This policy illustrates how Luxottica Group S.p.A, through and together with its Affiliates, (hereinafter “Luxottica”) in their quality of Data Controllers, with registered office in Milan, Piazzale Luigi Cadorna No. 3, process your personal data.
1.TYPES OF DATA
Luxottica processes the following categories of personal data collected through the automatic tracking systems when you browse the website and use its services:
- Information relating to your usage of the website;
- Navigation information collected when you surf the website. Luxottica uses some technologies (e.g. cookies and automatic tracking systems) that automatically collect certain items of information relating to the way in which the user utilizes the website such as the IP address or other unique code of the device (computer, mobile or other devices) employed by the user to browse the website, technical information that may include the URL from where a user originates, browser information, language (“Browsing Data”). This information helps us to continuously improve the browsing experience and the mechanisms for displaying Luxottica products and services, and to monitor the correct operations of the website. This information only includes statistical data relating to the actions performed by the user and is not intended to be associated with the user’s identifying data. Generally, this information is not sufficient to identify the user personally, but it could be if it is read in combination with each other or with additional information collected by Luxottica or a third party.
2. PURPOSES OF DATA PROCESSING
Luxottica processes your Browsing Data with specific reference to pages consulted and products viewed on the website to analyze your interests and preferences. This activity will help Luxottica to provide you with offers more in line with your interests.
Luxottica also processes your Personal Data for additional purposes and, in particular:
- To enable the technical management of the website and its operational functions, including solving any technical problems, to perform tests and updates and upgrades;
- To prevent or identify fraudulent activities or misuses of the website or against the Luxottica group and/or the users of the website.
3. METHODS OF PROCESSING AND RETENTION PERIOD
The processing of your Browsing Data is carried out, electronically and manually, only within the limits necessary to pursue the purposes outlined above. Browsing Data will be stored for the time strictly necessary to achieve the purposes for which Browsing Data were collected and further processed, including any retention period required under the applicable legislation.
For more information about how Luxottica processes your Browsing Data you can contact the following email address:firstname.lastname@example.org
Applicable to Singapore, Malaysia and Thailand
LUXOTTICA SEA PTE LTD PERSONAL DATA PROTECTION POLICY
LUXOTTICA SEA PTE LTD (“Luxottica”) (“Company”, “we”, “us” or “our”) is committed to the protection of your personal data which you have entrusted to us.
We have prepared this Personal Data Protection Policy (“Policy”) on how the Company collects, uses, discloses your personal data under the Singapore Personal Data Protection Act 2012 (PDPA) (“Act”). We encourage you to take the time to read it.
Please note that this Policy may be amended or updated from time to time without notice to reflect the change/s in the applicable data protection laws.
1. YOUR CONSENT
By interacting with us, visiting our physical stores or website, submitting information to us, purchasing any product/s and or services offered by us, you agree and consent to the Company, including its related companies, as well as their respective representatives and/or agents to collect, use, disclose to any relevant third party for the purposes and in the manner outlined in this Policy.
2. DEEMED CONSENT FOR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA
You are deemed to have given your consent for the collection, use, or disclosure of your data under the following circumstances allowed by law:
(a) For the conclusion of a contract between you and our Company.
(b) For a 3rd Party by the Company to perform the contract between you and
(c) Where the Company has determined that the use, collection or disclosure is not likely to have an adverse effect on you.
(d) For any business improvement process.
(e) For any new product/or service the Company is providing to its customers.
(f) Under any circumstances where it would be reasonable for the Company to do so on your behalf and in your interest.
3. COLLECTION, USE AND DISCLOSURE WITHOUT CONSENT UNDER THE ACT
The Company is entitled under the relevant provisions of the law to collect personal data about you from a source other than you, use or disclose your personal data without your consent.
4. NOTICE TO WITHDRAW FROM USING YOUR PERSONAL DATA
If you do not agree to the above, you may inform us and we will proceed to fulfil your request not to collect, use or disclose your personal data. Please note that we may, where relevant decide to terminate your contract with the Company when it is no longer practicable and/or where we are not able to fulfil the contract based on your request.
No compensation is payable by the Company based on your decision to withdraw and the process of withdrawal may take up to 30 days from the date of your written request received by our Data Protection Officer.
5. PERSONAL DATA DEFINED
In this Policy, “personal data” means data, whether true or not, about an individual who can be identified —
(a) from that data.
(b) any derived data; or
(c) from that data or other information to which the Company has or is likely to have access to, including but not limited to:
(i) Identity data such as your name, gender, and date of birth.
(ii) Contact information such as a delivery address, telephone number/s, and electronic mail address.
(iii) Location information such as your Global Position System (“GPS”) signal sent by your mobile device, your Internet Protocol (“IP”) address and other data from your device, and from a country from which a request is received.
(iv) Information relating to your work or profession such as your job title or function, job description and related information, company’s name, department, and other company’s details as relevant.
(v) Company’s User Account registration data such as your unique username or password, activation code/s, billing information, license and related verification information.
(vi) Account data such as bank account and payment information such as the name of cardholder, card number, billing address, expiry date and the like.
(vii) Network data such as your IP address, cookies, web browser type and version, operating system, the domain name of your Internet provider, location and device identifier and/or any information generated from any computer system/s or device.
