PRIVACY POLICY
This Policy describes what personal information we, Luxottica Retail Hong Kong Limited and Lunettes Group Limited, and its affiliates companies, collect about you, how and why we use it, who we share it with and how we protect your privacy. For the purpose of this Policy, personal information refers to any information which relates directly or indirectly to you and allows us to identify you either directly or in combination with other information that we may hold (“Personal Information”). Your Personal Information may include for example your name, your contact details, your location data, information relating to your shopping history or information on how you use our site or how you interact with us.
In collecting, processing, storing, handling and transferring your Personal Information, we pledge to comply with, including others, the Personal Data (Privacy) Ordinance (Cap.486) of Hong Kong and Law No. 8/2005 of Macau, together with all other applicable legislation relating to privacy or data protection ("Data Protection Legislation").
WHAT INFORMATION DO WE COLLECT?
The information we collect depends on what you do when you visit our site. Please note that we do not collect personal information about you unless you choose to provide such information to us.
The Personal Information we may collect and use may include: (a) your Personal Information such as your name, gender, date of birth, or other personally identifiable number and information about your registered status with any of our subsidiaries, associated companies and/or business partners’ membership or loyalty program; (b) your contact information such as your telephone numbers, mailing addresses, email addresses and fax numbers; (c) your responses to market surveys; (d) your responses/submissions to contests conducted by us or on our behalf; (e) shopping records at our stores; (f) shopping preferences; and (g) Prescription records.
In the course of providing services to you, we may collect information that could reveal your racial or ethnic origin, physical or mental health, religious beliefs or alleged commission or conviction of criminal offences. Such information may be considered sensitive Personal Information sometimes referred to as special categories of Personal Information. By providing any sensitive Personal Information, you explicitly agree that we may collect and use it in order to provide our services and in accordance with Data Protection Legislation and this Privacy Policy.
HOW WE COLLECT INFORMATION ABOUT YOU
You may provide your Personal Information to us in the following circumstances: (a) submission of your requests for services through the site; (b) the creation of a user account (through the site, mobile App or any other manner), (c) uploading/posting any material to the site or via mobile App, (d) your participation in surveys (on the site, via our mobile App or any other manner). From time to time, we may provide you the opportunity to participate in contests or in other voluntary activities through the site or our mobile App. We may request personal information from you, along with other information, in order for you to participate. Participation in these activities is completely voluntary; therefore, you can elect not to provide your Personal Information by not participating in the activity.
Depending on your settings or the privacy policies for social media and messaging services such as Facebook, LinkedIn and Instagram you might give us permission to access information from those accounts or services.
In addition, for each visitor to our site, we, like most websites, use “cookies” and “log files” to help us make our site and the way you use it better. Cookies mean that our site will remember you. They are small tex files that sites transfer to your computer (or phone/tablet). They improve website use and speed (see section “Cookies” below for more information). Likewise log files will gather your information such as the internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We collect and store such information on an individual basis and in aggregate, or combined form, as well as both user-specific and aggregate information on what pages visitors access or visit, so as to identify the trend of the activities on our site.
HOW DO WE USE YOUR INFORMATION?
We use the information we collect about you to: (a) process and administer your registration of a user account with us; (b) process and administer your product order request with us; (c) improve the user experience of the site and/or our mobile App, including, without limitation, to analyze trends, administer the site, track users' movements around the site, and gather demographic information about our user base as a whole as well as to improve the content of our web pages, and to customize the content and layout of our pages; (d) compile and provide anonymous statistics about users of our site and to provide related usage information to reputable third parties for market research purposes which will not in any event enable any third party to identify individuals; (e) provide and/or market our goods and services; (f) manage and maintain the customer relationship between us and you such as sending you updates on latest offers and promotions in connection with products and services offered by us; (g) facilitate the implementation of any promotional activities or services to be co-organized by us and our business partners; (h) evaluate, develop, offer and promote our tailored-made services and products to you; (i) facilitate our business operations, including without limitation to, the fulfillment of any legal requirements in any applicable jurisdictions which may be within or outside Hong Kong or Macau; (j) for the use by any of our holding companies, subsidiaries, associated companies and/or business partners in connection with any of the aforesaid purposes.
We also use third-party tracking services to track non- personally-identifying information about visitors to our site in the aggregate. These third-party services may use JavaScript, pixels, transparent GIF files, and other means to enable us to learn which advertisements bring users to our website. Any information we track in this manner is anonymous, limited to usage and volume statistics, and is used to provide insight into the effectiveness of our online marketing initiatives and strategies.
