The controller for your personal data is HOYA Vision Care Europe Hoya Holdings N.V., Radarweg 29, 1422 AC Amsterdam, The Netherlands (hereafter referred to as “HOYA”).
Our Services are not intended for children, and we do not knowingly collect data relating to children. Children must not use our Services, except where their parent or guardian has provided consent, if this option is available in your location.
If you are a user located in California please see the additional terms relevant to you in the Addendum below.
1. Collection and Use of Personal Data
You may provide some or all of the personal data set out below by contacting us or requesting our Services.
- Website visits and requests: When you visit our Website and you request information on our Services we collect your name, address, phone number, and e-mail address and use it to communicate with you and to comply with your request;
- We may also contact you by telephone if you have indicated to be contacted this way;
- We also collect information on your browsing activity and interactions with us in order to improve our Website, Services, to maintain safety of security of our users and to address and remediate technical issues and bugs.
- If you submit comments or testimonials, those posts contain your first name, last name, country, and testimonial. We use this information solely with your consent for promotional purposes and to provide information to other users to inform them about experiences about our Services or our company. You can withdraw this consent at all times sending an e-mail to email@example.com.
Order products as an eye care professional:
We collect the following information from eye care professionals who order our products or use our Services including name, address, e-mail address, IP address, phone number, reports on visits, buying group membership (if applicable), sales order and invoice information in order to produce and deliver your order and to handle payment, to communicate with you and to provide customer service. Participate in training and events as an optician or healthcare professional:
- We collect the following information from opticians or healthcare professionals who participate in HOYA-organised trainings and events including name, address, email address, phone number, date of birth, information on the event or training and information on sports preferences, to carry out your participation and to invite you to upcoming events.
Order lenses as a consumer via your eye care professional:
- If you order lenses or spectacles with prescription lenses through your optician, your optician will provide us with your prescription details so we can produce and deliver your lenses and a warranty card. Your optician will obtain your consent to provide us with your name in order to identify your order and to produce the warranty card.
- As an end-user, you may also choose (via your eye care professional) to use one of our tools to advise you on the type of lenses or frames that suit your preferences and needs according to your lifestyle. You can also use our tools to provide advice on the most suitable frame according to your face image. In that case, we process your name, gender, age, prescription, satisfaction, lifestyle and face image in order to provide you with this advice. We also use that data in an aggregate form for product development purposes.
- Please note that we may process the data set out above as either a controller or a processor on behalf of the eye care professional, depending on local agreements and circumstances.
- If you subscribe to our HOYA Vision Care knowledge articles (blogs), HOYA will use your e-mail address to provide online articles about HOYA products, services and articles about topics you have selected. In case you do not wish to receive any more notifications by e-mail, you can unsubscribe by using the link at the bottom of each email or by sending an e-mail to firstname.lastname@example.org
- We may also send you newsletters on our products and Services by postal mail. If you do not wish to receive those newsletters, please send an e-mail to email@example.com
2. Legal ground
The most important legal ground for processing your data is that this is necessary for the performance of a contract between you and HOYA, for instance, if you order a product, request certain information, register for an event or place an order.
In some cases, the processing may be necessary to comply with a legal obligation, such as the obligation to keep accurate books and records for financial or tax purposes. In certain cases, the processing is based on your consent, for instance in the event of your subscription to our newsletters, marketing or blogs or if you use any of the HOYA Tools to order lenses. Finally, HOYA has a legitimate interest to improve the contents of its Website, its products, and Services by analysing your browsing behaviour, purchases, and interactions with us.
We use necessary, preference, statistical and marketing cookies and similar technologies. Cookies allow us to personalise content and ads, to provide social media features and to analyse our traffic. This helps us to improve our Services and the way our Website works. You can find more information about cookies and how to manage them here.
You can find more information about cookies and how to manage them here. A change of cookie settings will have no effect on the information collected before such change.
4. Use of personal data by third parties
HOYA does not share your data with third parties, unless:
- You have given us your permission;
- There is a legal obligation to do so;
- When we act on your request or carry out your order to HOYA group companies, or to third-party payment or shipment providers;
- In the event of a merger with or acquisition of HOYA or (part of) its assets by a third party (see more below);
- When we work with service providers and vendors that act for HOYA as a processor on our behalf: Such third parties include: (i) data analytics vendors; (ii) security vendors; (iii) website hosting vendors; and (iv) vendors that help in general operations. These service providers assist us with many different functions and tasks, such as providing data storage and disaster recovery services and communicating with you;
- In our legitimate interests with companies within our corporate family; and
- As necessary with our professional advisors: We will share your personal data with professional advisors such as auditors, law firms, or accounting firms.
