PRIVACY POLICY
SUNGLASS HUT INTERNET PRIVACY POLICY
This website is managed by Luxottica Group S.p.A. (“Sunglass Hut” and “Luxottica”), and the privacy and security measures applicable to this website are designed with the strictest security in mind, so any personal information that you provide via this website is used only for the purposes outlined herein. This privacy policy tells you how Sunglass Hut collects and uses your personal information, who it shares it with and how you can access, change and remove your information. When used in this policy, depending on the context, "we," "our" and "us" refers to Luxottica Group S.p.A. and its subsidiaries, its holding companies (including Luxottica) and subsidiaries of such holding companies, individually and collectively.
HOW WE COLLECT THE INFORMATION
There are many ways that we obtain information from you, including but not limited to: (1) via signup on any of our website(s); (2) from a retail, fax or telephone purchase; (3) from navigational information about where visitors go on our website; (4) when you enter a Sunglass Hut trade promotions/giveaways; (5) anytime you submit a business reply, product, or warranty card; and (6) people who come into contact with Sunglass Hut, for example, at an event.
THE INFORMATION WE COLLECT
When you register online to receive our product information, you will need to provide us with your name, address and e-mail address. If you contact our customer care department, you may need to provide us with additional information so that we can respond to your questions or concerns as completely and thoroughly as possible. In order to provide users and subscribers with the most efficient and enhanced service and to better understand your preferences, we may request your gender, year of birth, shopping preference and product interest. Whether or not you provide this information is entirely up to you. We also may collect additional non-personally identifiable information (for example, browser version, IP address) which will provide information regarding the general use of our website. The navigational information allows us to see which areas of our website are most visited and helps us improve the quality of your online experience by recognising and delivering more of the most desired features and services.
HOW WE USE THE INFORMATION
This website is generally directed to individuals residing in Singapore and Malaysia. As such, all personal information that we obtain about you will be recorded, used and protected by us in accordance with the Personal Data Protection Act of 2012 and this privacy policy. To the extent your personal information is recorded or used by our affiliates in Australia, the United States or Europe it is also covered by current Australian data protection legislation, United States data protection legislation or European Union data protection legislation, respectively, and any other applicable laws. By providing us with your personal information, you consent to us processing this personal information in one or more of the ways described in this privacy policy. We will primarily use your personal information to provide products and services to you. We may also use your personal information for the following purposes:
· To administer a contest, promotion, survey or other site feature and to provide you with the relevant products or services (for instance to deliver a prize you may have won in a contest).
· To analyse visits to the website and learn about the interests of our visitors in the aggregate so we can improve our products and services and deliver the best user experience.
OUR USE OF COOKIES
A cookie is a small removable data file that is stored by your web browser on your computer. Cookies are only used by us to allow you to use the website in the most efficient manner. Cookies allow you to place an order on our website and allow us to enhance and personalise your online surfing experience. For example, we use cookies to:
· Recognise you when you return to our website
· Analyse visitor behaviour
You can choose to have your computer warn you each time a cookie is being sent or you can choose to turn off all cookies. You do this through your browser settings. Please note, however, that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our website. We also work with other companies who use tracking technologies, including web beacons, to serve ads on our behalf across the internet. These companies may collect non-personally identifiable information about your visit to our website about your interaction with our communications, including advertising and e-mails. If you object to web beacons, we recommend that you follow the instructions for deleting existing cookies and disabling future cookies as provided by your web browser provider. We will still know how many of our e-mails are opened and we will automatically receive your IP address, a unique identifier for your computer or other access device but we will not identify you as an individual.
