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Privacy Notice

Last Update: 19 August 2024

This Privacy Notice outlines how we handle information that can directly or indirectly identify an individual (personal data) and it explains what personal data is collected and processed by Satisloh AG and the group of companies belonging to Satisloh AG (referred to as ā€œSatislohā€, ā€œweā€, ā€œusā€, or ā€œourā€) when conducting its business, who uses your personal data, for what purpose, for how long, and what rights you have in this context.

1. Who we are and how to contact us

Satisloh AG is a company incorporated under the laws of Switzerland, with registered office at Neuhofstrasse 12, 6340 Baar, Switzerland, registered with the Commercial Registry of the Canton of Zug under registration number CHE-107.363.527.

The group of companies belonging to Satisloh AG is made up of the following legal entities with offices located across the globe:

Country

 

Company

 

Brazil

Satisloh Do Brasil Ltda,

China

Satisloh (Zhongshan) Ltd.

France

Delamare Sovra SAS

France

SCL International SAS

Germany

Satisloh GmbH

Hong Kong Special Administrative Region of China

Satisloh Asia Limited

Italy

Satisloh Italy S.r.l.

Switzerland

Satisloh Holding AG

Switzerland

Satisloh AG

United States

DAC Vision Incorporated

United States

Satisloh North America, Inc.

 

We, Satisloh AG and the group of companies belonging to Satisloh AG, are - in the context of the applicable data protection law - the data controller of your personal data, which alone or jointly determine the purposes and means of the processing of your personal data.

In case of any data privacy related questions or if you wish to exercise your rights under section 9 Satislohā€™s data privacy organization may be contacted at privacy@satisloh.com. If you would like to exercise any of your rights under applicable data protection law, please complete the relevant form here.

Besides contacting Satislohā€™s data privacy organization, you always have the right to approach the competent data protection authority with your request or complaint.

2. Where are the personal data collected from?

The personal data we collect about you depends on the context of your interactions with us, the purposes of this interactions, the products, services and features that you use, your location and applicable law.

We use different methods and various sources to collect data from and about you. We collect and obtain information:

  • Provided directly by you

We collect personal data that you provide directly through our external and internal websites or using applications, or online services (hereinafter ā€œsitesā€) or other communication channels (for example via e-mail, chat, phone, SMS/MMS, postal service), for example, during registration process, the creation of an account on our sites, or when completing online forms to contact us for request, feedback or complaint, subscribing to a newsletter, subscribing to receive marketing communications from us, participating in surveys or registering for webinars/events that we are organizing.

We do not intentionally collect sensitive personal data (for example health data, data about political opinions, religious or philosophical beliefs, and biometric data for identification purposes), unless you provide us with such data. While there may be free text boxes on our site where you are able to enter any information, we do not intend to process sensitive personal data. You are not required to provide, and should not disclose, sensitive personal data. If you choose to provide any sensitive personal data in this manner, you acknowledge you consent to the collection and processing of this sensitive information.

If you register on our site, your personal data will be stored in our CRM and ERP system. If you have opted out of receiving marketing communications, your basic contact details will remain on our opt-out list.

  • Using automatic tracking systems

When you visit our site, we may use cookies and other tracking technologies (collectively ā€œCookiesā€) that automatically collect certain personal data from your device relating to the way you are using our site. ā€œCookiesā€ are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets). You can consent to or reject Cookies other than to technically necessary Cookies for our sites through our cookie settings in the footer of dacvision.com. You can also do so by adjusting your web browser controls.

  • From social network profile

If you decide to log into the sites through social network applications or to link your account to your public profiles available on social networks, and share your actions through the site on those channels via the corresponding plug-ins (e.g. Facebook Connect, I like, fb share, etc.). The use of the said plug-in entails sharing the corresponding actions and information on the related social networks (see section 6).

  • Through visits in our offices, production facilities etc.

When you visit our offices, production facilities etc., information may be collected during the registration, negotiation or purchase or procurement process, the creation of quotation, the acceptance or adjustment of purchased products and/or services that can be carried out in our facilities. We also use surveillance systems (for example security camera, CCTV) in our facilities for purpose of security, access control, fraud and loss prevention, and for operational purposes.

  • From you when you correspond via email or chat

If you correspond via email or chat with a Satisloh recipient, your emails resp. chats will be scanned by the tools Satisloh operates to maintain the security of its IT infrastructure.

  • From you when you correspond via phone and voice mail services

When you call Satisloh personnel, only your phone number will be stored on our servers and will be delivered to the recipient of your call on its phone and via an email. Under certain conditions, we also keep records of calls from customers and other requestors and maintain a transcript of chats for quality assurance and quality management. No other personal data is collected but technical logs and reports may be stored for trouble shooting purposes.

