Luxottica and its related bodies corporate knows that you care how information about you is used and recognises the importance of protecting the privacy and the rights of individuals in relation to their personal information. This Privacy Policy explains how we collect and manage your personal information. In this Privacy Policy, “Luxottica”, “we”, “our”, “us” refers to Luxottica Retail Australia Pty Limited (ACN 000 025 758) and Luxottica Retail New Zealand Limited (NZCN 636829), their related bodies corporate, and the ultimate holding company EssilorLuxottica, including related entities and stores that trade under the brands “OPSM”, “Ray-Ban”, “Sunglass Hut”, “Laubman & Pank”, “EyeQ”, “Clearly”, “Costa Del Mar”, “Nuance Audio” and “Oakley”.
What is your personal information?
The term ‘personal information’ has the meaning given to it in the applicable privacy laws, for Australia Privacy Act 1988 (Cth) and for New Zealand Privacy Act 2020. In general terms, personal information is any information that can be used to personally identify you. This may include your name, address, telephone number, email address, profession or occupation. If any of the information we collect from you identifies you, or is reasonably capable of identifying you, then it will be considered personal information.
Some personal information is also ‘sensitive information’ under the Privacy Act (for example, health information or biometric information). We explain how we handle sensitive information in the ‘Sensitive Information’ section below.
What personal information do we collect and hold?
We may collect the following types of personal information:
● full name;
● mailing or street address;
● email address;
● telephone number;
● your gender and date of birth;
● your lifestyle, occupation and hobbies;
● health fund details;
● your employer;
● details of the products and services you have ordered or purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
● your payment details, such as your credit card information;
● details of your style and preferences, such as your choices of glasses, lens, frame or factors relevant to your hearing aid;
● details regarding your participation in loyalty programs, including your interactions with us through any loyalty program, such as your membership tier, points balance and redemption history;
● any information that you provide to us directly through any of our websites, mobile apps or indirectly through the use of our websites, mobile apps or online presence, through our representatives or otherwise;
● information you provide to us through our Customer Care team or our Customer Experience Surveys;
● government identifiers such as Medicare number, Customer Reference Number and driver licence, or any other concessional numbers or identifiers where required;
● details about your emergency contact, legal representative, or guardian;
● biometric information (for example facial scanning using our virtual try-on technology or virtual measurement tools); and
● medical information and medical history about you, such as the parameters of your prescriptions and information about the health of your eyes and / or hearing.
Sensitive Information
We understand that some of the personal information we gather is sensitive information, such as details about your health, including medical history, prescriptions, eye scans, audiogram results and health conditions. Collection of this information is necessary for the provision of health services. Rest assured, your sensitive information will be used and disclosed when necessary for the purpose it was collected or for a closely related secondary purpose, unless you give us permission for other uses or required by law.
We are required to collect some information, such as your name, address and date of birth as part of our legal and regulatory obligations, including under the Health Practitioner Regulation National Law as enacted in each state and territory of Australia and for New Zealand, the Health Practitioners Competence Assurance Act 2003 and the Hearing Services Rules of Conduct 2012. If you refuse to provide us with information required to comply with our legal and ethical obligations, then we may not be able to provide health services to you.
How we collect your personal information
We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect it in different ways including:
● when you visit any of our stores, including through CCTV systems and other cameras in our stores or related coverage of public areas and store entrances;
● when you visit a store for a service, such as an eye test or hearing test;
● when you attend a vision screening organised by us at a public or industry event or a vision screening organised by your employer;
● when you visit any of our stores to purchase eyewear products (such as sunglasses, frames, lenses and contact lenses), hearing devices, and associated products and services;
● when you book an eye test or hearing test using our website, our apps, over the phone or when you visit our store or attend our screening clinic;
● when you contact us via our social media pages (such as Facebook, Twitter or Instagram);
● when you enter a competition;
● when you order or complete a purchase order with us, including online purchases;
● when you visit our mobile van clinic for an eye test;
● when you complete a survey;
● when you create a membership or loyalty account, or join a loyalty program;
● when you contact us or otherwise interact with us, including during phone calls, webchats or via social media, including when you contact us with an enquiry or complaint in relation to our products and services;
● through your registration, access and use of our website or mobile apps; and
● when you apply for a job with us.
