing information regarding vision, vision care and vision correction, applying for employment, purchasing a product or service, completing online surveys, contacting us with questions or comments, or for product registration. We may also generally use your information, including PII, to:

-        Respond to your questions or comments or otherwise communicate with you.

-        Provide customer service.

-        Improve our products, services, marketing, and customer service.

-        For promotional purposes and to send you promotional communications.

-        Identify your preferences to customize our communications and marketing.

-        Manage communications and opt-out choices.

-        Provide information about Essilor, its products, and services.

-        Provide information regarding vision, vision care and vision correction.

-        Allow you to schedule eye exams or similar appointments with professionals in your area.

-        Understand patterns of Digital Services activity and improve the Digital Services. 

-        Conduct market research.

-        Prevent and investigate malicious activity, security breaches, and fraud.

-        Conduct analyses and for administrative purposes.

-        Administer and fulfill Promotions, including tax and legal disclosure requirements and reporting to relevant authorities.

4.        Protection of PII

Although Essilor employs physical and electronic security measures to protect PII, Essilor cannot promise the use of our Digital Services is completely safe or that your PII will not be disclosed or misused, either by accident or by the unauthorized acts of others. Essilor urges you to use caution when using the Internet. This includes not sharing your passwords.

The Digital Services may contain customer reviews, forums and/or message boards and other Online Content. Please remember that any information disclosed in these areas becomes public information, and you should exercise caution when considering the disclosure of your PII. You agree that Essilor is not responsible for material posted by you or others in these public forums.

5.        Sharing of Information

Essilor may share your information, including your PII, as follows:

·         Subsidiaries and Affiliates. Essilor may transfer PII to its subsidiaries and corporate affiliates, including future subsidiaries and affiliates.

·         Consultants and Service Providers. Essilor will disclose PII to third party consultants, vendors, and service providers (such as providers of hosting, support, maintenance and remedial, repair services, mail delivery services, evaluation data analysis, data cleansing, order fulfillment and shipping, Promotion administration and fulfillment, advertising, marketing and promotional activities, fraud protection and risk reduction, and payment processing and authorization) to the extent that they require access to our databases, or the PII contained in our databases, to provide services to you or Essilor.

·         Joint Promotion Partners. Sometimes we conduct joint promotions with third parties. If you register for one of those joint promotions your information may be collected by both Essilor and the third party. Or, we may give you the option to have us share your information with the promotion partner. Your information will be used by us and/or by them as described in our posted privacy policies.

·         Enforcement of Rights/Security. Essilor reserves the right to release PII (i) when Essilor is under legal compulsion to do so (e.g. we have received a subpoena) or Essilor otherwise believes that the law requires us to do so, (ii) when Essilor believes it is necessary to protect and/or enforce the rights, property interests, or safety of Essilor, our users or others, or (iii) as Essilor deems necessary to resolve disputes, troubleshoot problems, prevent fraud and otherwise enforce the Privacy Policy and Terms of Use.

·         Reorganization or Sale of the Company. In the event that the Essilor is merged with or becomes part of another organization, or in the event that Essilor is sold or it sells all or substantially all of its assets or is otherwise reorganized, the PII Essilor collects will be one of the transferred assets to the acquiring or reorganized entity.

·         Third-Party Marketing. Essilor may share your PII with third parties for their marketing purposes.

·         As Otherwise Allowed by Law. Essilor may transfer PII to third parties where we are expressly authorized by applicable law to do so.

·         Non-PII. Essilor may transfer your non-PII to third parties for any lawful purpose. This non-PII may include aggregate information, which is compiled information reflecting the collective usage of multiple users, and/or de-identified information, which reflects the usage patterns of a particular use of the Digital Services, as opposed to users collectively, but is not personally identifiable.

Except as set forth above, Essilor will not sell, trade, or otherwise transfer to third parties your PII unless Essilor provides advance notice as set out in the Terms of Use or obtains your consent. 

6.        Parents and Guardians

Our Digital Services are meant for adults. We do not knowingly collect personally identifiable information from children under 18. If you are a parent or legal guardian and think your child under the age of 18 has given us information, you can contact us to remove the information. We will take reasonable steps to delete such information from our database within a reasonable time.

7.        Opt-Out Choices

Emails. You can opt out of receiving future promotional emails from Essilor by following the unsubscribe procedures indicated in each email. Even if you opt out of receiving promotional emails from Essilor, we will send you transaction emails and respond to questions from you. 