  • From you when you apply for an employment

Any application data received for the purpose of processing the application procedure, which may be transmitted in various ways. The information that we collect, the manner in which it is used, and the timing in which it is gathered varies depending on the country in which you apply. You may find further information about Satisloh North America collects and processes your application data in the USA career center in the privacy notice specified here.

If an employment contract is concluded with you, the data provided will be processed for the purpose of managing the employment relationship. If no employment contract is concluded with you, the application documents will be deleted in accordance with section 5 of this Privacy Notice, except where it has been individually agreed with you to retain the data for a longer period in order to be able to contact you in the event of future job offers.

  • From you when you are an employee

Further Satisloh-internal privacy notices are available in the Satisloh Intranet (Satisloh Intranet access required).

  • From you when you act as reporter on the EssilorLuxotticaā€™s reporting channels

Satisloh provides employees and other stakeholders outside Satisloh/EssilorLuxottica the opportunity with a means to confidentially, and either anonymously or on a disclosed basis, to report on activities which involve unethical or illegal behavior that is in violation of our highest ethical and legal standards or otherwise inconsistent with the EssilorLuxottica Code of Ethics. Reporting may be sent via e-mail, signed or anonymous, to the following address: compliance@essilorluxottica.com or via the existing EssilorLuxottica Ethics Points. The respective ethics point contains its own privacy notice which describes the practices EssilorLuxottica follows.

  • From other sources

As far as it is not unlawful we may obtain information about you from other sources, such as your employer who is acting as our business partner, data analytics providers, marketing or advertising service providers, service providers for fraud prevention, credit agencies (for example credit reports), associations, contractual partners, vendors that provide services on behalf us, banks, insurance companies or from public sources and authorities (for example debt collection registers, land registers, commercial registers), or the media and internet including social media, information from legal proceedings in which you appear (e.g. witness statements), documents concerning you (.e.g. power of attorney, recommendations, references), or we may receive data from other companies within our group. We also create information based on our analysis of the information we have collected from you.

3. What personal data may we process about you?

In the context of your interaction with us we may process the following categories of personal data:

CATEGORY OF DATA

TYPES OF DATA

Identification information

 

Including such as name and surname, e-mail address, gender, date of birth, country of residence, postal address, phone numbers, job title, job function, role, education.

Payment information

 

Including your bank details, data related to your credit card for the purchase of products through the sites (payments are made via a secure platform, supplemented by control measures, including encryption of contact details) and details about products which you have purchased from us.

Profile and Commercial data

 

Including account name, password, personal data published on your social network, billing and delivery addresses, details about products and/or services which you have requested or purchased from us (in store or online, including your request for quotation, order, tracking and invoices, amount and type of purchases) and your interests, preferences, complaints, feedback and survey responses, powers of attorney, signature authorizations, declaration of consents and information relating to training attendance/completion and to webinars/events captured through event-related forms, such as dietary restrictions, hotel and flight information, registration/participation status, media interview attendance and previous event experience.

Marketing and Communications Data

Including your preferences in receiving marketing from us, your communication preferences and information contained in any correspondence or requests sent by you to us or asked to you by us if problems with the sites or purchased products and services are reported.

Device information

Including the IP address or other unique code of your device (computer, mobile or other devices), identification as registered user or not (login data), technical information that may include the URL, time zone setting and location, browser information and language.

Navigation information

Including information regarding your interactions with our sites, emails, products or advertisements and statistical data relating to these interactions.

 

4. For what purpose do we use your personal data?

When conducting business and operating our various web presences and other communication channels, we process personal data of the people we interact with, including customer, partners, suppliers, vendors, candidates, and any other people with whom we interact. You can find further information on the legal basis of our processing in section 10.

Satisloh may process your personal data for one or more of the following business purposes depending on the nature of our relationship and the context in which your data is collected:

PURPOSES

DETAILS

Follow-up and execution of our contractual relationship, e.g. your (respective your employers) orders offline and online and the after-sales services management

  • Formalize a quotation and/or a contract (including employment contract);
  • Manage product and/or service sales, offline and online orders (purchase, payment terms, delivery and supply of products and services);
  • Manage your invoicing, your warranty;
  • Manage follow-up and provide after-sales service and customer relations (including, for example, returns, warranty and customer support);
  • Manage safety, security, access control with respect to our facilities.

Transaction and potential unpaid invoices management

  • Carry out secure banking payments (with reference to invoicing obligations);
  • Manage incidents related to payment and debts;
  • Process potential unpaid invoices:
    • Identify your unpaid invoices
    • Inform you of this unpaid amount, of the means available to you to regularize it, of the possibility of making observations and of requesting a review of your situation if necessary.

Account and inscriptions creation and management

  • Allow you to register to our sites and create your own account;
  • Provide the services available through the sites (e.g. management of the registration process and access to the account, account management, the reminder for products in the shopping cart, etc.);
  • Manage your client profile;
  • Permit you to join our engagement programs;
  • Allow you to participate in our contests and initiatives promoted.

