The controller for your personal data is HOYA Vision Care Europe (HOYA Holdings N.V.) together with HOYA Lens [INSERT COUNTRY] as joint controllers (together hereafter referred to as “HOYA”).
HOYA Holdings N.V., Amsterdamseweg 29, 1422 AC Uithoorn, The Netherlands and HOYA Lens [INSERT LOCAL COUNTRY OFFICE address]
1. Use of personal data
We like to give you a description of the personal data we use, for what purposes and on which legal grounds.
Website visits and requests
- When you visit our website and you request information on our products, tools or services, through the site, we use your name, address, phone number and e-mail address 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 use information on your browsing and interactions with us to improve our site, products and services;
- Order products as an optician
- As an optician you order our products. In this case we register your name, address, e-mail address, internet address, phone number, reports on visits, buying group membership if applicable and sales, order and invoice information 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
- As an (employee of an) optician or healthcare professional you may also participate in training and events organized by HOYA. In case you participate HOYA processes your 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 for upcoming events.
- Personalized newsletters
- If you subscribe to our HOYA Vision Care blogs, HOYA will use your e-mail address to send you newsletters on HOYA products and services. The contents of the newsletters will be determined according to your behavior on the site, your order and sales information, and interactions with us enriched with information from public available sources, the country you are located and products ordered from us. In case you do not wish to receive any more newsletters by e-mail, you can unsubscribe by using the link at the bottom of each mail or by sending an e-mail to email@example.com.
- We may also send you newsletters on our products and services by ordinary mail. If you do not wish to receive those newsletters, please send an e-mail to firstname.lastname@example.org.
- Order lenses as a consumer
- 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 with a warranty card. If, as a reference for your order, the optician provides your name, it is used to identify your order and the warranty card.
- As an end-user you may also choose to use one of our tools to advise you on the type of lenses 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.
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 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 permission, for instance in the event of your newsletter subscription or if you use any of the HOYA Tools to order lenses. Finally, HOYA has a legitimate interest to improve the contents of the website, its products and services according to an analysis of your browsing behavior, purchases and interactions with us.
3. 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;
- Parties act for HOYA as a processor on our behalf.
4. Transfer of data outside the EU
Within the abovementioned purposes for processing of data by HOYA, your personal data are transferred to Hubspot. This company processes data on our behalf in the United States of America. The level of personal data protection in the USA is not considered similar to the EU Regulations on the protection of Personal Data. However, we have entered into a data processor agreement with Hubspot that includes the EU standard contractual clauses for processors and as a result your data are protected accordingly. A copy of these clauses may be obtained by sending a request to DPO@hoya.com.
5. Merger or acquisition
HOYA may transfer its enterprise as a whole or part of its assets to a third party. In that case your personal data shall also be transferred to that party. We shall inform you hereof timely in advance. In case you do not wish to use our services anymore, you may request us to remove your data.
6. Storage period
Personal data will not be kept by us any longer than necessary for the purposes for which they were originally collected or processed further. All personal data will be stored no longer than required by the GDPR and national regulations such as financial and tax obligations. This includes ordering, financial, contact data. Your personal profile is based on order history of 2 years preceding the newsletter.
If as an end user you have made use of our advisory tools, your data are kept for 6 months after the advice was provided.
You have the right to inspect your data and to request to correct, restrict, block or remove them. You also have the right to request a machine-readable subset of your data and store it elsewhere. Where the processing of your personal data is based on your permission, you are at all times entitled to withdraw this permission.
Furthermore, you may always object against the use of your data for direct marketing purposes. You may also object against any other processing for legitimate interest purposes in connection with your personal circumstances.
Requests to exercise the above rights may be submitted by sending an e-mail to our DPO. The Data protection officer for HOYA Europe may be contacted by DPO@hoya.com. You may also at all times file a complaint with the Data Protection Authority.
9. Changes of 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.