Where required by Data Protection Legislation, you will be given a choice when you provide us with your Personal Information (email, push message, direct mail, telephone, fax and/or other form of communication) to opt into certain uses we may intend to make of that information, such as to provide you with information and update you about the products and/or services offered by us. As a global brand owner, we are able to supply you with information about a wide spectrum of eyewear products and services offered by any of our holding companies, subsidiaries, associated companies and business partners. If you have consented to receive the marketing and promotional offers of these companies, we may provide your Personal Information to facilitate the communication of such information to you. Please note that under no circumstances we will use your sensitive Personal Information for the direct marketing purpose.
You may indicate your consent to the use of your Personal Information for direct marketing purposes as described above by the following ways: (a) ticking the box (es) indicating your consent when providing us with your Personal Information through our site, our mobile App or submission of any enrollment form; or (b) indicating your consent to our customer representative when providing your Personal Information to Our Company through the telephone.
You may also at any time inform us that you no longer wish to receive any promotional and marketing information of either product or service offered by us or those products and/or services offered by any of our holdings companies, subsidiaries, associated companies and business partners by following the Opt Out Procedures described below.
LEGAL GROUNDS FOR USING YOUR PERSONAL INFORMATION
We are permitted to process your Personal Information in the way we do because the processing is:
(a) necessary for the purposes of the legitimate interests that we pursue, which are to run and administer our business, to discharge our legal obligations to store and disclose information where necessary and to evaluate, develop and improve our services, implement our terms of service or this Privacy Policy, to safeguard the rights, property or safety of you or other customers and to maintain the security and operation of the products or services provided by us (for example, when we need to investigate and fix malfunctions of Our Company’s services and products).
(b) necessary for the performance of our contract to provide you with services you have purchased; and/or
(c) necessary in order to comply with a legal obligation to which we are subject including: (i) necessary to comply with applicable laws and regulations; (ii) necessary to comply with court orders or other legal proceedings, including but not limited to those directly related to crime investigations, prosecutions, trials, and enforcement of judgments; and (iii) in response to a request made by a government authority, law enforcement agency or similar bodies (whether situated within or outside Hong Kong) to us, including but not limited to those directly relating to national security, national defence security, public safety, public health, and public interests; and/or
(d) with your consent: (i) if you are considered to be (1) a minor in certain jurisdictions (for example, in Hong Kong if you are below 18 years old or in Mainland China if you are under 16 years old), (2) incapable of managing your own affairs, or (3) mentally incapacitated, we will need the explicit consent or authorization from your parents or your guardian so as to collect and process your Personal Information; and/ or (ii) if you provide us with special categories or sensitive Personal Information as provided for in this Privacy Policy; and/or (iii) if we are transferring your Personal Information outside Hong Kong or Macau.
SHARING YOUR INFORMATION
We have a global partnership network and our holding companies, subsidiaries, associated companies, business partners, contractors, manufacturers and retailers are located worldwide. We, therefore, may disclose and transfer your Personal Information to such entities to assist in fulfilling the purposes, or directly related purposes for which the Personal Information is collected as described above. You expressly consent to the transfer of the Personal Information to these entities within or outside of Hong Kong or Macau. These entities may include:
(a) any of our group of companies within, directly or indirectly controlled by Luxottica Group S.p.A;
(b) any agent, contractor or third party service provider who provides administrative, marketing and research, advertising, distribution, data processing, telemarketing, telecommunications, computer, payment or other services to us in connection with the operation of our business;
(c) other business partners such as loyalty program operators and other companies involved in providing customer service or fulfilling customer requests;
(d) credit reference agencies;
(e) credit, debit and /or charge card companies and/or banks;
(f) government or non-government authorities, agencies and/or regulators; and
(g) medical professionals, insurers and clinics/hospitals.
We will only disclose your personal data under the following circumstances:
(a) it is necessary to honor our contract with you;
(b) it is within our legitimate interest;
(c) any other mandatory requirements from government authorities or arising from legal proceedings; or
(d) in certain circumstances, with your consent.
COOKIES
We use both session cookies and persistent cookies on this website. A cookie is a small text file that is stored on a user's computer for record-keeping purposes. While cookies in general do not tell us your Personal Information, however, if you voluntarily provide such Personal Information by, for example, registering a user account with us or subscribing for any of our services, we may link the information we store in cookies to your Personal information in order to provide a faster and more pleasant online experience.
We use session cookies to make it easier for you to navigate our site. We use session cookies to record session information, such as which web pages a user has visited, and to track user activity on the site. We also use session cookies to store any passwords used on the site (such as a password associated with a user account), so you don't have to enter it more than once per session. Session cookies expire when you close your browser.