Communication between us

  • Send you commercial and promotional communications and periodical updates (e.g. via e-mail, phone, SMS/MMS, postal service, social network and newsletter) related to our products, services, initiatives, webinars and events;
  • Manage our personalized commercial offers based on the analysis of your personal data related to spending volume, product category, and methods of purchase;
  • Fulfil your requests via e-mail, chat, phone, SMS/MMS, postal service (e.g. management of requests for information, responding to inquiries and exercise of your rights (section 9), booking of webinars, events, providing the ā€œshare with a friendā€ feature, etc.).

Analyses purposes

  • Managing of personalized content and communications;
  • Carry out statistical analyses on the customer audience;
  • Analyze the performance of our sites, our media investments and marketing campaigns, and our web orders;
  • Market research;
  • Improvement and development of our products, services and operations.

Legal obligations complying

  • Comply with the requirements of the laws, regulations, directives, protocols, recommendations from authorities, industrial standards and internal regulations, risk management and corporate governance (certain automatic or manual processes are designed to conduct checks in relation to economic sanctions, export control and anti-money laundering legislation);
  • Implement the decisions of public authorities;
  • Data retention with regard to accounting and tax obligations;
  • Prevention and control of crime and fraud (certain automatic or manual processes are designed to verify your online payments and to combat fraud involving payment methods and identity theft).

Legitimate interests pursuit

  • Send you commercial communications via e-mail, chat, phone, SMS/MMS, postal service on similar products, events and services already provided to you, unless you object to such a processing at the time of the collection or on the occasion of each communication;
  • Attracting, identifying and sourcing talents and processing and managing applications for roles at Satisloh, including the screening and selecting of candidates;
  • Managing trainings, providing instructions;
  • Exercise or defend legal claims in court proceedings or in administrative or out-of-court procedures, investigations, relating to our rights, of our group companies and/or of our representatives, shareholders, officers and directors;
  • Enable the technical management of the sites and its operational functions, including solving any technical problems, providing support, reporting and hosting of data or performing tests, maintenance, improvements, updates and upgrades that cannot be performed through non-personal data;
  • Prevent or identify fraudulent activities or misuses of the sites or against the EssilorLuxottica group and/or the users of the sites;
  • Complete a potential merger, sale of assets, transfer of all or a material part of its business, or financing transaction by disclosing and transferring the personal data to the third party or parties involved in the transaction as part of the transaction;
  • Conduct, surveys and market research relating to our products and services by post or e-mail;
  • Anonymize personal data in order to perform statistical analysis;
  • Safeguarding other legitimate interest that cannot be named exhaustively.

5. For how long do we retain your personal data?

We retain all or part of your personal data for the time strictly necessary for the following reasons:

(a)          To meet applicable statutory requirements for data retention;

(b)          To meet and comply with our legal and/or contractual obligations;

(c)          For as long as necessary to carry out each of the purposes mentioned in this Privacy Notice, including for the purposes of satisfying any legal, accounting, reporting requirements.

To determine the appropriate retention period for personal data, we consider jointly the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

6. Who are the recipients of your personal data?

In relation to our contracts, the sites, our services and products, our legal obligations or otherwise with protecting our legitimate interests and the other purposes set out in Section 4, we may share your personal data with third parties, in particular with the following categories of recipients:

The below mentioned recipients will process your personal data on our behalf (as data processors) or as joint controllers with us or as separate controllers, depending on the circumstances.

  • Group companies

For the purpose of and to the extent necessary to conduct our business relationship with you, we may grant access to or transfer your personal to other Satisloh group companies and EssilorLuxottica group companies since Satisloh AG is an entity within the EssilorLuxottica group. An overview of the Satisloh AG group entities is available here. We sell certain products and services to our customers only via local business relationships and in this case, we may transfer your personal data to our respective local Satisloh affiliates conducting the business relationship with you.

An overview of the EssilorLuxottica group entities is available here. EssilorLuxottica is a global organization with offices and operations throughout the world and some of your personal data relating to is stored and processed within a range of global applications that is used globally by the affiliates of EssilorLuxottica. Some of the processing of your personal data is carried out through the concentrated services of two entities: Essilor International and Luxottica Group S.p.A.

  • Service Providers

To be able to deliver our products and services efficiently and focus on our core competencies, we work with service providers in Switzerland and abroad who process your data on our behalf or as joint controllers with us or who receive data about you from us as separate controllers in various areas. These include, for example, IT services, information transmission, marketing, sales, logistics, communication or printing services, facility management, security and cleaning, organizing and holding events and receptions, debt collection, credit agencies, address verification provider (for example to update address lists in case of relocations), fraud prevention measures and services from consulting companies, lawyers, banks, insurers and telecommunication companies.

If Service providers process your personal data as joint or separate controllers they inform you about their independent data processing activities in their own privacy statements. More information on how Microsoft processes data can be found here; for the use of Microsoft Teams in particular here.