HOW MIGHT WE DISCLOSE THE INFORMATION
Luxottica is made up of many companies all over the world, and different companies have different operations and responsibilities within the larger group. Based on those operations and responsibilities we will share your information with our affiliated companies, who will use that information only in the manner set forth in this policy. We also engage third parties to perform services in connection with the operation of our business. Examples of these services include payment processing and authorization, fraud protection and credit risk reduction, product customization, website evaluation, data analysis and, where applicable, data cleansing. We may need to share personal information with these third parties so that they can perform these services, however, we limit the personal information that we give to them and authorise them to use this information only for the purpose of performing those services and provided they use your personal information in a manner that is consistent with Singaporean law. We share aggregated demographic information about our user base with our agents, including agencies or third party vendors so that they can provide marketing analysis and consult on advertising strategies. This information does not identify individual users. We also may share non-personal information, such as the number of users who visited the website during a specific time period or who purchased a specific product through the website, with our marketing partners, advertisers and others from time to time. This information generally is shared in an aggregated form. We may release personal information if we believe in good faith that: the law or legal process requires it; if we have been advised by counsel; we have received a valid administrative request from a law enforcement agency; or such release is necessary to protect the rights, property or safety of Luxottica, or any of our respective affiliates, business partners, customers or others. As with any business, it is possible that as our business develops, we might go through a business transition, such as a merger, acquisition by another company, sale of all or a portion of our assets or buying online stores or other assets. In such transactions, your information will likely be transferred. You will be notified via a prominent notice on our site and notified of any such change in ownership or control of your personal information. You will be deemed to have consented to the transfer of your personally identifiable information to any such successor entity unless you notify us via email to the contrary within the 30 day period. Personal information submitted to or collected through this website may, in addition to Singapore, be stored and/or processed in Australia, the United States or Europe for the purposes described in this privacy policy. By providing us with your information (including simply using our website), you consent to any such transfer of information outside of Singapore and Malaysia. We do not share, sell or rent to other third parties any personal information that you provide to us, except with your consent or as described in this Privacy Policy.
UPDATING YOUR PERSONAL INFORMATION
We require accurate personal information about you to ensure you receive the best possible service from Sunglass Hut. We take reasonable steps to ensure that your personal information is up-to-date whenever we collect it or use it. If you find that current personal information we hold about you is inaccurate or out-of-date, please contact us and we will correct it.
ACCESSING YOUR PERSONAL INFORMATION
We will provide you with access to the personal information you provided to sunglasshut.sg by allowing you to view, update or correct your information. In order to protect your privacy, we will take steps to verify your identity before granting you access to the private information or enabling you to make corrections. We may accomplish this through the use of passwords and personal data. This information can be accessed by writing to us at the email address below. We prefer to receive written requests as this assists us to verify your identity. We reserve the right to charge a reasonable administrative fee for processing the request.
MANAGEMENT AND SECURITY OF PERSONAL INFORMATION
Sunglass Hut takes reasonable steps to protect any personal information that we hold from misuse and loss. We also take reasonable steps to protect it from unauthorised access, modification and disclosure. Your personal information may be stored in hard copy documents or electronically. Sunglass Hut maintains physical security over hard copy and electronic data storage. Personal information about individuals is stored on servers that sit behind a firewall that is housed within a secure data centre. We monitor activity on the website to prevent any unauthorised disclosure of credit card numbers or other personal information. Notwithstanding this, we cannot guarantee that your personal information will be protected against unauthorised access or misuse, and do not accept any liability for the improper actions of unauthorised third parties. Whilst Sunglass Hut takes reasonable efforts to safeguard the privacy of your personal information, transmissions made by means of the internet cannot be made absolutely secure. Sunglass Hut accepts no responsibility for disclosure of data due to errors in transmission or by unauthorised third parties. Sunglass Hut also accepts no responsibility or liability for third parties such as advertisers or other entities who utilise banner ads and links from our website(s). If you click through to a banner ad or link and submit your information via that banner ad or link, you will be subject to their own privacy policies.
We also use your e-mail address to respond to any inquiries you make online.
CHILDREN'S PRIVACY
If you are a minor, you should surf houseofsunsea.com only with involvement of a parent or guardian. Although we do not specifically direct our website, catalogs or e-mails to children, we strive to provide children with as much customer care as possible without violating their privacy rights. For their protection, we ask that minors not attempt to register with sunglasshut.sg or otherwise provide us with any personal information without the consent of a parent or legal guardian.
UPDATES TO PRIVACY INFORMATION
We reserve the right to make changes to this website, our Privacy Policy, and other policies posted on this website at any time. Please review the website periodically to see any updates to the information provided here. If any of the terms of this Privacy Policy, or other policies posted on this website, shall be deemed invalid, void, or for any reason unenforceable, that term shall be deemed severable and shall not affect the validity and enforceability of any remaining term or condition. This privacy policy was last updated on in July 2019.