5. Transfer of data outside the EU
Within the above mentioned purposes for the processing of data by HOYA, your personal data are transferred to third parties outside of the EU and UK.
The level of protection for your personal data in those countries may not be considered to be similar to your country. We have, however, entered into the EU standard contractual clauses (SCCs) , or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals’ rights and freedoms for their personal data (e.g. Japan). A copy of these SCCs may be obtained by sending a request to DPO@hoya.com.
6. Merger or acquisition
HOYA may transfer its enterprise as a whole or part of its assets to a third party, in connection with an asset sale or purchase, a share sale, purchase or merger, bankruptcy, or other business transaction or re-organisation, in our legitimate interests.
In that case, your personal data shall also be transferred to a prospective buyer, new owner, or other relevant third party as necessary while negotiating, fulfilling or otherwise in relation to a change of corporate control such as a restructuring, consolidation or merger, or the sale or transfer of our assets.
7. Storage period
All personal data will be stored no longer than required by the GDPR and national regulations such as financial and tax obligations.
In case you order products from us, we keep your data as long as reasonably necessary in order to comply with our warranty obligations under the applicable period.
In case you have opted in to receive newsletters from us, your personal profile is based on a history of 2 years preceding the newsletter.
If as an end user you have made use of our advisory tools, your data is kept for no longer than 1 year after the advice was provided.
The storage period for customer testimonials is 3 years after the testimonial is provided.
You have the right to access correct, port, restrict, object or delete your personal data. Where the processing of your personal data is based on your permission, you are at all times entitled to withdraw this permission.
Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests or where we are required by law to retain your personal data.
To exercise any of these rights, you can contact us at DPO@hoya.com.
Furthermore, you may always object against the use of your data for direct marketing purposes.
If you think we have infringed data protection laws, please contact our Data Protection Officer at DPO@hoya.com and we will respond to your request as soon as possible. You can file a claim with the relevant data protection supervisory authority.
Although we do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the website or over email; any transmission is at your own risk.
10. Third-party websites
Our Website may contain links to other online platforms, plug-ins or other applications operated by third parties. We do not control such other sites or applications, and are not responsible for their content, their privacy policies, or their use of your information.
12. Changes to this policy
HOYA reserves the right to change this policy.
Make sure you are always familiar with the latest version of this policy posted here. We will inform you of important changes timely in advance.
14. Addendum for California Residents
The terms of this Addendum apply to residents of California under the California Consumer Privacy Act (“CCPA”) and other applicable laws. The CCPA provides California residents with certain legal rights such as access, deletion, disclosure, or “do not sell.” These rights are not absolute and are subject to certain exceptions.
Collection and Disclosure of Personal Information
Over the past 12 months, through your use of our Services, we may have collected and disclosed the following categories of personal information from or about consumers, as defined in the CCPA:
- Identifiers, such as phone number, name, email address, mailing address, date of birth, gender, age, physical characteristics or description, or health insurance information.
- Internet or other electronic network activity information, including browsing activity and interactions with our website.
- Prescription lens data from eye care professionals or directly from consumers;
- Commercial information, including payment card information and transaction verification information.
We collect personal information for the following purposes:
- To operate and administer the Services requested;
- To fulfill customer orders;
- To communicate with you;
- To improve our services;
- To personalise our services for you;
- To maintain the safety and security of our users; and
- To address and remediate technical issues and bugs.
We disclose each category of personal information to the following types of entities:
- Our affiliate companies within our corporate group who process your personal information in order to operate the Services
- Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing the services to us
- Regulators and judicial authorities and law enforcement agencies
- Professional advisors such as auditors, law firms, or accounting firms.
- Entities that acquire all or substantially all of our business
- With other third parties upon your direction or with your consent
In the past 12 months, we have not sold personal information of California residents within the meaning of “sold” in the CCPA.
Rights under the CCPA
If you are a California resident and the CCPA does not recognise an exemption that applies to you or your personal information, you have the right to:
Request we disclose to you free of charge the following information covering the 12 months preceding your request:
- the categories of personal information about you that we collected;
- the categories of sources from which the personal information was collected;
- the purpose for collecting personal information about you;
- the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
- the specific pieces of personal information we collected about you;
Request we delete personal information we collected from you, unless CCPA recognises an exemption; and
Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or deny goods or services to you when you exercise your rights under the CCPA.
We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.
How to Exercise Your Rights
You can contact us via email at DPO@hoya.com. California residents may also contact us by calling (844) 735-5773. You may also designate an authorised agent to make these requests on your behalf. For requests by an agent, we may require you to verify your identity directly with us, and directly confirm with us that you provided the authorised agent permission to submit the request.