If you decide to log into the sites through social network applications or to link your account to your public profiles available on social networks, and share your actions through the site on those channels via the corresponding plug-ins (e.g. Facebook Connect, I like, fb share, etc.), these third-party services may be able to collect information about you, including information about your activity on the sites. Their use of your personal data is not governed by this Privacy Notice but in accordance with their own data protection policies.

Google+              https://policies.google.com/privacy

Twitter                 https://twitter.com/en/privacy

YouTube             https://support.google.com/youtube/answer/2801895?hl=en

LinkedIn              https://www.linkedin.com/legal/privacy-policy

Facebook           https://www.facebook.com/policy.php

Pinterest             https://policy.pinterest.com/en/privacy-policy

Instagram           https://help.instagram.com/519522125107875

TikTok                 https://www.tiktok.com/legal/privacy-policy?lang=en.

  • Contractual partners including customers

This refers to customers (for example service recipients), vendors and our other contractual partners as this data disclosure results from these contracts. If you work for one of these contractual partners, we may also disclose data about you to that partner in this regard. These recipients also include contractual partners with whom we cooperate or who carry out advertising for us and to whom we may therefore disclose data about you for analysis and marketing purposes (these may again be service recipients, but also sponsors and online advertising providers). We require these partners to send you or display advertising based on your data only with your consent.

  • Authorities

We may disclose your personal data to any authority, court, administrative body, or other authorized third party in Switzerland and abroad (including, without limitation, counsel), if we are obliged or entitled to by law, regulation or court order or where such disclosure is necessary for the protection and defense of our rights.

  • Other instances

We may ask if you would like to disclose your information with other third parties who are not described elsewhere in this Privacy Notice. For example, we may transfer your registration data based on your consent or as otherwise indicated by your request to companies listed on the registration page of a Satisloh webinar or event. These recipients may receive your personal data as co-organizer or sponsor of the event and will use your registration data for the purposes of your participation in the event. They will provide you directly with any legally required information about their processing purposes and how you may exercise your rights.

Other recipients include other third parties in relation to agency relationships (for example if we share your data with your lawyer or your bank) or persons involved in administrative or legal proceedings. If we cooperate with the media and share materials with them (for example photos), this may also affect you depending on the circumstances. The same applies if we publish content (for example photos, interviews, quotes, etc.), for example on our website or in our other publications.

As part of our business development, we may sell businesses, parts of businesses or companies to others or acquire them from others or enter into partnerships, which may also result in the disclosure of data (including from you, for example as a customer or supplier or as a supplier representative) to those persons involved in these transactions. In relation to communicating with industry organizations, associations and other bodies, data may be exchanged that also affects you. However, we do not sell, rent, or lease your personal data to third parties.

7. International data transfers

As explained in section 6, we disclose data to other parties. These are not all located in Switzerland. Your data may therefore be processed both in Europe and (given the presence of Satisloh in many countries around the world) in any country in the world as part of Satislohā€™s international business operations.

As a result of the above, some of your personal data may be transferred to or accessible from countries which do not have adequate statutory data protection. In such cases, and if required by applicable law, we take the following measures:

If a recipient is located in a country without adequate statutory data protection, we require the external recipient to undertake to comply with data protection (for this purpose, we use the revised and - if data transfer is subject to Swiss law and GDPR - adapted or supplemented European Commissionā€™s standard contractual clauses, which can be accessed here), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.

Please note that data exchanged via the internet is often routed through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.

For further information with regard to the appropriate or suitable safeguards and the means by which to obtain a copy of them, you can contact us with the modalities as per this Privacy Notice.

8. How do we protect your personal data?

We take appropriate physical, technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, use, or alteration and against unauthorized disclosure or access. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

Furthermore, a secure system for authorizing credit card payments and identifying fraudulent activities is used.

9. Your rights

To help you control the processing of your personal data, you have the following rights in relation to our data processing, depending on the applicable data protection law and subject to verification of your identity where necessary, in order for us to be able to prevent misuse (for example by means of a copy of your ID card, unless identification is possible otherwise):

  • request for information whether or not your personal data is being processed by us and if that is the case request to be informed of its content, the purposes of processing, categories of recipients, storage period and source.
  • request to rectify or delete your personal data our databases currently contain. We may not accommodate a request to change or delete your personal data if we believe that this would violate any law or legal requirement or cause the information to be incorrect. Upon receipt of such a request we will confirm receipt, consider your request, take a decision and communicate it to you.
  • restrict the processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Notice.
  • object to the processing of your personal data on grounds relating to your particular situation, if the processing is based on our legitimate interest. In addition, you have the right to object at any time to processing where your personal data are processed for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing. When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other right under this Privacy Notice.
  • where applicable by local laws, request your personal data portability, i.e. that personal data you have provided to us be returned to you or transferred to the person of your choice in a structured, commonly used and machine-readable format. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Notice. Where applicable, we will ensure such changes are shared with any trusted third party.
  • where processing is based on your consent, you may withdraw your consent at any time to the processing of your personal data. Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data.
  • lodge a complaint with the relevant data protection supervisory authority.