We use persistent cookies to track and target the interests of our users to enhance the experience on our site. Persistent cookies remain on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your browser's "help" file.
The use of any Personal Information collected by us either through the use of cookies or otherwise shall be subject to this Privacy Policy. Most web browsers are initially set up to accept cookies. You may choose to edit your browser options to block cookies in the future. However, if you block cookies, certain features of our site may not work properly.
Please take note that cookies from third parties may be set before, during or after browsing our site. We do not and cannot control these cookies set by third parties and you should check these third party websites for more information about their cookies.
OPT OUT PROCEDURES
If you do not wish to receive promotional emails from us, please let us know by using the opt-out response device that can be found at the bottom of every email we deliver or by emailing us at CustomerCare-HK@lenscrafters.com. To help us process your request, please include sufficient information for us to identify you in our records. Please allow a reasonable time for us to process your request. Please note that, although you can opt not to receive promotional messages, we reserve the right to send you informational email messages about any user account you establish on this website or administrative notices regarding the site.
SECURITY
The security of your Personal Information is important to us. You acknowledge and understand that the transmission of information via the internet is not completely secure. Although we follow generally accepted industry standards to protect the Personal Information submitted to us (such as encrypt transmissions involving such information using secure protocols), and to guard that information against loss, misuse or alteration, you acknowledge that no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we use commercially-reasonable means to protect your personal information, we cannot guarantee its absolute security and you acknowledge and accept that any transmission is at your own risk.
THIRD PARTY SITES
This Privacy Policy applies only to information collected by our site, our mobile App and/or any other manner instructed by us.
From time to time, this website may link you to other sites ("Linked Sites") that are not controlled by us. We do not control the collection or use of any information, including personally-identifying information, that occurs during your visit to the Linked Sites. Further, we make no representations about the privacy policies or practices of the Linked Sites, and we are not responsible for the privacy practices of these Linked Sites.
Be careful of disclosing any of your personally identifiable information when leaving our site. We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collects personally identifiable information.
HOW LONG WE KEEP YOU INFORMATION
Personal Information provided by you will be retained for such period as may be necessary for carrying out the purposes stated in this Privacy Policy and in any event, for as long as required by the applicable laws.
Unless otherwise agreed, hard copies of any documents containing Personal Data that you have provided to us become our property and we will destroy any documents in possession in accordance with the applicable laws.
Personal Information collected by us in order to carry out the purposes or directly related purposes stated in this Privacy Policy will be stored in our databases.
We may send you direct marketing communications, and retain your contact information necessary for this purpose, (provided that you have consented to receiving them) for as long as you do not unsubscribe from receiving the same from us.
YOUR RIGHTS
At any time, you have the right:
(a) to be informed about the processing of your Personal Information (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
(b) to request access to or a copy of any Personal Information which we hold about you;
(c) to rectification of your Personal Information, if you consider that it is inaccurate;
(d) to ask us to delete your Personal Information, if you consider that we do not have the right to hold it;
(e) to withdraw consent to our processing of your Personal Information (to the extent such processing is based on previously obtained consent);
(f) to ask us to stop or start sending you marketing messages (e.g. our newsletter) at any time by using the below contact details;
(g) to restrict processing of your Personal Information;
(h) to data portability (moving some of your Personal Data elsewhere) in certain circumstances;
(i) to object to your Personal Information being processed in certain circumstances; and
(j) to not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your Personal Information.
A request to exercise the rights detailed above must be in writing and sent to us via postal mail at the following address:
The Data Protection Officer: Sophia Wang, mail: CustomerCare-HK@lenscrafters.com / Hotline: 852-23438223
We will endeavor to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation.
We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.
CHANGES TO THIS POLICY
From time to time, we may need to use customer information for new, unanticipated uses not previously disclosed in our Policy. We will then post the changes to our website and revise our Policy accordingly. In addition, if we have collected personally-identifying information from you, we will notify you about the changes and secure your consent prior to making use of your information in new ways.
QUESTIONS/CONCERNS/COMPLAINTS
Questions, comments and requests regarding this Privacy Policy are welcomed and should be communicated to [Sophia Wang, Mail address: CustomerCare-HK@lenscrafters.com/ Hotline: 852-23438223]. You may also use these contact details if you wish to make a complaint to us relating to your privacy.
If you have any concerns about our use of your information, you also have the right to make a complaint to the Office of the Privacy Commissioner for Personal Data, which regulates and supervises the use of Personal Data in Hong Kong, and/or to the Macau Data Protection Office, which regulates and supervises the use of Personal Data in Macau.
This policy is written in English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this privacy policy, the English version shall prevail.
