(EFFECTIVE AS 20.09.2014)
The Arnette.com website (hereinafter "Website") is managed by Luxottica Retail North America Inc. 4000 Luxottica Place, Mason, Ohio 45040, a subsidiary of Luxottica Group S.p.A. ("Luxottica"), and the applicable security and privacy measures on this website have been defined and developed to guarantee that personal information is processed correctly in compliance with local and international safety and privacy regulations. This policy illustrates how Luxottica, directly or through its subsidiaries, collects and/or uses personal information, how this information is shared and how one may access, change or delete personal information.
Luxottica acknowledges and complies with the individuals’ right to privacy regarding personal information. As proof of its commitment towards privacy, Luxottica has defined this policy within the wider scope of a global management model on privacy, to ensure total compliance with privacy as the foundation of Luxottica’s company culture. All personal information supplied by you through this website is used exclusively for the objectives described below.
1.1 Responsibility for data processing Any personal information given or collected by connecting to the website will be processed by Luxottica as data controller.
Personal information will be processed by the Luxottica staff deputed to handle the personal information collected in relation to your use of this Website (including, but not limited to):
• staff authorised to manage the website and supply the related services, e.g. customer services, management of Luxottica Computer Systems;
• staff in the finance, administration and accounting department;
• staff in the marketing department. In addition, Luxottica may request its service providers to carry out some processing operations on its behalf and according to the instructions provided by Luxottica. These providers will process personal information as data processors based on adequate contractual commitments, and they include, by way of illustration:
• suppliers of services to manage the Computer Systems and the Website (e.g. hosting providers, market and analyst service providers, database management and maintenance services);
• suppliers of online payment services;
2. PROCEDURES FOR COLLECTING INFORMATION
Luxottica acquires personal information of users through the Websites.
There are several procedures with which it is possible to obtain such information, such as for example:
• registration on the Websites;
• purchases made on-line, by e-mail;
• browsing information of a user on the Websites;
• participating in competitions, promotions, events available through the Website;
• contacting and/or sending information in relation to any warranty;
• contacting the customer services or any other contact point of Luxottica.
3. TYPES OF INFORMATION COLLECTED, PURPOSE AND PROCESSING PROCEDURES
3.1 Source of personal information Luxottica processes different types of information on the user collected from different sources, such as:
• information provided directly by the user;
• information obtained from automatic tracking systems when using the Website and its services.
3.2 Type of personal information Luxottica may collect and process the following personal information of the user:
3. Information provided by the user during the registration process or when completing the order (e.g. name and surname; e-mail address; password; gender; country (nation); postal address and phone numbers for deliveries and contacts related mainly to the process of the order) and other information contained in any correspondence or requests sent by the user. We may also ask the user to provide some information if problems with our service on the Website are reported;
4. Information relating to the user’s social network profile, if public.
If the user decides to log in through social network applications or to link his/her Luxottica account to the user’s public profiles available on social networks, and share his/her actions through the Website on those channels via the corresponding plug-ins (e.g. Facebook Connect, I like, fb share, etc.), some data published by the user on his/her social network will be collected by the Website and processed for the corresponding functions. The use of the said plug-in entails sharing the corresponding actions and information on the related social networks;
5. Information relating to the use of the Website by the user. For security purposes we process the log files related to each session when the user logins into his/her account, as well as information on payment transactions that will be processed through our provider;
6. Navigation information. When the user uses the Website, we use some technologies that automatically collect certain items of information relating to the way in which the user uses our products and services, 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, identification as registered user or not, technical information that may include the URL from where a user originates, browser information, language. This information helps us to continuously improve the browsing experience and the mechanisms of purchase of our 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.
3.3 Nature of providing personal information When the users are requested to provide personal information, e.g. when registering on the Website, Luxottica will inform them what personal information is necessary for the registration and what is optional. Failure to provide some items of information may make it impossible to set up the account (e.g. name and surname) or purchase the products (e.g. credit card or debit card information). The provision of other information is entirely optional, but if not provided, some of the features of the services offered by Luxottica might be unavailable or limited.
3.6 Payment details If purchases are made using the website, credit card information and other financial information of a user can be processed and used by third parties who process the purchase and payment transactions on our behalf. Luxottica may also gather additional information, such as postal code, mobile phone number and the log of the user’s transactions.
3.7 Underage users’ data The Luxottica website is not intended for minors under the age of 18 years and Luxottica does not intentionally collect personal information from them. If information about minors is unintentionally recorded, Luxottica will provide to cancel the personal information of those minors in a timely manner.
4. PURPOSES OF THE PROCESSING
The information we collect, including personal information, are used for the following:
• to provide the services available through the Website (e.g. management of the registration process and access to the account, account management);
• to manage orders, to supply products and services, to process payments, to transmit orders, products, services;
• for the technical management of the Website and its operational functions (including logistics), including solving any technical problems, statistical analysis, tests and research;
• to prevent or uncover fraudulent activities or misuse that is damaging to our website or threatening the security of the transactions;
• to manage promotions and contests, if any;
• to fulfil the user’s requests (e.g. management of requests for information);
• to manage promotions or contest as available from time to time on the Website;
• to communicate with the users for purposes related to the supply of the service;
• to promote Luxottica's products, service and brands, including sending commercial, promotional or information communications and periodic updates (e.g. via e-mail, phone, SMS/MMS, post and through social network) relating to Luxottica's products, services, initiatives and events organised by, or in collaboration with, Luxottica.
