Privacy Policy

The Personal Data we collect depends on the point of contact through which you interact with us, as well as the purposes of this interaction as described hereafter in this Privacy Notice and are also limited to those which are relevant and appropriate for this interaction.


3.1 Categories of Personal Data

3.2 Processing of Special Personal Data

For the purposes set out below, we may process Personal Data which are qualified as “sensitive” Personal Data, under the meaning of local data protection laws and notably under art. 9 of the GDPR (“Special Personal Data”). This is particularly the case of Health and Medical data and the data related to your care 

Please note that, when this happens, we process such Sensitive Data only:
    • where it is required or allowed under local applicable legislation; 
    • when any conditions for Processing under local applicable data protection laws are met; 
    • while implementing adequate safeguards to ensure the protection of such Special Personal Data, and
    • when one of the alternative conditions set out by applicable data protection laws (notably art. 9 of the GDPR) is fulfilled.

However, please note that, when your explicit consent is required as legal basis to process your Sensitive Data and you don’t grant such consent to us, you will not be able to benefit from the services you are asking for and for which the processing of Sensitive Data is necessary.

We are required to use your data for purposes defined according to the nature of our relationships. Thus, depending on the context in which your data is collected, it may be used for one or more of the following purposes: 

5.1 What modalities do we use to process your personal data?

The processing of your Personal Data is carried out, electronically and manually, only within the limits necessary to pursue the purposes outlined above.

We undertake to protect your Personal Data. 

We advise that the password is one of the protection mechanisms of the account. Therefore, you are invited to use a password sufficiently secure and stored in a safe place, limiting access to it on your own computers and browsers, disconnecting it after having visited the Website and/or the Services. 

All Personal Data provided by you is kept on secure servers, adopting adequate security measures to protect Personal Data from non-authorized access, to maintain the accuracy of Personal Data and guarantee the proper use of information. 

Furthermore, a secure system for authorizing credit card payments and identifying fraudulent activities is used. We use the standard SSL (Secure Sockets Layer) to protect the confidentiality of your Personal Data.


5.2 We share your Personal Data with other Affiliates of the Group

EssilorLuxottica is a global organization with offices and operations throughout the world and most of your Personal Data relating to is stored and processed within a range of global applications that is used globally by the Affiliates of EssilorLuxottica. The majority of the processing of your personal data is carried out through the concentrated services of two entities: Essilor International and Luxottica Group S.p.A.

We may share your Personal Data with certain Affiliates or Brand of the EssilorLuxottica group, based on your preferences and interests about these Affiliates or Brand, for the purposes set out in this Privacy Notice, in each case in or outside your country, as permitted and required by applicable law and/or in other circumstances with your consent.

We may also share your information for our internal business purposes.


5.3 Is your Personal Data transferred to third parties?

a) Service provider 

We may disclose your Personal Data with our third parties service providers entrusted with processing activities that provide services or assistance and advice to us, with special – but not exclusive – reference to technology, accounting, administrative, legal, insurance, IT, marketing, customer service, data subjects requests management, data analysis matters. 

Each service provider will act as a data processor, on behalf of and in accordance with the instructions received from us, by virtue of a specific agreement in place per Article 28 of the GDPR, or as an independent data controller   depending on the cases. 

We require that any such third-party provider is subject to strict control and implements appropriate guarantees of security and confidentiality of your Personal Data. 


b) Sales or merger

We may also disclose Users Personal Data:
    • in the event that we sell any business or assets, in which case we may disclose Users Personal Data to the prospective purchaser of such business or assets; or
    • if we sell, buy, merge with, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, Users Personal Data may be among the transferred assets.

