Privacy Notice
Shamir Website

[Last Revised: June, 2022]

Under this Privacy Notice, we, Shamir Optical Industry Ltd. and/or its subsidiaries (collectively – “Shamir”), inform you what personal data of yours we collect when you visit our website (“Website”) or we provide you with services (including the Shamir Online platform) through our Website (“Services), why we collect it, and what we do with it. Your personal data means any information or opinion about you, in particular your name and contact details such as your telephone number or your email address.

Please take the time to read this Privacy Notice carefully, it is very important that you fully understand how we process your personal data and how we protect your privacy. This Privacy Notice should be read together with our Terms of Use. By accessing our Website or using our Services, you agree to be bound by, and abide by, the terms of this Privacy Notice and the accompanying Terms of Use, both of which govern your use of our Website and our Services.

If you have any question regarding our use of your personal data, you can of course contact us as set out below:

Our contact details are: Shamir Australia Pty Ltd, 1/23 Luke St, Lytton QLD 4178; info@shamirlens.com.au.

WHO WE ARE

Shamir Optical Industry Ltd. is an Israeli based company. Shamir Optical Industry Ltd. and its subsidiaries are joint controllers of the data processed about you through the use of our Website or our Services.

WHAT PERSONAL DATA WE COLLECT

Data we collect when you visit our Website

When you access our Website, we automatically collect and store some of your data in our server logs and in cookies, which are small files we send to your computer.

This data does not allow us to directly identify you; however, it records data related to your browsing on our Website, such as the pages that you accessed, the date and time you accessed to these pages, your search queries, information on your device (hardware model, operating system version, unique device identifier, Internet protocol address, hardware settings, browser type, browser language), the date and time of your request, and the referral URL.

The provision of your personal data is not required if you only want to visit our Website. This means that you may refuse to accept cookies by configuring your web browser accordingly (for more information, refer to the ‘help’ section of your web browser). However, refusing cookies is likely to disrupt your navigation on our Website, in particular by preventing you to access to certain parts of it.

Data we collect when you sign up or when you order products

Some of the Services offered on our Website require you to sign up. If you want to use these Services, we will ask you to provide us with personal data, and we ask that you provide us with complete and accurate data, and also to inform us if your data needs to be updated. If you do not provide us with complete and accurate data, or if you do not inform us that your data needs to be updated, we may not be able to provide you with the Services you requested.

We collect the following categories of personal data:

• Identification data, including your name, telephone number, email address, postal address, country, employer, login and password, country.
• Credit-related information, including credit reports and trade references.
• IT data, including data related to your browsing on our Website (including on the Shamir Online platform), such as the pages that you accessed, the date and time you accessed to these pages, your search queries, information on your device (hardware model, operating system version, unique device identifiers, Internet protocol address, hardware settings, browser type, browser language), the date and time of your request, and referral URL.
• Data that relates to customers of Eye-Care Service Providers, including names and prescription information that is relevant in order for us to be able to provide our products and services to Eye-Care Service Providers.

Data we collect when you act as guarantor

In some cases, we may require a client to appoint a guarantor.  In those circumstances, we collect the following categories of personal information:

• Identification data about the guarantor, including their name, address and date of birth; and
• Information about the witnesses to the guarantee deed, including their name, address and occupation.

HOW WE USE PERSONAL DATA WE COLLECT

We only use your personal data within the limits authorized by the laws and regulations. Sometimes, we will use your personal data because the laws and regulations require us to do so. In any case, we do not make any automated decisions solely on automatic processing which may produce legal effects concerning you, or similarly significantly affect you.

We use your personal data for the following purposes:

• We use your identification data to receive and process your message when using the contact form and being able to answer it in case it contains a request from you. Such a process is based on your consent, as expressed through clicking on the sending button of the contact form. We also use your identification data to create and manage your Shamir Online user account, and to provide the service to you; such a process is based on the necessity for performance of a contract with you, namely the Terms of Use of the Website; and to communicate with you and send you marketing materials based on your consent. We use your credit information when you sign up as a new customer of Shamir, and information collected from a guarantor if we make a call on the guarantee in connection with exercising our rights under the guarantee.
• We use your IT data to allow correct display of our Website and Shamir Online platform on your device. Such a process is based on the necessity for performance of a contract with you, namely the Terms of Use of the Website.

You may provide us, through the Shamir Online platform, with personal data of your customers (“End-users”); such as their name, eye-related prescription, etc. End-users must be informed by you about how you process their personal data and in particular that their personal data will be communicated to us for management of orders.