If you take the view that Satisloh is not processing your personal data in accordance with the applicable data protection laws, you can at any time lodge a complaint with your locally relevant data protection authority. If you are located in the European Economic Area, the United Kingdom or Switzerland, you can lodge a complaint with the competent data protection supervisory authority in your country. You can find a list of authorities in the European Economic Area here. You can reach the UK supervisory authority here. You can reach the Swiss supervisory authority here.

In order to exercise your rights, or if you do not agree with the way we process your personal data and/or our response to a request to exercise your rights, please contact privacy@satisloh.com.

Furthermore, we offer tools to you to update and amend your personal data e.g. through user account, if you are a registered user. You may modify and update your preferences on how you wish to receive e-mails or other communications from us. You may also request that your information on your account is deleted. For information on how to withdraw your consent for Cookies, please refer to the cookie settings in the footer of dacvision.com.

10. Additional country and regional specific provisions

  • Processing under the EUā€™s General Data Protection Regulation (GDPR)

This section applies and provides you with further information if your personal data is processed by one of our companies located in the European Economic Area.

Controller. The specific company identified in our external and internal websites and online services as being the operator of the site is the data controller in the meaning of the GDPR for the processing activities described in this Privacy Notice.

Legal basis of the processing. The GDPR requires us to provide you with information on the legal basis of the processing of your personal data. The legal basis for our processing data about you is that such processing is necessary for the purposes of:

  • exercising our rights and performing our obligations under any contract we make with you (Article 6 (1) (b) General Data Protection Regulation) (ā€œContract Performanceā€);
  • Compliance with our legal obligations (Article 6 (1) (c) General Data Protection Regulation) (ā€œCompliance with Legal Obligationsā€); and/or
  • Legitimate interests pursued by us (Article 6 (1) (f) General Data Protection Regulation) (ā€œLegitimate Interestā€). Generally, the legitimate interest pursued by us in relation to our use of your personal data is the efficient performance or management of (i) your use of the online services, and/or (ii) our business relationship with you. Where the below table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interest is not overridden by your interests and rights or freedoms, given (i) the regular reviews and related documentation of the processing activities described herein, (ii) the protection of your personal data by our data privacy processes and policies, (iii) the transparency we provide on the processing activity, and (iv) the rights you have in relation to the processing activity. If you wish to obtain further information on this balancing test approach, please contact our Data Privacy Organization at privacy@satisloh.com.

In some cases, we may ask if you consent to the relevant use of your personal data. In such cases, the legal basis for us processing that data about you may (in addition or instead) be that you have consented (Article 6 (1) (a) General Data Protection Regulation) (ā€œConsentā€).

PURPOSES

DETAILS

LEGAL BASIS

Follow-up and execution of our contractual relationship, e.g. your (respective your employers) orders offline and online and the after-sales services management

  • Formalize a quotation and/or a contract (including employment contract);
  • Manage product and/or service sales, offline and online orders (purchase, payment terms, delivery and supply of products and services);
  • Manage your invoicing, your warranty;
  • Manage follow-up and provide after-sales service and customer relations (including, for example, returns, warranty and customer support);
  • Manage safety, security, access control with respect to our facilities.

Contract Performance (Article 6 (1) (b) GDPR)

 

Transaction and potential unpaid invoices management

  • Carry out secure banking payments (with reference to invoicing obligations);
  • Manage incidents related to payment and debts;
  • Process potential unpaid invoices:
    • Identify your known unpaid invoices
    • Inform you of this unpaid amount, of the means available to you to regularize it, of the possibility of making observations and of requesting a review of your situation if necessary.

Contract Performance (Article 6 (1) (b) GDPR)

 

Account and inscriptions creation and management

  • Allow you to register to our sites and create your own account;
  • Provide the services available through the sites (e.g. management of the registration process and access to the account, account management, the reminder for products in the shopping cart, etc.);
  • Manage your client profile;
  • Permit you to join our engagement programs;
  • Allow you to participate in our contests and initiatives promoted.

Contract Performance (Article 6 (1) (b) GDPR)

 

Legitimate Interest (Article 6 (1) (f) GDPR)

Communication between us

  • Send you commercial and promotional communications and periodical updates (e.g. via e-mail, phone, SMS/MMS, postal service, social network and newsletter) related to our products, services, initiatives, webinars and events;
  • Manage our personalized commercial offers based on the analysis of your personal data related to spending volume, product category, and methods of purchase;
  • Fulfil your requests via e-mail, chat, phone, SMS/MMS, postal service (e.g. management of requests for information, responding to inquiries and exercise of your rights (section 9), booking of webinars, events, providing the ā€œshare with a friendā€ feature, etc.).