We may share all of the information we collect in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.


c) Third Party Social Network Service Providers

If you decide to log into the Website and/or the Services through social network applications or to link your account to your public profiles available on social networks, and share your actions through the Website and/or the Services on those channels via the corresponding plug-ins (e.g. Facebook Connect, I like, fb share, etc.), these third-party services may be able to collect information about you, including information about your activity on the Website or/and the Services, and they may notify you connections on the third-party services about their use of the Website and/or the Services. Their use of your Personal Data is not governed by this Privacy Notice but in accordance with their own data protection policies. 


d) Legal process 

We may disclose your Personal Data to any authority, court, administrative body, or other authorized third party (including, without limitation, counsel), where the disclosure of Personal Data is required by law, regulation or court order or where such disclosure is necessary for the protection and defense of our rights.


e) Other instance

We may ask if you would like to disclose your information with other third parties who are not described elsewhere in this Privacy Notice. Furthermore, we do not sell, rent, or lease your Personal Data to third parties but we may, from time to time, contact you on behalf of external business partners about a particular offer that may be of interest to you. In those cases, without your consent, your Personal Data would not be transferred to the third party.

The abovementioned recipients will process your Personal Data as data controllers, data processors or people in charge of processing, depending on the circumstances.

More info on the categories of data processors is available on request.


5.4 Is your Personal Data transferred across the border?

Given the presence of EssilorLuxottica in many countries around the world and to provide you with personalized service worldwide, some of your data may be collected, accessible or stored outside your country of residence.

As a result of the above, your Personal Data may be accessed and/or transferred to countries which do not have equivalent data protection laws to those required within the European Economic Area (EEA).

In such cases, EssilorLuxottica ensures that, always, appropriate safeguards are implemented to ensure that your Personal Data is processed in accordance with applicable legislation. In this respect, where your Personal Data is processed by another EssilorLuxottica entity, the safeguards are based on the commitments taken based on (ii) a dedicated transfer agreement binding upon the EssilorLuxottica entity involved in the processing and (ii) a set of common rules applicable through the EssilorLuxottica Group Data Protection Policy. 

Where your data is processed by EssilorLuxottica entities or third parties located outside the European Economic Area, EssilorLuxottica ensures that specific contractual protection is implemented to ensure that this requirement is addressed in accordance with the Applicable Legislation.

For further information regarding the appropriate or suitable safeguards and how to obtain a copy of them, you can contact us with the modalities as per this Privacy Notice.


5.5 For how long do we retain your Personal Data?

We retain all or part of your Personal Data for the time strictly necessary for the reason: 

            (a) to meet applicable statutory requirements for data retention,
            (b) to meet and comply with our legal and/or contractual obligations,
            (c) as long as necessary to carry out each of the purposes mentioned in this Data Protection Privacy Notice, including for the purposes of satisfying any legal, accounting, reporting requirements. 

To determine the appropriate retention period for Personal Data, we consider jointly the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In particular, we hereby specify that your Personal Data will be retained for a period of 10 years for our invoicing and accounting purposes, save for the circumstances in which applicable laws may provide for different retention requirements.

Furthermore, if you have consented to the processing of your Personal Data for marketing activities (e.g., commercial and promotional communications, commercial newsletters, personalized offers, periodical updates related to our products, services initiatives and events, etc.), such a Data will be retained for 10 years as from the last interaction as for customers and for 2 years from the last interaction as for prospects. Last interaction is defined as the last contact you made and that is traceable by our systems or salespeople.

In any case, please note that, as general rule, within EssilorLuxottica, retention and archiving of Personal Data will not exceed 10 (ten) years overall calculated as of the first record and/or consent renewal and/or any other relevant interaction, exception made for further legal hold obligations.

In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you, such as for statistical analysis, monitoring and/or enhancing our medical devices, R&D purposes, training AI models, etc.

For any additional information on the retention of your Personal Data, you can contact us at the email address set out in section 8 of this Privacy Notice.


5.6 We keep your data safe, updated and accurate

EssilorLuxottica has a responsibility for the security and accuracy of the Personal Data that it processes about you and also for keeping data up to date. EssilorLuxottica has taken steps to eliminate duplicate copies of data and to facilitate updating of data that may change over time.

EssilorLuxottica regards the protection of Personal Data as an essential priority. 
In this respect, EssilorLuxottica has implemented appropriate measures and safeguards to protect the Personal Data it processes.