HOW LONG WE KEEP PERSONAL DATA WE COLLECT

The retention periods for your personal data depend on the purpose for which we collect this data is processed for. We will retain your personal data only for the later of the period (i) necessary for the respective purpose, (ii) necessary to carry out our contractual relationship with you, and (iii) required by statutory retention laws.

PERSONAL DATA WE SHARE

We will not sell, rent, or license your personal data; however, we may share your personal for the purposes described in this Privacy Notice, as follows:

• Shamir’s Affiliates or related parties: we may share your information with Shamir’s affiliates for legitimate business purposes, including processing operations, such as data hosting and maintenance.
• As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, we may share your personal data as part of the transaction.
• Third Party Service Providers: We may use third party service providers (including cloud storage and web hosting providers) to host the Services and store data processed in the scope of the Services; or other service providers that may handle payment or credit card processing, data management, customer data pooling or aggregating, feature administration, email distribution, market research, information analysis, and promotions management. These service providers will only have access to the personal data needed to perform these limited functions on our behalf.
• We may share your personal data with advertisers and analytics companies who may use it to deliver targeted advertisements to you on the Services. Similarly, these advertisers may share personal data with us that they have independently gathered or acquired. We may also share encrypted versions of personal data we have collected in order to enable our advertising partners to perform data analysis or for advertising-related use.
• Credit reporting bodies and referees to obtain credit reports and trade references if you are a new customer. We may also disclose certain personal information about the business information of our client if we register an interest on the Personal Properties Securities Register at the time of an account application
• Legal or Regulatory Obligations. We may disclose and/or share your personal data to comply with legal or regulatory obligations (including to comply with a court order, judicial subpoena or other subpoena or warrant), industry standards, judicial process, and our policies, as well as to protect against, identify, investigate, prevent and respond to fraud or illegal activity (such as identifying and responding to incidents of hacking or misuse of our Service), and claims and other liabilities.

Some of the recipients of the data are located in countries outside the European Union/European Economic Area, including in Israel, the USA, Hong Kong, India and Thailand. Recipients of your data may be in countries that do not provide the same standard of legal protection for your information as in your country.

For recipients located in Israel, the European Commission has decided that this country ensures an adequate level of protection by reason of its domestic law or of the international commitments it has entered to.

For recipients located in the USA, Hong-Kong, India, Australia or Thailand, there is no adequacy decision by the European Commission for such countries; this means that the level of data protection in such country is not comparable with the level of data protection in the European Union therefore, we use as appropriate technical, organizational and contractual safeguards to secure your personal data.

In case you require additional information concerning the transfer and/or safeguards of your personal data we invite you to contact us at info@shamirlens.com.au.

HOW WE HOLD AND PROTECT PERSONAL DATA

We store your personal information in hard copy and electronically. Electronic information is stored by third party storage providers. We hold personal data across multiple systems and may combine it in one central database. We have measures in place to protect your personal data against unauthorized access, use, or disclosure, including without limitation:

• We implement and maintain technical measures intended to ensure that your personal data is recorded and processed in a confidential and secure manner.
• We implement and maintain appropriate restrictions on access to your personal data, and monitoring of access, use, and transfer of personal data.
• All of our employees who have access to your personal data are required to enter into non-disclosure or similar agreements, which imposes obligations on them to comply with our data privacy and confidentiality requirements.
• We require any business partners and third party service providers with whom we may share your personal data to comply with any applicable data privacy and confidentiality requirements.
• We provide data privacy training on a regular basis to our employees and third parties who have access to personal data.

WHAT RIGHTS YOU HAVE

Under applicable data protection laws and regulations, you have right:

• Of access to, rectification of, and/or erasure of your personal data;
  • To restrict or object to its processing;
  • To tell us that you do not wish to receive marketing information;
  • In some circumstances, to require certain of your personal data to be transferred to you or a third party;
  • to the extent our processing of your personal data is based upon your consent, to withdraw your consent, without affecting the lawfulness of our processing based on your consent before its withdrawal.

If you are a French user, you also have the right to set guidelines for the retention, erasure and communication of your personal data after your death.

We are committed to enable you to exercise your rights: to do so, you can contact us at the details set out at the beginning of this Privacy Notice. We will need to verify your identity before responding to your request. If we decide to refuse your request, we will tell you why in writing and how to complain.  We will respond to you within a reasonable period of time to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint. If you are not satisfied with our response , you can also lodge a complaint about our processing of your personal data with a local data protection authority. We can provide you with details of your local data protection authority on request.

CHANGES TO THIS PRIVACY NOTICE

We regularly review our Privacy Notice, in particular to make it compliant with new laws and regulations regarding data protection. However, we will not reduce your rights under this Privacy Notice without notifying you.