We may also collect personal information from third parties including:
● from third party companies such as credit reporting agencies, law enforcement agencies and other government entities (such as the Department of Veterans Affairs, Medicare, the Commonwealth Hearing Services Program (HSP), the Commonwealth Department of Health and Aged Care);
● from data analysis agencies and other commercial partners;
● from employment recruitment agencies;
● from health funds;
● from our franchisees who operate optometry practices under any of our brands;
● from third party optometry practices which have been converted to our stores;
● from our related bodies corporate;
● from financial service and insurance providers (such as ‘Buy Now Pay Later’ providers);
● third parties that operate within our stores, where you provide information directly to those third parties, they collect and hold that information in their own right subject to their own Privacy Policy;
● from other optometrists, audiology professionals and health practitioners with your consent; and
● referrals from your doctor, employer, or other healthcare professionals.
When you use our website or our mobile apps, we may use aggregated, anonymous analytic tracking via a third party to gather information about the way the website or app is used.
Cookie notice
In some cases we may also collect your personal information through the use of cookies. When you access our website by typing the address in your browser or by clicking on our advertisement on a third party website, we or a third party on our behalf may send a “cookie” (which is a small summary file containing a unique ID number) to your computer. This enables us to recognise your computer and greet you each time you visit our website without bothering you with a request to register or to log in. It also enables us to keep track of products or services you view so that, if you consent, we can send you news about those products or services. We also use cookies to measure traffic patterns, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online products and services. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them.
We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track users’ movements, and gather broad demographic information.
We also work with other companies who use tracking technologies, including web beacons, to serve ads on our behalf across the internet. These companies may collect non-personally identifiable information about your visit to our website about your interaction with our mobile app or communications, including advertising and e-mails. If you object to web beacons, we recommend that you follow the instructions for deleting existing cookies and disabling future cookies.
What happens if we can’t collect your personal information?
Whether or not you provide personal information to us is entirely up to you. If you do not provide us with the personal information described above, then depending on the context, some or all of the following may happen:
● we may not be able to provide the requested products or services to you, either to the same standard or at all;
● we may not be able to process your order and purchase;
● we may not be able to process health fund discounts or rebates;
● we may not be able to provide certain services or products that are eligible for government or private rebates, discounts or vouchers;
● we may not be able to process any third party discounts or benefits;
● we may not be able to provide you with information about products and services that you may want, including information about discounts, sales or special promotions;
● some functions our website or mobile apps may be restricted or not operational;
● we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful
Anonymity / pseudonym
Whenever possible, we offer you the choice to remain anonymous or use a pseudonym. However, there may be instances where this isn’t possible, particularly when it’s impractical or legally necessary to confirm your identity, such as when providing health services.
For what purposes do we collect, hold, use and disclose your personal information
We collect personal information about you so that we can understand your needs better, provide you with the most appropriate eye care and audiology services, along with a range of eye wear products and hearing devices, improve our products and services, and to provide you with a high quality of customer service.
We also collect, hold, use and disclose your personal information for the following primary purposes:
● to provide products and services to you and to facilitate the use of any of our websites or apps, including personal shopping and “virtual try on” experiences;
● to provide products and services to you as a result of a contractual arrangement with your employer;
● to process credit and debit card payments via third party payment processors such as Afterpay, QCard and Paypal (we do not hold this information);
● to process health fund claims through third parties such as such as TyroHealth;
● to answer enquiries and provide information or advice about existing and new products or services;
● to advise you on your eye care and hearing needs including when it’s time to come and see us for another eye test or hearing test;
● advise you if we or one of our optometrists or audiologists relocate;
● advise you if your store has merged rebranded, relocated or closed;
● to assess the performance of the website and mobile apps and to improve the operation of the website and mobile apps;
● to assess our customer service and to improve our customer service to you;
