privacy-statement-for-this-website

PRIVACY STATEMENT FOR THIS WEB SITE
Last modified: 10th July 2018

This Privacy Notice ("Notice") describes what personal information we collect, why we collect it, how we use, process and share it and your legal rights. This Notice doesn’t apply to practices of companies that we do not own or control, including other companies you might interact with through our Services.  

When we say Transitions Optical (“we”, “our” or “us”), we mean Transitions Optical Limited, a company which is based in Ireland.

This Notice applies to users of our products (including prospective users), employees of our business partners or corporate vendors, vendors who are sole traders who we procure goods and services from, eye care professionals and visitors to our websites and premises (“you”, “your” or “yours”). It also applies to individuals who apply for jobs with us.

You provide us with your personal information when you contact us, complete our forms, speak with us or visit our website, online registration pages or social media platforms.

We use personal information to fulfil our contracts, create and administer our online portals, accounts and registrations, manage our research, promotional and marketing activities and to respond to you (together the “Services”).

Please take the time to read this Notice carefully. It is important to us that you fully understand how we are processing your personal information and how we are protecting your privacy.  If you provide us with personal information about someone else, please make sure that you have their permission and make them aware of this Notice.

If you have any questions regarding our use of your personal information, you can of course Contact Us using the details below.

WHAT PERSONAL INFORMATION DO WE COLLECT?

Personal Data is defined in data protection laws and put simply is information which either by itself or with other information held by us or available to us can be used to identify you. When we provide the Services online and in-premise, we collect and process your personal information. The type of information we gather will depend on how you interact with us and whether you are a user of our products, an eye care professional, a vendor who is a sole trader, an employee of one of our business partners or corporate vendors or applying for a job with us. The personal information we collect includes:

  • Personal details and contact information: This includes information such as your full name, telephone number, e-mail address, home address, age and occupation.  In the case of eye care professionals, employees of our business partners or corporate vendors or vendors who are sole traders, it also includes work information (e.g. company name, work address, work phone number, work email address, job title).  In the case of vendors who are sole traders, it may include bank account details and a tax reference number.

  • Surveys and training initiatives: We also collect information about you when you agree to participate in one of our research or marketing surveys, our training programs or other initiatives for eye care professionals like the Transitions 30 Day Challenge. In the case of eye care professionals, this may include information about your dispensing practices, experience with our products and other feedback.

  • Customer support information: If you send us support requests, comments or feedback, you may also provide us with additional information. We retain this information to respond to you and to enhance our Services and products. This includes information you provide us which is related to your use of our products and other information you share with us such as where, for example, you have elected to take our Transitions 30 Day Challenge. It also includes any content you share with us in complaints or concerns which you submit to us.  It may be necessary for us to share your information with our affiliates or business partners in order to deal with your request, comment or feedback.

  • Sales and marketing related information: This includes information such as our products that you buy, use or dispense, your marketing preferences as well as your number, email address, signature and work information (e.g. company name, work address, work phone number, work email address, job title) and information about how you interact with our marketing materials (such as whether you opened one of our marketing emails).

  • Video surveillance and visitor logging information:  We monitor both the external and certain internal areas of our premises using video surveillance systems. If you visit our premises, we record your image using video surveillance and ask you to provide your name and contact details on arrival for security and health and safety purposes.

  • Log Data: When you use our online Services, we automatically collect information from your browser, computer or mobile device including certain log data, such as your IP address, browser type, hardware type, unique device ID, the version of your operating system and your activity within the Services. We use log data to improve our websites.

  • Cookies: We and our partners also use cookies and similar technologies to operate and provide our website, to support advertising on and off our website (including on social media) and for other purposes. For example, we and our partners use cookies to remember your choices, such as your language preferences, and otherwise to customize our services for you. See our Cookie Notice to find out more.

  • Job information: If you apply for a role with us, we will collect the information you provide to us such as your CV and other information we generate in considering your application, such as notes from interviews, references, background checks and other relevant information.

We may get this information from you, when you interact with us through or on social media, from your device directly or, in certain appropriate cases, from your eye care professional if you are a user of our products.  Please ensure that you provide us with complete and accurate information and inform us if it needs to be updated.

We may combine the information collected about you through the various sources above.

Sometimes we require you to provide us with information for contractual or legal reasons. We’ll normally let you know when such information is required and the consequences of failing to provide it.

We do not knowingly collect personal information relating to children.

HOW DO WE USE THE PERSONAL INFORMATION WE COLLECT?

We use your personal information in accordance with applicable data protection laws and regulations. In doing so, we rely on a number of separate legal bases to lawfully process such information.

 

In particular, we use and process your personal information for the following purposes:  

  • To fulfil our contracts with customers, partners and vendors: We process your personal information in order to perform any agreement(s) which you have entered into with us and to fulfil our contracts with business partners, vendors and suppliers. We do this based upon our legitimate interests in fulfilling contractual commitments and developing and sustaining our business, as well as where it is necessary to perform our contractual obligations with you.