NEED MORE INFORMATION
If you have a query on how your personal information is collected or used, or any other query relating to Sunglass Hut’s privacy policy, contact:
Luxottica Group S.p.A
Via Cantu, 2
20123 Milano
Italy
Phone: +39 02 8633400
Email: privacy@luxottica.com
Applicable to Thailand
Last updated: 12 January, 2023
Under this Privacy Notice, we, Sunglass Hut (Thailand) Co.,Ltd. (hereinafter referred to as the "Company"), inform you what personal data of yours we collect, why we collect it, and what we do with it.
Your personal data means any information relating to you, including but not limited to your name, contact details, phone number, age/date of birth, country of residence, social security number, tax identification number and also includes sensitive data such as biometric data, health status, personal medical records (“Personal Data”).
Please take the time to read this Privacy Notice carefully. It is very important that you fully understand how we process your Personal Data and how we protect your privacy. If you have any question regarding our use of your Personal Data, you can of course contact us using the contact details provided below:
Our contact details are:
Sunglass Hut (Thailand) Co.,Ltd.
No. 26/56 TPI Tower 25th Floor Zone 3 Room No.1
Nanglinchee Road, Thungmahamek, Sathorn, Bangkok 10120
Contact Number: 66 2 117 4813-15
The contact details of our Data Protection Officer are:
E:Mail ID : [privacy@luxottica.com]
1. TO WHOSE PERSONAL DATA DOES THIS NOTICE APPLY?
● Customers
2. WHAT PERSONAL DATA WE COLLECT ?
The provision of Personal Data is a requirement in order for us to perform our business activities and carry out our contractual obligations. Please provide us with complete and accurate data, and also inform us if your data needs to be updated. If you do not provide us with complete and accurate data, or if you do not inform us that your data needs to be updated, we may not be able to render or continue certain activities with regard to your relationship with the Company, such as, but not limited to provision of products and/or services to you, administration of our promotions, contests, campaigns, customer surveys, any other initiatives or events. Communications may be sent in various forms, including mail, SMS/MMS, e-mail, phone, social network, instant messaging, applications and newsletters.
We collect the following categories of Personal Data for the purposes (“Purposes”) set out below:
· Identity & Contact information that we use to identify, verify or authenticate your identity and/or contact you for fulfilling sales and customer service obligations, such as name, address, phone number, identification documents, age/date of birth, nationality, gender, photograph, place of birth, country of residence, current location, signature and/or biometric information.
· Finance related Personal Data, to facilitate smooth running of business transactions and customer service for the provision of our products and/or services, including your bank account details and credit/debit card information.
· Health-related and biometric data, and all personal information necessary for the provision of our services to you and necessary for your experience in our stores.
· IT and security-related personal data, including your computer-related data (installed software, internet protocol address, cookies, web browser type, and version, operating system, domain name of your internet provider, device id, location, and/or any information generated from any computer system/s or device/s etc.), data contained in log files or security reports (in particular your IP address, name, location and time of access), on-line account access, log- in and similar credentials, and information about use of such access.
· Video and/or audio recordings and/or photographs during Company events, which we may use in our marketing materials, intranet publications, newsletters or other external platforms with or without editing, copying, publishing or distribution and CCTV recordings or footages which we may use for site security purposes.
· Any other information relating to any individual/s which you have provided to us in any form/s which you may have submitted to us, or obtained through any form of interaction with you whether through any electronic system or with you in person.
Please note that, besides from yourself, we may obtain or receive personal data of yours from other sources such as your family and/or friends (e.g. if you involve them in your feedback correspondences); emails or email chains of customers may contain personal data about you (e.g. in the context of supplier or customer relationship management) and social media sites. These sources may or may not be publicly accessible.
For the Personal Data which we have collected prior to the date on which the Thailand Personal Data Protection Act 2022 has become fully effective, the Company will continue to collect and use such Personal Data in accordance with the manner stated herein. If you wish to update or to withdraw your consent for the collection/use of this data, you can do so by contacting us at the contact details set out herein.
