1. GENERAL INFORMATION
a) Who is the Data Controller?
The accreditation system currently being accessed (hereinafter, the “System”) is managed by Luxottica Group S.p.A. (hereinafter, “Luxottica”), with registered office at Piazzale Cadorna, 3, 20123, Milan - Italy, as Data Controller.
In its capacity as Data Controller, Luxottica determines the purposes and means of the processing of personal data collected within the Site.
b) Who is the Data Protection Officer?
Luxottica has designated a Data Protection Officer for all Luxottica Group companies.
The DPO may be contacted at the company’s registered office or at the following e-mail address.
2. PERSONAL DATA PROCESSED
a) Which personal data are processed?
Luxottica processes the following categories of personal data :
- Personal data (Name, Surname, email, Company of origin, etc.);
- Information about your internal contact at Luxottica;
- Any personal data acquired during navigation on Luxottica’s internal network through your devices (e.g., by accessing Wi-Fi, some information will be acquired, such as the device’s IP address and network access credentials).
b) How do we use these personal data?
Personal data under section 2.a above shall be processed for the following purposes, respectively:
- Issue your entrance badge and provide access to Luxottica’s various services;
- Check the truthfulness of the relationship between you and your internal contact;
- Check that access to the building and to the internal areas is not contrary to Luxottica’s policies;
- Check that internet surfing is not contrary to Luxottica’s policies.
c) Which is the legal basis of data processing?
- We process Personal Data for the performance of a contract to which the user is a party.
- In the event the registration to the System is carried out by external parties (e.g., candidates, consultants), the processing of personal data is necessary for the execution of the contract between Luxottica and the data subject or for the execution of pre-contractual measures requested by the data subject (e.g., participation in a selection procedure). In such a case the user is free to provide the data. Failure to provide personal data will not have negative consequences for the data subject. However, failure to provide the aforementioned information would make it impossible to gain access to the Luxottica building and consequently to take part in the selection procedures.
- The processing of personal data is necessary for the pursuit of Luxottica’s legitimate interest.
- In some cases, Luxottica has a legitimate interest in the processing of the user’s personal data. For example, access to personal data collected (through the System or via Wi-fi) is necessary for Luxottica’s legitimate interest in order to verify compliance with internal policies on the use of information systems and access to the building.
d) To whom user’s personal data will be disclosed with?
Personal data provided by the user shall be disclosed to:
- Luxottica’s employees, trained and authorised for the processing;
- Companies belonging to Luxottica Group with which contractual agreements are in force for the management of personal data (e.g., appointments as data processor);
- Third-party companies used by Luxottica to carry out its business activities (e.g. telecommunication companies, IT companies, recruitment agencies) expressly appointed as Data Processors.
e) Where do we transfer personal data?
Depending on the case, some of the companies belonging to the categories mentioned under point 2.d (2,3) may be located in countries that do not offer an appropriate level of protection of personal data. The European Commission has the power to define a country as adequate and the updated list of countries offering protection can be consulted here.
Transfers of personal data outside the European Union and to countries not included in the list mentioned above will be made exclusively following specific agreements between Luxottica and the companies involved, through the use of instruments deemed suitable by the European Commission, such as Standard contractual clauses for data transfers between EU and non-EU countries.
f) How long will we process user’s personal data?
The user’s personal data are stored for no longer than is necessary for the processing activity for which they have been provided.
- System registration data are stored for one year after they are entered;
- Data relating to navigation on the Luxottica network are stored for 12 months from the last access.
g) Data provided by users under 16 years of age
The System is not intended for users under the age of 16 and Luxottica does not intentionally collect any personal information from them. If information about minors is accidentally recorded, Luxottica will promptly delete such minors’ personal information, unless the personal data of these users is disclosed with the express consent of the person exercising parental guardianship over them.
3. RIGHTS OF USERS
In accordance with the rules and regulations applicable to data protection, the user has the right to:
- access your personal data, obtain the rectification and/or erasure thereof;
- obtain restriction of processing of your personal data, or object thereto;
- inform us of his/her wish not to receive any further marketing information;
- in some cases, have part of your personal data transferred to third parties;
- insofar as the legal basis for the processing of your personal data is your consent, withdraw that consent, without it affecting the lawfulness of processing based on consent before its withdrawal.
4. AMENDMENTS TO THIS PRIVACY NOTICE
If you are not satisfied with the handling of a request, you may file a complaint regarding the processing of the personal data with the Italian supervisory authority.
Last update 5 September 2018
Luxottica Group S.p.A.