Consent, if voluntarily provided (Article 6 (1) (a) GDPR)

Legitimate Interest (Article 6 (1) (f) GDPR)

Analyses purposes

  • Managing of personalized content and communications;
  • Carry out statistical analyses on the customer audience;
  • Analyze the performance of our sites, our media investments and marketing campaigns, and our web orders;
  • Market research;
  • Improvement and development of our products, services and operations.

Consent, if voluntarily provided (Article 6 (1) (a) GDPR)

Legitimate Interest (Article 6 (1) (f) GDPR)

Legal obligations complying

  • Comply with the requirements of the laws, regulations, directives, protocols, recommendations from authorities, industrial standards and internal regulations, risk management and corporate governance (certain automatic or manual processes are designed to conduct checks in relation to economic sanctions, export control and anti-money laundering legislation);
  • Implement the decisions of public authorities;
  • Data retention with regard to accounting and tax obligations;
  • Prevention and control of crime and fraud (certain automatic or manual processes are designed to verify your online payments and to combat fraud involving payment methods and identity theft).

Compliance with Legal Obligations (Article 6 (1) (c) GDPR

 

Legitimate Interest (Article 6 (1) (f) GDPR)

Legitimate interests pursuit

  • Send you commercial communications via e-mail, chat, phone, SMS/MMS, postal service on similar products, events and services already provided to you, unless you object to such a processing at the time of the collection and on the occasion of each communication;
  • Attracting, identifying and sourcing talents and processing and managing applications for roles at Satisloh, including the screening and selecting of candidates;
  • Managing trainings, providing instructions;
  • Exercise or defend legal claims in court proceedings or in administrative or out-of-court procedures, investigations, relating to our rights, of our group companies and/or of our representatives, shareholders, officers and directors;
  • Enable the technical management of the sites and its operational functions, including solving any technical problems, providing support, reporting and hosting of data or performing tests, maintenance, improvements, updates and upgrades that cannot be performed through non-personal data;
  • Prevent or identify fraudulent activities or misuses of the sites or against the EssilorLuxottica group and/or the users of the sites;
  • Complete a potential merger, sale of assets, transfer of all or a material part of its business, or financing transaction by disclosing and transferring the personal data to the third party or parties involved in the transaction as part of the transaction;
  • Conduct, surveys and market research relating to our products and services by post or e-mail;
  • Anonymize personal data in order to perform statistical analysis.

Legitimate Interest (Article 6 (1) (f) GDPR)

 

International data transfers. In the event that - as part of our global business operations ā€“ some of your personal data is transferred to or accessible outside the European Economic Area, we ensure that your data is protected in a manner which is consistent with the General Data Protection Regulation. Therefore, and if required by applicable law, we take the following measures:

If we share your personal data with affiliated companies or external recipients located in countries outside the European Economic Area for which the EU Commission has not issued an adequacy decision, we ensure that specific contractual protection (such as the EU standard contractual clauses) is implemented. You may request further information about the safeguards implemented in relation to specific transfers by contacting us with the modalities as per this Privacy Notice.

Your competent data protection authority. In case of data privacy related concerns and requests, we encourage you to contact our Data Privacy Organization at privacy@satisloh.com. Besides contacting the Data Privacy Organization, you always have the right to approach the competent data protection authority with your request or complaint. A list and contact details of local data protection authorities is available here. More information from the European Commission on international data transfer you may also obtain here.

  • Processing under the Brazilian General Data Protection Law

This section applies and provides you with further information if the processing by one of our companies (i) occurs in Brazilian territory, (ii) concerns the data of individuals located in Brazilian territory, (iii) comprises personal data collected in Brazilian territory or (iv) has as its objective the offer or supply of products and/or services to individuals located in Brazilian territory. In these cases the Brazilian General Data Protection Law (Lei Geral de ProteĆ§Ć£o de Dados - LGPD) applies to the processing of your personal data and the following additions and/or deviations apply to related sections of this Privacy Notice:

Retention Periods. As allowed under article 16 of LGPD we may retain your personal data to comply with legal or regulatory obligations (such as retention obligations under tax or commercial laws), during the legal statute of limitation period, or for the regular exercise of rights in judicial, administrative or arbitration proceedings.

Your rights. Additionally to the rights mentioned in this Privacy Notice, you are entitled under LGPD to:

  • In case you understand your data is not being processed in accordance with the applicable data protection law or in an excessive way, request us to anonymize, block or delete unnecessary or excessive personal data or;
  • Request information regarding the public and/or private entities we shared your personal data with;
  • Be informed about the possibility of not giving your consent to process your data and the consequences of not giving the consent in case we request your consent to process your data;
  • Revoke at any time your consent to our processing of your personal data in case we request your consent to process your data.

Legal basis of the processing. The Brazilian General Data Protection Law requires us to provide you with information on the legal basis of the processing of your personal data.

