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PRIVACY POLICY

 

This Privacy Policy was last modified and is effective as of June 15, 2022.

This Privacy Policy applies to the collection, use, communication and retention of personal information made by EssilorLuxottica Canada Inc. and certain of its affiliated entities (“Essilor,” “we” or “us”) on or through:

  • the access, browsing or use of any of Essilor’s websites, mobile applications and other digital platforms to which this Privacy Policy is posted;
  • communications and other interactions with Essilor by any means (such as online contact forms, email, phone, our social media pages and accounts, etc.); and
  • other electronic, in-person, hard copy written or other means by which you may provide us with information, such as by participating in Essilor-related contests, sweepstakes and/or other promotions, by redeeming an Essilor-related offer, by communicating with us at trade shows or events,  by presenting products for service, and/or by registering your product.

 Any of the above will be referred to as the Essilor Digital Services” and. any person accessing, browsing or otherwise using the Digital Services, either manually or via an automated device or program, shall be considered a “User.”  

This Privacy Policy also explains how cookies and other tracking technologies may be activated and used on our Digital Services.

1.  Essilor Can Modify This Privacy Policy

We may modify this Privacy Policy at any time. If we do so, we will make the new version available through the Website, indicate the date of the latest revision, and will try to notify you of such change through the applicable interface, when required under applicable law. 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 may Collect

Electronic information: We may collect certain common technical information. 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 collects 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. While this information is generally non-personal, it may constitute personally identifiable information (“PII”) in certain circumstances. It is automatically collected through cookies, pixels, web beacons, log files and/or other tracking technologies, whether developed by us or provided by third parties (collectively “Cookies”), to the extent activated by you if required under applicable law. For information on default privacy settings and how to change them,  including how to enable and disable geolocation services on a mobile device, see Section 7 below.

PII we collect on or through Digital Services: The types of 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. Depending of the circumstances, 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 you decide to register your product(s), you may choose to voluntarily provide the date of your last eye exam, the type(s) of products to register and their purchase date, the reason(s) why you decided to buy Essilor products and your consent to receive our newsletter on our brands.

- 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, language proficiency and any other information you include in the resume and/or cover letter you upload to the Digital Services. You may also choose to voluntarily 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 contacting us by email or other means, we may collect all PII contained in your communications.

- 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. By using such a referral feature, you certify that you have permission to provide your friend’s email address and to send them this content.

- If you are requesting or using any other of our services, information necessary to provide the service you have requested.

PII we collect from third parties: We may collect PII indirectly from third parties when you use their respective websites, mobile applications and/or other platforms to connect or interact with us. More specifically, you may be given the option to apply for employment through the use of your account on third-party platforms such as your LinkedIn account, and/or be able to interact with us through third-party social media platforms such as Facebook, Twitter, YouTube and Instagram. By doing so, you authorize us to access and store your username, public profile information and any other PII that such third parties make available to us, and to use and disclose it in accordance with this Privacy Policy. You should check your privacy settings on each such third-party service to understand what PII it makes available to us, and make changes as appropriate. Please carefully review each such service provider's terms of use and privacy policies before using their services to interact or connect with us.

Location Information: We may also 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, to the extent activated by you if required under applicable law. If you access or use the Digital Services from a mobile device, we may collect more precise geolocation information from your mobile device, subject to your activation of such function if required under applicable law. 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 default privacy setting and how to change them, including how to enable and disable geolocation services and/or push notifications on a mobile device, see Section 7 below regarding your Opt-Out Choices.

3. Purposes of PII Collection

We collect PII to provide a service, product or information about Essilor’s products or services or to complete a transaction with you. Examples include subscribing and sending you newsletters, entering you in a Promotion, enabling your participation in training, providing you with functions to find an eyecare professional or doctor, distributor, store or sales consultant, providing you with information regarding vision, vision care and vision correction, receiving, processing and responding to applications for employment, selling you a product or service, completing online surveys,  or for product registration. We may also generally collect, use and disclose your 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, to the extent permitted by law.
  • Identify your preferences to customize our communications and marketing.
  • Manage and record your settings, consents, 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 find an eyecare professional or doctor, distributor, store or sales consultant in your area and schedule eye exams or similar appointments with such persons.
  • Understand patterns of Digital Services activity and improve and customize the Digital Services.
  • Conduct market research.
  • Prevent and investigate malicious activity, security breaches, and fraud.
  • Conduct analysis and for administrative purposes.
  • Administer and fulfill Promotions.
  • De-identify and/or anonymize your PII.
  • Comply with applicable law, including tax and legal disclosure requirements and reporting to relevant authorities.

4. Retention and Protection of PII

Essilor will retain your PII for the period necessary to fulfill the purposes of PII collection, unless a longer retention period is required or permitted by law.

We take steps designed to ensure that only those employees and members of our staff who need access to your PII to fulfil their employment duties will have access to it.

Although Essilor employs physical, organizational 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.

5. Disclosure of PII

Essilor may disclose your PII, as follows, for the purposes of PII collection and/or for other purposes specified below:

-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 necessary for them to provide services to you or Essilor that are aligned with the purposes outlined above.

- 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 PII with the promotion partner. Your PII will be used by us and/or by them as described in our posted privacy policies.

-  Other Users of certain Digital Services. The Digital Services may contain customer reviews, forums and/or message boards and other online content. Please remember that any information submitted in these areas becomes publicly available to other Users, and you should exercise caution when considering the disclosure of your PII. To the fullest extent allowed under applicable law, we do not monitor such content and are not responsible for material posted by you or others in these public forums.

- 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 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.

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

Except as set forth above, Essilor will not grant access, disclose or otherwise transfer to third parties your PII unless Essilor obtains your consent in accordance with applicable law or if permitted or required .

6. Parents and Guardians

Our Digital Services are meant for adults only. 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, using the contact information provided at the end of this Privacy Policy. We will take reasonable steps to delete such information from our database within a reasonable time.

7.  Consent Withdrawal, Opt-Out Choices and Privacy by Default

Withdrawal of consent to the use and disclosure of PII. You can withdraw your consent to our communication or use of your PII, at any time. However, such withdrawal may mean you will not be able to use or (fully) benefit from our services, features or offerings. Also, we may keep using or communicating your PII following your consent withdrawal to the extent permitted or required under applicable law.

Emails. You can opt out at any time 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/.

When required by applicable law, we ensure that, by default, the parameters of our Digital Services provide the highest level of confidentiality without any intervention by you. This means, notably, that any Cookies and any other technologies with features allowing you to be identified, located or profiled (including for interest-based behavioral advertising activities described below) will be turned off by default, until you activate them directly in the [privacy and cookies settings manager] or authorize us to do so.

Regarding other Cookies and technologies we may use, you may block or restrict them 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, subject to the activation mechanism described above, 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. 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 on and off the GPS locator or push notification on your phone. Please consult your mobile device’s user guide for instructions on clearing cookies, enabling and 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 hold about you. In addition, you have the right to request correction of such PII by contacting us using the contact information provided at the end of this Privacy Policy. 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. International Data Transfer

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 outside of your country, province or state of residence, in any jurisdiction where we have facilities or in which we engage service providers, to the extent allowed in accordance with applicable law. This means that your PII may be transferred in jurisdictions that has less restrictive privacy laws than your country, province or state of residence, in which case we will ensure, through contractual means or otherwise, that it will receive an adequate protection in compliance with generally accepted data protection principle. 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 the person in charge of the protection of personal information at the following email address: infolegal@essilor.ca.