3. HOW WE USE PERSONAL DATA WE COLLECT
We use your personal data to serve legitimate interests or serve lawful purposes such as:
● to perform our business purposes and day to day operations of the Company, including for marketing and/or promotion of our products and services
● to fulfil our contractual obligations within the limits authorized by the laws
● to comply with applicable regulations
● to manage and/or improve relationships with customers, suppliers, employees and other data subjects
In all the above cases, we do not make any automated decisions based solely on automatic processing which may produce legal effects on you, or similarly significantly affect you.
4. HOW LONG WE KEEP PERSONAL DATA WE COLLECT
We will retain your Personal Data set out in this Notice for as long as required to perform the Purposes for which the data was collected, depending on the lawful basis on which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain the Personal Data.
Even if we are not able to outline the various retention periods in a reasonably intelligible format under this notice, we want you to know that we will only retain your personal data for as long as
(i) it is necessary for the relevant purpose,
(ii) it is necessary to carry out our business relationship with you,
(iii) you have consented to it, and/or
(iv) it is required by statutory retention laws such as tax and company regulations.
5. PERSONAL DATA WE SHARE
Please note that we may share or store your Personal Data with companies, organizations, public authorities or individuals outside of the Company. Further, some of the recipients of the data may be located in countries outside the country in which the Company is situated.
These recipient countries may not have the equivalent level of data protection laws as prescribed in local applicable regulations prevalent and applicable to the Company. If we need to transfer Personal Data outside the country, we will take steps to ensure that your Personal Data is protected and safeguarded at a standard of protection comparable to the protection under the local regulation to the overseas recipient. If you would like to obtain the details of such safeguards, you can request these by using the contact details set out below. In some cases, we may request your consent for the international transfer of your Personal Data, subject to the requirements under the local applicable regulations.
6. HOW WE STORE AND PROTECT PERSONAL DATA
We have measures in place to protect your Personal Data against unauthorized access, use, or disclosure including, without limitation, the following measures:
● We implement and maintain sophisticated technical measures to ensure that your personal data is recorded and processed in complete confidentiality and security;
● We implement and maintain appropriate restrictions on access to your personal data, and monitoring the access, use, and transfer of personal data
● We store the Personal Data set out in this Notice in both physical and electronic forms in our servers, databases, cabinets, department lockers, and, in certain circumstances, we may use external data retention service providers to store such Personal Data and relevant documents. In all these cases, we ensure that Personal Data under our custody is protected against any accidental or unlawful destruction, alteration and disclosure as well as against any other unlawful processing.
● All of our employees who have access to your Personal Data are required to enter into non- disclosure or similar agreements, which impose obligations on them to comply with our data privacy and confidentiality requirements;
● We require any business partners and third party service providers with whom we may share your Personal Data to comply with any applicable data privacy and confidentiality requirements;
● We provide data privacy training on a regular basis to our employees and third parties who have access to personal data.
7. WHAT RIGHTS DO YOU HAVE
Under applicable data protection laws and regulations, you have the right to:
● Access to, rectify of, and/or erase of your personal data;
● Restrict or object to its processing;
● Tell us that you do not wish to receive marketing and/or promotional information;
● In some circumstances, require certain of your personal data to be transferred to you or a third party;
● To the extent our processing of your Personal Data is based upon your consent, withdraw your consent, without affecting the lawfulness of our processing based on your consent before its withdrawal.
We are committed to enabling you to exercise your rights and, to do so, you can contact us using the contact information set out at the beginning of this Privacy Notice. Please provide us with the following information, so that we act on your request with all due consideration:
● Your name and surname, and a photocopy of your identity document;
● Your specific request (in other words, what rights you want to exercise); and
● The date of the application and your signature (if you send your application by postal mail).
If you are not fully satisfied with our response, you can also complain about our processing of your personal data to the relevant data protection authority.
8. CHANGES TO THIS PRIVACY NOTICE
We regularly review our compliance with our Privacy Notice, in particular to ensure it complies with new laws and regulations regarding data protection. But, although this Privacy Notice may change from time to time, we will not reduce your rights under this Privacy Notice without your explicit consent.