The legal basis for our processing is:

  • Article 7 V LGPD (ā€œContract Performanceā€);
  • Article 7 II LGPD (ā€œCompliance with Legal Obligationsā€);
  • Article 10 I and II LGPD (ā€œLegitimate Interestā€).
  • Article 7 I LGPD (ā€œConsentā€).

International transfers. Following the LGPD requirements defined in the Article 33 of Brazilian General Data Protection Law, in the event that we transfer your personal data outside the Brazilian territory, we ensure that your data is protected in a manner which is consistent with the Brazilian General Data Protection Law, we will follow the applicable law and decisions imposed by the proper authority.

Your competent data protection contact. If this section applies, you may also contact our Brazilian Data Privacy Organization at info.br@satisloh.com.

  • Processing under Peopleā€™s Republic of China Personal Information Protection Law

This section applies and provides you with further information if the processing by one of our companies is located within the borders of Peopleā€™s Republic of China (ā€œPRCā€) or concerns the data of individuals within the borders of PRC.

Processing of sensitive personal information.

According to the Personal Information Protection Law of PRC (PIPL), sensitive personal information means personal information that, once leaked or illegally used, may easily cause harm to the dignity of natural persons or grave harm to personal or property security, including information on biometric characteristics, religious beliefs, specially-designated status, medical health, financial accounts, individual location tracking, etc. as well as the personal information of minors under the age of 14.

In addition to the payment information mentioned in section 3 of this Privacy Notice, we will, in principle, not process your sensitive personal information. In case your sensitive personal information will be processed, we will notify you about the necessity of processing and effects on the individualā€™s rights and interests, and obtain your specific consent if applicable.

Transfer and disclosure of personal data. Following the requirements defined in the Article 23 of PIPL, additionally to the contents mentioned in section 3, we, in principle, will not transfer or share your personal information to third party controllers, unless (1) we obtain your specific consent if applicable, or (2) to fulfill the statutory duties under local laws and regulations.

International Transfer. You acknowledge that your data will be transferred and proceed outside of PRC. We will follow the applicable laws and decisions imposed by the competent authority, and ensure that your data is protected in a manner which is consistent with the PRC Personal Information Protection Law. If you or the company you work for is a business partner, please be aware that Satisloh is a multi-national company, and for the purpose of concluding or fulfilling the contract/agreement with you or the company you work for, you understand and agree that we may transfer your personal information to foreign affiliated companies.

Legal Basis of the processing. The PIPL requires us to provide you with information on the legal basis of the processing of your personal data.

The legal basis for our processing is:

ā€¢ PIPL Article 13(2) (ā€œContract Performanceā€);

ā€¢ PIPL Article 13(3) (ā€œStatutory duties and responsibilitiesā€)

ā€¢ PIPL Article 13(6) (ā€œProcess publicly available dataā€);

ā€¢ PIPL Article 13(1) (ā€œConsentā€)

Usage by Children. This Online Offering is not directed to children under the age of fourteen (14). We will not knowingly collect personal data from children under the age of fourteen (14) without prior parental consent if required by applicable law. We will only use or disclose personal data about a child to the extent permitted by law, to seek parental consent, pursuant to local law and regulations or to protect a child.

11. Changes to this Privacy Notice

We will update this Privacy Notice from time to time, in particular in response to legal and/or organizational developments.

You can see when this Privacy Notice was last updated by checking the ā€œLast Updateā€ date displayed at the top of this Privacy Notice.

United States Privacy Notice

Last Update: 19 August 2024

To submit a Data Subject Request click here.

This U.S. Privacy Notice describes how Satisloh AG, including all direct and indirect subsidiaries (collectively ā€œSatisloh,ā€ ā€œwe,ā€ ā€œour,ā€ or ā€œusā€), collect, use, and disclose and safeguard your information. This U.S. Privacy Notice applies to individuals in the U.S. and who access this website and any other websites, applications or online services (collectively ā€œSitesā€) that link to this U.S. Privacy Notice or to individuals that interact with us through other communication channels. However, other Satisloh websites, products, and services may have their own privacy policies. This U.S. Privacy Notice, together with our Legal Notice , collectively govern your use of our Sites.

The group of companies belonging to Satisloh AG is made up of the following legal entities with offices located across the globe:

Country

 

Company

 

Brazil

Satisloh Do Brasil Ltda,

China

Satisloh (Zhongshan) Ltd.

France

Delamare Sovra SAS

France

SCL International SAS

Germany

Satisloh GmbH

Hong Kong Special Administrative Region of China

Satisloh Asia Limited

Italy

Satisloh Italy S.r.l.

Switzerland

Satisloh Holding AG

Switzerland

Satisloh AG

United States

DAC Vision Incorporated

United States

Satisloh North America, Inc.

We, Satisloh AG and the group of companies belonging to Satisloh AG, are - in the context of the applicable data protection law - the data controller of your personal data, which alone or jointly determine the purposes and means of the processing of your personal data.