  • To create and administer accounts and registrations: When you create an account with us or register in connection with a research, marketing or promotional initiative, we process your personal information in order to create and administer your account or registration. In the case of the Transitions Hub, we may use your personal information to alert you to new images or products that are available, updates or new services.  We use your name and other personal information to identify you as a registered user and to determine your level of access to our digital content. We use your e-mail address to confirm your download and in certain instances, to notify you of new image products that are available or other news.  We do this based upon our legitimate interests in developing and sustaining our business, as well as where it is necessary to perform our contractual obligations with you.

  • To operate, improve and evaluate our business: We use your personal information for day to day operational and business purposes, to improve our business including by developing and analysing our products, technologies and services, attracting talented individuals to work with us, providing customer support, managing our communications and responding to your comments and queries. For example, we use information that we receive via the Contact Us form to continuously improve our products and technologies.  We do this based upon our legitimate interests in developing and sustaining our business.

  • When you engage with us: We use your personal information to deal with queries, complaints or suggestions you provide us with and to analyse feedback you give us about your wearer experience. We do this based upon our legitimate interests to engage with individuals who reach out to us and take on board their feedback.

  • For direct marketing: We use your personal information to keep you informed about our business, products and services. We do this if you have subscribed for and consented to the receipt of such information.

  • To participate in promotional and marketing activities: We use your personal information in connection with your participation in competitions, promotions and marketing activities, such as our Transitions 30 Day Challenge.  We send you information if you have consented to this or based on our legitimate interests to market our business, products and services.

  • For market research: We use your information to undertake market research and statistical analysis. We do this based upon our legitimate interests in improving and evaluating our business. We may combine and aggregate personal information to help us understand our business and develop our products and services.

  • To support safety and security: It is in our legitimate interests to use your personal information to prevent unlawful activities and misuse of our products and services, to protect the safety and security of our customers and personnel, to protect our property, to deter crime and to investigate any security incidents or accidents.  

  • In connection with legal proceedings: We process your information if necessary to defend our interests in legal proceedings.

In certain other circumstances, we also use your personal information based upon consent you have given us or to comply with our legal obligations (such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request).

PERSONAL INFORMATION WE SHARE

To provide the Services, we share your personal information with certain third parties. For example:

  • Affiliates: Depending on the circumstances and with your consent, we may share your information with our affiliates within the Transitions Optical corporate group (including Transitions Optical Inc. which is based in the USA) and the Essilor corporate group (being Essilor International which is headquartered in France and its group companies), who may in turn share information with us, for the purposes outlined in this Notice.

  • Business Partners:  It may be necessary for us to share your information with our business partners, such as our customers, distributors and other entities in the distribution chain, in order to deal with your request, comment or feedback in a satisfactory manner.

  • Service providers: We work with third-parties providers who are data processors providing their services to us to help us operate our business, provide, improve, understand, customize, support and market our products and services. When we share your information with third-party service providers, we require them to use your information on our behalf in accordance with our instructions and terms.

  • Professional advisers: We may share your information with our professional advisers, for example our lawyers, where necessary, such as in connection with the defence of legal claims.

  • Following the law and protecting rights and interests: We may work with or assist law enforcement and government agencies when it is in our or others’ legitimate interests and where we have a good-faith belief that such cooperation is reasonably necessary to protect our or others’ interests, property or rights.

  • Merger: We may share some or all of your personal information in connection with, or during negotiation of or diligence for, any merger, financing, acquisition or dissolution, transaction or proceeding involving a sale, transfer or divestiture of all or a portion of our business or assets. In the event of insolvency, bankruptcy or receivership, information may also be transferred as a business asset.

TRANSFERS OUTSIDE OF THE EUROPEAN ECONOMIC AREA

Like most international businesses, we operate globally. As a result, your personal information may be disclosed and transferred to a country outside of the European Economic Area (EEA) in connection with the Services. For example, we may store your personal information on servers in the United States of America. Some of these countries may not have the same levels of data protection as are present in the EEA.

In certain cases, we use a legal mechanism known as “standard contractual clauses” to protect personal information that is transferred outside the EEA. Standard contractual clauses refer to contracts between companies transferring personal information that contain standard commitments approved by the European Commission protecting the privacy and security of the information transferred.

Alternatively, we will transfer personal information to a country which is deemed to have adequate protections in place pursuant to adequacy decisions issued by the European Commission. To access the current list of countries for which there is an adequacy decision in place, please click https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

To learn more or to request a copy of any standard contractual clauses which may relate to your personal information you can Contact Us using the details below.