This is reflected in EssilorLuxottica’s procedures described in the EssilorLuxottica Group Data Protection Program, guidelines and policies and in the actual measures implemented throughout the Group.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality. These measures range from technical security measures that protect IT systems to the physical security measures employed at EssilorLuxottica sites. EssilorLuxottica also requires its staff to participate in information security trainings. Details of these measures may be obtained from the Group Information Security Department.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

You can exercise any of the following rights, subject to verification of your identity where necessary:

a) Right of Information and Access
You may request the confirmation of the existence of your Personal Data and to be informed of its content and source and obtain a copy of those Personal Data which our databases currently contain. 

b) Right to Rectification
You may request to rectify what Personal Data our databases currently contain. We may not accommodate a request to change Personal Data if we believe the change would violate any law or legal requirement or cause the information to be incorrect. 

c) Right to Restriction of the Processing
When applicable, you may restrict the processing of your Personal Data. When such restrictions are not possible, we will advise them accordingly. You can then choose to exercise any other rights under this Privacy Notice, including withdrawing your consent to the processing of your Personal Data.

d) Right to Object to the Processing 
When applicable, you have the right to object to the processing of your Personal Data on grounds relating to your situation, if the processing is based on our legitimate interest. In addition, you have the right to object at any time to processing where Personal Data are processed for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing.
When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Notice, to include withdrawing your consent to the processing of your Personal Data. 

e) Right to Erasure 
If you wish to have your Personal Data deleted, then you may submit a request. Upon receipt of such a request for erasure, we will confirm receipt and confirm once your Personal Data have been deleted. 

f) Right to data Portability
Upon request and when possible and where applicable by local laws, we can provide to you with copies of your Personal Data. If such a request cannot be honoured, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Notice, including withdrawing your consent. Where applicable, we will ensure such changes are shared with any trusted third parties.

g) Right to Withdraw your Consent
Where processing is based on consent, you may withdraw his/her consent at any time to the processing of your Personal Data. Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your Personal Data.

h) Right to lodge a complaint with the relevant data protection supervisory authority
If you are not satisfied with the way we process your Personal Data and/or respond to a request to exercise the rights you have exercised, you can lodge a complaint with the relevant data protection competent supervisory authority.


In order to exercise your rights, you can use the privacy form or by contacting nuanceaudio.privacy@luxottica.com

Please note that if you exercise your rights pursuant to this Privacy Notice, your request(s) will only target the Personal Data collected by EssilorLuxottica for the purposes defined here above in this Privacy Notice.

Consequently, if you purchased Nuance Audio in the stores of any of the other EssilorLuxottica Group’s entities or third parties/independent sellers, to exercise your rights on the Data provided in occasion of such a purchase, you shall refer to the privacy notice of the relevant selling entity. This means, by way of example, that even if you decide to revoke your consent to the marketing communications sent out by EssilorLuxottica pursuant to this Privacy Notice but you consented to marketing communications in the store in occasion of the purchase of the Nuance Audio, you may still continue to receive marketing communications by the relevant seller, including marketing communications on Nuance Audio as well. EssilorLuxottica also provides you with tools to update and modify your Personal Data. Any Nuance Audio Users can access and update their own information (e.g., through their account).
You may also change and update your preferences about how you would like to receive e-mails or other communications from EssilorLuxottica and request the deletion of your Data.

8.1 Contact of the Dat Controller

The Data Controllers for the processing of your Personal Data are set out in Section 1.1 of this Privacy Notice.Should you have questions or comments on this Privacy Notice or on any data processing carried out by us, we may be contacted at the postal address set out in Section 1.1 above and/or at the email address specified in the preceding Section 7 and in the following Section 8.2.


8.2  Contact of the Data Protection Officer

EssilorLuxottica has appointed a Data Protection Officer which can be contacted at the following email address nuanceaudio.privacy@luxottica.com or through the other contact methods provided for in section 8.1 above.

For legal and/or organizational reasons, this Privacy Notice may undergo changes. We suggest, therefore, checking this Privacy Notice regularly and referring to the latest version of it, we will post the date it was last updated at the top of this Privacy Notice.

In any case, an updated version of Privacy Notice will be always available on the Website and the Services, and we will provide additional notice to you if we make any changes that materially affect your privacy rights.