1. GENERAL INFORMATION
a) Who is the Data Controller?
The Luxottica.com website (hereinafter, the “Website”) is managed by Luxottica Group S.p.A. (hereinafter, “Luxottica”), with registered office at Piazzale Cadorna no. 3 – 20123 Milan, Italy, in its capacity as Data Controller.
In this capacity, Luxottica sets out the purposes and means to process the personal data collected from the website.
b) Who is the Data Protection Officer?
Luxottica has appointed a Data Protection Officer of all companies of the Luxottica group.
The DPO is available at the registered office of the company or at this address.
2. PERSONAL DATA PROCESSED
a) Which personal data are processed?
The following categories of personal data are processed by Luxottica:
- Personal data (e.g., name, surname, email address) provided in case of contact through the methods indicated on the website (Contact us, Customer Care).
- Personal data provided in case of voluntary submission of CVs (e.g., data contained in CVs).
- Personal data provided to receive, from Luxottica, commercial and marketing communications (e.g., email address, telephone number) such as, for example, newsletters and surveys.
b) How do we use these personal data?
The personal data referred to in section 2.a. shall be processed, respectively, to:
- Manage the relation between users and Luxottica. In particular, Luxottica uses the aforementioned data to contact users regarding their requests or to evaluate any requests for assistance on products under warranty.
- Evaluation of CVs voluntarily submitted.
- Analysis of the functioning of the website.
- Transmission of commercial and marketing communications.
c) Which is the legal basis of data processing?
- Luxottica shall process the personal data to perform a contract to which users are a party.
- In this case, users are free to provide the personal data to have access to the legal warranty, submit a CV for a job position with Luxottica or request information from Luxottica. In this case, failure to provide the personal data shall have no negative consequences, although requests may not be complied with. For example, failure to provide one’s own email address shall result in the impossibility for Luxottica to contact users to fulfill their requests or to evaluate their job application.
- Data shall be processed subject to the users’ prior consent.
- In this case, users are free to give their consent to a specific data processing activity. For example, users shall give their consent to the processing of their contact information if they wish to receive commercial and marketing information.
- Data processing is necessary for the purposes of the legitimate interest of Luxottica
- In some cases, Luxottica has a legitimate interest in the processing of your data to follow up on your specific requests for information or assistance, sent to our addresses indicated on the Website.
d) To whom user’s personal data will be disclosed with?
The personal data of users will be communicated to:
- Luxottica personnel in charge of and authorized to processing;
- Companies belonging to the Luxottica Group with whom specific agreements are in place regarding the processing of personal data (e.g. appointment of data processors);
- Third companies engaged by Luxottica to pursue its business activities (e.g., telecommunications companies, IT companies, recruitment agencies) expressly appointed as Data Processor.
e) Where do we transfer personal data?
As the case may be, some of the companies belonging to the categories referred to in section 2.3.d may be located in countries which do not have an appropriate level of personal data protection. The European Commission has the power to define the appropriateness of a country; an updated list of Countries offering personal data protection is available here https://www.garanteprivacy.it/home/provvedimenti-normativa/normativa/normativa-comunitaria-e-intenazionale/trasferimento-dei-dati-verso-paesi-terzi#1
Transfer of personal data outside the EU and towards countries not included in the above list shall exclusively occur on the basis of specific agreements between Luxottica and the companies involved, using means deemed suitable by the European Commission, such as the so-called standard contractual clauses for data transfers between EU and non-EU countries.
f) How long will we process user’s personal data?
The personal data of users shall be stored for the time necessary to perform the processing activity for which they have been provided.
- The data provided by users to get in contact with Luxottica will be erased after 12 months from the last interaction with Luxottica.
- The data indicated in CVs shall be stored for 6 months from receipt or shall be stored according to Luxottica internal procedures in case of finalization of employment.
- The data processed for marketing purposes shall be stored for 24 months following objection to processing and, in any case, data shall be erased within 30 days in case of a specific request from the users.
g) Data provided by users under 16 years of age
The website is not intended for users under 16 years of age. Luxottica does not intentionally collect personal information coming from these users. In case of accidental registration of information on minors, Luxottica shall promptly erase the personal information of these minors, unless the personal data of these users are communicated under an express consent of the persons holding parental authority.
3. RIGHTS OF USERS
In accordance with the applicable laws and regulations on data protection, users shall have the right to:
- Access, amend and/or erase their own personal data;
- Restrict or object to the processing of their personal data;
- Communicate their intention to no longer receive marketing information;
- In certain instances, request transfer of some of their data to the users themselves or to third parties;
- To the extent that the processing of personal data is based on the users’ consent, withdraw such consent without this affecting the legitimacy of the processing based on the consent given prior to withdrawal.
It is our commitment to allow users to exercise their rights: to this purpose, users can contact Luxottica using the information indicated in the header of this privacy notice. Users may exercise their rights in regard to the companies and the brands of the Luxottica Group clicking here or requesting general information on the processing of personal data at this address.
4. AMENDMENTS TO THIS PRIVACY NOTICE
We shall periodically verify that this privacy notice is legally compliant, in particular, that it complies with new laws and regulations on data protection. However, even if it can be amended in the course of time, the rights of users shall not be restricted without the users’ prior express consent.
Where users are not satisfied with the way their requests are fulfilled, they have the right to lodge a complaint with a supervisory authority about the way we process personal data.
Last update 25 May 2018
Luxottica Group S.p.A.