COOKIES

We use technologies such as cookies, which deposit small data files stored on your computer or mobile device. We use cookies and other technologies to help keep track of website visits, to track user trends and to improve the areas of our website that our users find valuable.  Our cookies do not collect personally identifiable information, nor do we share them with anyone. We collect this non-personal information to help us monitor traffic and enhance your experience of our websites.

You can withdraw your consent to our use of cookies using your browser settings or your device’s limit ad tracking settings. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited. For more information about how we use cookies and similar technologies and how to manage them, please see our Cookie Notice.

HOW DO WE PROTECT PERSONAL INFORMATION?

We have measures in place to protect your personal information against unauthorized access, use or disclosure. In particular:

  • We implement and maintain industry standard technical measures and internal procedures which are designed to ensure that your personal information is processed in a confidential and secure manner.

  • We implement and maintain appropriate restrictions on access to your personal information.

  • All employees who have access to personal information commit to information privacy and confidentiality requirements and are provided with privacy training.

  • We require any business partners and third party service providers that process your personal information on our behalf as data processors to protect your personal information with appropriate security measures.

HOW LONG DO WE KEEP THE PERSONAL INFORMATION WE COLLECT?

We retain your information for as long as is necessary to fulfil the purposes outlined in this Notice or for such longer retention period as may be required or permitted by applicable law. For instance, we may keep your information to comply with our legal obligations (e.g. tax laws), to resolve disputes, to enforce our agreements or as otherwise permitted by law.

The precise time periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or anonymised, whether we continue to require it for the purpose it was collected and other relevant criteria. For example,

  • Personal information collected in connection with competitions or promotions may be retained for 3 years from collection.

  • Personal information disclosed to us through our Contact Us form may be retained for up to 18 months from the date you contacted us.

YOUR RIGHTS

If you reside in certain territories, including the European Economic Area, you benefit from a number of rights in relation to your personal information. While some of these rights apply generally, certain rights apply only in certain limited cases. We have summarised these below:

  • Right to withdraw consent: If we rely on consent for the processing of your personal information for a particular purpose(s), you can withdraw that consent to our future use of your personal information for those purpose(s) at any time by Contacting Us using the details set out below.

  • Right of access: You have a general right to find out if we hold personal information relating to you. You also have a general right to obtain a copy of such personal information.

  • Right to rectification: You have the right to rectify any information we hold about you that is inaccurate.  Please let us know if the information you have provided us with has changed so that we can keep it up to date.

  • Right to erasure: You have the right, in certain cases, to have erased any personal information we hold about you, provided there is valid grounds for doing so.

  • Right to restriction: You have the right, in certain cases, to temporarily restrict the processing of your personal information, provided there is valid grounds for doing so.

  • Right to data portability: You have the right, in certain cases, to obtain a commonly used machine-readable copy of the electronic information you provided to us for transfer to you or another controller if required.

  • Right to object: You have the right, in certain limited cases, to object to the processing of your personal information.

  • Cookies and similar technologies: You can manage cookies and similar technologies by following the steps set out in our Cookie Notice.

  • Direct marketing: You have the right to require us to stop using your personal information for direct marketing purposes.  You can get us to stop sending you marketing communications by clicking the unsubscribe link in the messages we send you or by Contacting Us using the details set out below.

  • Right to lodge a complaint: If you are unhappy with how we have acted in handling your personal information, you have the right to lodge a complaint. Our lead data protection supervisory authority is the Irish Data Protection Commission (“DPC”). For further information on your rights and how to complain to the DPC, please refer to www.dataprotection.ie or contact the DPC using the following details:

Office of the Information Protection Commissioner

Canal House

Station Road

Portarlington

Co. Laois

R32 AP23

Ireland

+353 (0)761 104 800

info@informationprotection.ie

When exercising your rights, you should make the request in writing by mail or by email by Contacting Us using the details set out below. To help us process your request, we ask you to provide us with your full name; your specific request and your signature (if you send your application by postal mail).

SOCIAL MEDIA

If you interact with us through or on social media platforms, for example Facebook, YouTube, Twitter, Instagram or LinkedIn, you can find out information about how our social media partners collect and use your information and what arrangement we have with them on their website(s).  

CONTACT US

If you have any questions about this Notice, or any concerns or complaints with regard to the administration of this Notice, you can contact us:

By mail: Data Protection Contact, Transitions Optical Limited, IDA Industrial Estate, Dunmore Road, Tuam, Co. Galway, Ireland H54 RD25

By phone: +353 (0)93 70600 and ask to speak to the Data Protection Contact

By email: privacy@transitions.com

 

CHANGES TO THIS PRIVACY NOTICE

We will update this Notice from time to time, particularly to maintain compliance with evolving personal information protection laws and our business needs. When we make changes, we will update the “Last modified” text at the top of the Notice and post it on our websites. If we make material changes to it or the ways we process personal information, we will notify you (by, for example, prominently posting a notice of the changes on our websites before they take effect).