If the user consents to the processing of his/her data for marketing purposes, the said data may also be processed for the purpose of conducting, by post, telephone or e-mail, statistical analyses, surveys and market research relating to Luxottica’s products and services.
5. OPT IN/OUT
If the user consents to the processing of his/her data for marketing purposes, the said data may also be processed for the purpose of conducting, by post, telephone or e-mail, statistical analyses, surveys and market research relating to Luxottica’s products and services. Such consent may be subsequently changed (opt-out) by the user accessing his/her profile on the Luxottica account or sending a communication to customer service.
If a user who receives e-mail messages from the website wants to opt out of receiving those communications in the future, the user may do so by following the instructions in the messages or the procedures described above in this clause. Luxottica undertakes to carry out the opt-out requests received, but a user may still receive communications from us for no more than ten business days while their request is being processed.
6. TRANSFER AND SHARING INFORMATION
In addition, a user’s information may be shared with third parties for the following reasons:
• to permit a merger, acquisition or sale of all or part of our company assets;
• in response to proceedings;
• to comply with the requirements of the laws in force, to protect the safety of an individual, to protect the rights and the property of Luxottica, including the need to have the Terms and Conditions of Use observed, and to hinder deceptions or security or technical problems;
6.1.1 Social media plug-ins This Website uses social media plug-ins furnished by the most important social networks (e.g. facebook.com and twitter.com).
When visiting the webpage the browsing data may be transferred directly to the social networks concerned, even without a user’s direct interaction. The user acknowledges and agrees that the operation of social networks' plug-ins is managed directly by the company that manages the corresponding plug-in.
When the users use the plug-ins available through the Website (e.g. log in with their access credentials to a social network, or link their Luxottica account to their account on a social network, click on the Facebook “Like” or “Share” button), the User’s browser establishes a direct connection with the server of that social network, which sends the contents of the plug-in directly to the user’s browser.
If the personal information will be transferred to countries that do not provide the same level of protection, or in any case an adequate level of protection (e.g. the United States of America), of personal information, we ensure that each service provider enters into specific contractual obligations according to the applicable data protection legislations (including the execution of the Standard Contractual Clauses as approved by the European Commission) unless we can rely on any other legal basis for transferring personal information.
7. SECURITY AND PROTECTION OF INFORMATION
Luxottica undertakes to protect users’ information. Luxottica advises that the password is one of the protection mechanisms of the account, therefore users are invited to use a password sufficiently secure and stored in a safe place, limiting access to it on their own computers and browsers, disconnecting it after having visited the site. Luxottica also monitors the activity of the Website to avoid non-authorised circulation of credit card numbers or other personal information. Furthermore, a secure system for authorising credit card payments and identifying fraudulent activities is used.
Luxottica uses the standard SSL (Secure Sockets Layer) to protect the confidentiality of your personal information.
Luxottica undertakes to protect the information received from users. All personal information supplied is kept on secure servers and within its internal systems. Luxottica uses adequate safety measures to protect information from non-authorised access or non-authorised changes, and from the circulation or distribution of data.
To prevent non-authorised access, to maintain the accuracy of the data and guarantee the proper use of information, Luxottica uses adequate physical, electronic and managerial procedures to safeguard and protect the information and data stored in our system. Information on purchase transactions (e.g. credit card number) is handled securely through selected suppliers that guarantee that they have adopted the most adequate security measures.
Although no computer system is completely secure, Luxottica believes that the measures it has implemented reduce the possibility of security problems to an appropriate level for the type of data involved.
8. STORAGE AND DELETION OF INFORMATION
Luxottica accesses, uses, processes, files and stores personal information collected only for the purposes described in this document and in accordance with the consent expressed by the user. Specifically, Luxottica keeps personal information consistent with:
• the purposes for which they were collected;
• the consent received from the user;
• local and international regulations. Personal information is kept and deleted in accordance with Luxottica security policy for the time necessary to achieve the purposes for which data were collected and further processed, including any retention period required under the applicable legislation (e.g. retention of accounting documentation).
A user may request the deletion of his/her data and of the user's account, if any; in such case, Luxottica will satisfy the user's request provided that, and to the extent, Luxottica is not required under the applicable law to retain such personal information.
9. USER'S RIGHTS IN RELATION TO PERSONAL INFORMATION
Without prejudice to the other rights set forth under section 7 of the Italian data protection code (D.Lgs. 196/2003), or other applicable law, Luxottica offers tools to users to update and correct the personal information given. Every registered user may access his/her own information and update it.
It is also possible for users to modify and update their preferences on how they wish to receive e-mails or other communications from Luxottica. Users may also request that their information on their account is deleted. According to section 7 of the Italian data protection code, the user has certain rights, including the right to obtain confirmation at any time as to whether we keep his/her information, to be informed of such information and origin, to check their accuracy and updating, and to request his/her information is supplemented, or rectified.
The user is also entitled to request that data processed in violation of the law be erased, anonymized or blocked, and to object to any further processing of this information for legitimate reasons. In order to exercise these rights and to request information relating to the users’ data we keep, you may write to the following e-mail address firstname.lastname@example.org. Luxottica will respond within a reasonable time frame, after verifying the writer’s identity.
10. CONTACT INFORMATION
12. LINKS TO THIRD PARTY WEBSITES