(viii) Any other information relating to any individual/s which you have provided to us in any form which you may have submitted to us or obtained through any form of interaction with you whether through any electronic system and/or with you in person.
6. COLLECTION OF YOUR DATA
Generally, the Company collects your data when:
(a) You visit our website or participate in our promotions, contests, campaigns, customer surveys or any other marketing initiatives or exchange of both technical and non-technical information relating to our product/s or service for any reason.
(b) You accept our cookies on your device/s.
(c) You place an order with us in our physical stores or through our website.
(d) You visit our premise, and your image is captured by our closed-circuit television system.
(e) You interact with us on our social media platform/s.
(f) You interact with our staff or representative, through face-to-face or virtual meetings, telephone calls, electronic and/or physical mail correspondence or when you fill in our web forms.
(g) You subscribe to our publication/s or marketing collaterals.
(h) You enquire about our products or services through any medium.
(i) Your representative/agent submits your personal data to us for any purpose authorised by you.
(j) You voluntarily submit your personal data to us for any reason.
7. USE AND DISCLOSURE OF YOUR DATA
The personal data which we have collected from you may be used by us and/or shared with or transferred to a third party such as our related companies and our authorised service providers for which may include but is not limited to the following:
(a) To facilitate your use of our website including the identification of visitors and statistical usage of the website.
(b) To process your orders which you have placed with us in our physical store/s or through our website.
(c) To respond to your queries, complaint/s, feedback, claim/s or any update.
(d) To deliver the product/s you have purchased through our physical store or website.
(e) To administer our promotion/s, contest/s, campaign/s, customer survey/s or any other initiative/s.
(f) To ascertain or to investigate any fraud, carry out an audit or any other investigation/s as required under the law.
(g) During an acquisition where your personal data, as valuable assets, may also be transferred to a third party through the process of sale and purchase of our customer database, in whole or in part. However, the use of your personal data will be subjected to this data protection policy. Similarly, your personal data may be shared with a successor company or an entity in the event of a liquidation or bankruptcy proceeding.
(h) To comply with the legal requirements under any relevant law.
(i) To fulfil any other business requirement/s.
8. 3rd PARTY LINKS AND PROVISION OF DATA
To the fullest extent permitted under the law, the Company cannot be responsible for any consequence/s arising from your use of any third-party's link/s on our website, and any such liability is expressly disclaimed and excluded. If you provide to us with any personal data relating to a third-party including but not limited to information of your spouse, children, parents, employees and the like, you represent to us that you have obtained the consent of the third-party in the provision of that data.
9. ACCESSING & CORRECTING YOUR DATA
You should ensure that all personal data submitted to us is true, accurate and complete. Failure on your part to do so may result in our inability to provide you with the goods and services you have requested. You may:
(a) Request information about how your data is managed and used within the year before the date of your request.
(b) Correct and/or update any personal data submitted to us you deem as erroneous.
The Company reserves the right to charge a reasonable administrative fee for retrieving your record/s and we will inform you of the fee before processing your request.
The Company may reject your request under the relevant provisions of the Act. Generally, we will respond to your written request within 30 days from the date of your request.
10. RETENTION OF YOUR DATA
We will only retain your data for as long it is necessary for any legal or business purposes.
11. SECURITY OF YOUR DATA
We will protect your data by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risk/s and the loss of any storage medium or device on which the personal data is stored.
Despite such reasonable efforts, please note that it is the nature of the Internet, that any transmission and any method of electronic storage is inherently insecure, and the Company cannot warrant the security of the information which you have provided to us.
We assume no liability for disclosure of your personal data due to errors in transmission, unauthorised third-party access, or other cause/s beyond our control.
12. TRANSFER OF THE DATA OUTSIDE OF SINGAPORE
The Company will not transfer any of your data outside of Singapore unless the transfer conforms with the requirements under the Act.
13. NOTIFICATION OF DATA BREACHES
Where the Company is being made aware of a breach of personal data, the Company will assess whether the breach is a notifiable breach under the Act.
A notifiable data breach is one where (a) it results in or is likely to result in, significant harm to the affected individual(s), or (b) is, or is likely to be, of a significant scale.
The Company will inform the relevant authorities if the breach is a notifiable one, and in consultation with the authorities, may inform you of the breach and provide the necessary information concerning the breach through the Company’s website or any other means.
14. COMPANY’S DATA INTERMEDIARY
A Company’s data intermediary processing any personal data of the Company must, without undue delay, notify the Company if the data intermediary is aware of any breach of personal data within the intermediary or a related entity of the intermediary.
15. WITHDRAWAL OF YOUR CONSENT
You may communicate the withdrawal of your consent to the collection, use or disclosure of your personal data by submitting your request in writing to our Data Protection Officer.
16. GOVERNING LAW
This Policy and your use of the Company's services and all aspects of personal data protection between you and the Company is governed by the laws of Singapore and you agree to submit to the exclusive jurisdiction of the courts of Singapore in the event of any dispute.
17. DATA PROTECTION OFFICER
Luxottica Group S.p.A
Via Cantu, 2
Phone: +39 02 8633400
Email: privacy @luxottica.com