Cookies and other Technologies. Essilor uses cookies, which are small data files created by a Web server and stored by your browser, to keep track of and enhance certain user activities on our Digital Services such as logging into your account, making a purchase and other user-specific features. We also use cookies and web beacons (also known as pixel tags, action tags, or transparent GIF files), which are tiny graphic images, to permit our Digital Services to function properly, to implement analytics tools, including Google Analytics, that help us understand how the Digital Services are performing and how visitors engage with the Digital Services, and to improve and track our advertising and marketing, including how you interact with our advertisements and communications. For more information on Google Analytics, visit: https://www.google.com/policies/privacy/partners/.

You may block or restrict cookies on your computer or device or purge them from your browser by adjusting your web browser preferences. You should consult the operating instructions that apply to your browser or your mobile device’s user guide for instructions on how to configure your setting to meet your preferences. Cookies allow you to take advantage of some features or functions of the Digital Services, so if you block or otherwise reject our cookies, you may not be able to use some features of the Digital Services. If you don’t want your browser to share information with Google Analytics, you may download an Opt-out Browser Add-on by clicking here. Please note that the Add-on does not prevent information from being sent to Essilor.

Interest-Based Behavioral Advertising. Essilor’s advertisements are shown on third party websites, including Google. Essilor may use technologies such as cookies and web beacons to help manage online advertising. These technologies are provided by our third party vendor(s) and enable our third party vendor(s) to recognize a unique cookie placed by us (when you accessed the Digital Services) or by our third party vendor(s), or by another advertiser who works with our third party vendor(s). These technologies allow us to learn which advertisements bring users to our Digital Services. They also allow us to collect information about your online activities over time and across third party websites so we can manage advertising effectiveness and provide you with online advertisements, including advertisements on the websites of third parties not affiliated with Essilor, more likely to be of interest to you. Third party vendors, including Google, use cookies to serve ads to you based on your past visits to the Digital Services. With this technology, the information that we collect and share is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address. 

Tools on Mobile Devices. You can control the tools on your mobile devices. For example, you can turn off the GPS locator or push notification on your phone. Please consult your mobile device’s user guide for instructions on clearing cookies, disabling location services, and disabling push notifications. 

Do Not Track (“DNT”) Signals. Essilor does not currently respond to DNT signals but may do so in the future.

8.        Accessing and Updating Your PII

You have choices about the data Essilor collects. When you are asked to share your PII with us, you may decline; however, your choice not to share your PII with Essilor may mean you will not be able to use or (fully) benefit from our services, features or offerings.

Essilor respects your right to know and inquire about what PII we have collected about you. In addition, you have the right to request correction or deletion of such PII, as well as to request removal of your PII held by third parties with whom we conduct business by contacting us. In addition, you may contact your jurisdiction’s legal authority overseeing implementation of data protection laws to file a complaint regarding the processing of your PII.

Some Essilor Websites may allow you to set up an account and access and update your PII by logging into your account and going to the appropriate section of your account.

9.        Consent of Data Transfer of Non-Canadian Residents

If you reside in a country other than Canada, upon providing your PII to Essilor, you will be indicating your explicit consent that the PII you have provided may be transferred to, processed, and stored in a country that has less restrictive privacy laws than Canada.

As Essilor is a multi-national organization with locations in many countries around the world, your PII may be stored and processed in any country where we have facilities or in which we engage service providers. Essilor takes steps to process PII according to the provisions of this Privacy Policy and the requirements of applicable law.

10.     Links to Other Websites

Other Essilor Websites and Digital Platforms. This statement applies only to the Essilor Digital Services on which it is posted. Other Essilor websites, mobile websites, social media sites and other digital platforms may have different privacy policies so please be sure and read the privacy policy of each Essilor website, mobile website, social media site and other digital platform that you visit to understand how Essilor collects and uses information and under what circumstances Essilor shares information about you collected through that website, mobile website, social media site or other digital platform.

Third Party Websites and Digital Platforms. The Digital Services may contain links to third party sites and digital platforms. Essilor is not responsible for the content or policies of such sites and platforms and recommends that you review the privacy policy posted on each third party website and digital platform that you visit.

11.     Notification Procedures

In the unlikely event your PII is accessed, lost, or stolen by an unauthorized third party, Essilor will exercise commercially reasonable efforts to notify you to the extent required by law and disclose to you the personal data that was accessed/disclosed using the contact information provided to us or by other reasonable means.

12.     Contact Essilor to Ask Questions and Provide Feedback Regarding Privacy

Essilor welcomes your questions, comments and concerns about privacy. Essilor is committed to the resolution of concerns or complaints about your privacy and Essilor’s collection or use of your PII. If you have any questions regarding this Privacy Policy or how Essilor protects your PII, please contact us.

Last modified: October 1st, 2018.