From time to time, we may change this U.S. Privacy Notice. If we do, we will post an amended version on this webpage. Please review this U.S. Privacy Notice periodically.

You may submit a request to exercise rights you may have under applicable state law through our webform available here or by calling us toll free at 1-800-866-5640.

THE INFORMATION WE COLLECT

For the purpose of this U.S. Privacy Notice, personal information is any information about an identifiable individual. We collect the following types of personal information:

Information You Provide

We may collect the following personal information that you voluntarily provide us in using our Sites:

  • Create an Account. If you create an account with us, you will provide us with your name, email address, birth date, and you will create a password for future logins.
  • Registration Process. If you register an account with us or attend an event sponsored by us, you will provide us with your name, email address, birth date, and you will create a password for future logins.
  • Subscribe to Our Newsletter. If you subscribe to our newsletter, you will provide us with your email address.
  • Customer Service. If you contact our customer service department, you may need to provide us with additional information so that we can respond to your questions or concerns as completely and thoroughly as possible.
  • Purchases. When you make a purchase, you will provide us with your name, email address, phone number, physical address, and payment information, such as bank details or credit card information.
  • Apply for a Job. If you apply for a job through one of our Sites, we will collect any information you provide in your application, including, but not limited to, work authorization information, visa status, desired salary, language proficiency, educational background, employment history, and references. You may also choose to voluntarily provide optional information such as race, gender, or whether you are disabled.
  • Survey. If you are participating in a survey, you may provide your gender and age.
  • Business Information. We may collect personal information from business clients or vendors, including company name, physical address, phone number, email address, and payment information (bank details or credit card information).

We may collect the following personal information that you voluntarily provide us in the following scenarios:

  • Correspond via email or chat. If you correspond via email or chat with a Satisloh recipient, your emails resp. chats will be scanned by the tools Satisloh operates to maintain the security of its IT infrastructure.
  • Correspond via phone and voice mail services. When you call Satisloh personnel, only your phone number will be stored on our servers. This information will be provided, via phone and email, to the person you are attempting to contact. Under certain conditions, we also keep records of calls from customers and other requestors and maintain a transcript of chats for quality assurance and quality management. No other personal information is collected but technical logs and reports may be stored for trouble shooting purposes.

Information as You Navigate Our Sites

We automatically collect certain personal information through your use of the Sites, such as the following:

  • Usage Information. For example, the pages on the Sites you access, the frequency of access, and what you click on while on the Sites.
  • Device Information. For example, hardware model, operating system, application version number, and browser.
  • Mobile Device Information. Aggregated information about whether the Sites are accessed via a mobile device or tablet, the device type, and the carrier.
  • Location Information. Location information from Platform visitors on a city-regional basis.

 

Third Party Information

In some cases, we may receive certain personal information from you about a third party. For example, such as your employer who is acting as our business partner, data analytics providers, marketing or advertising service providers, service providers for fraud prevention, credit agencies (for example credit reports), associations, contractual partners, vendors that provide services on behalf us, banks, insurance companies or from public sources and authorities (for example debt collection registers, land registers, commercial registers), or the media and internet including social media, information from legal proceedings in which you appear (e.g. witness statements), documents concerning you (e.g. power of attorney, recommendations, references), or we may receive data from other companies within our group. We also create information based on our analysis of the information we have collected from you. If you submit any personal information about another individual to us, you are responsible for making sure you have the authority to do so and to allow us to use their personal information in accordance with this U.S. Privacy Notice.

 

HOW DO WE USE YOUR INFORMATION

We use the personal information we collect to improve our Sites and to protect our legal rights. In addition, we may use the personal information we collect to:

  • Formalize a quotation and/or a contract (including employment contract);
  • Manage product and/or service sales, offline and online orders (purchase, payment terms, delivery and supply of products and services);
  • Manage your invoicing, your warranty;
  • Manage follow-up and provide after-sales service and customer relations (including, for example, returns, warranty and customer support);
  • Manage safety, security, access control with respect to our facilities;
  • Carry out secure banking payments (with reference to invoicing obligations);
  • Manage incidents related to payment and debts;
  • Process potential unpaid invoices:
    • Identify your unpaid invoices
    • Inform you of this unpaid amount, of the means available to you to regularize it, of the possibility of making observations and of requesting a review of your situation if necessary.
  • Allow you to register to our Sites and create your own account;
  • Provide the services available through the Sites (e.g. management of the registration process and access to the account, account management, the reminder for products in the shopping cart, etc.);
  • Manage your client profile;
  • Permit you to join our engagement programs;
  • Allow you to participate in our contests and initiatives promoted;
  • Send you commercial and promotional communications and periodical updates (e.g. via e-mail, phone, postal service, social network and newsletter) related to our products, services, initiatives, webinars and events;
  • Manage our personalized commercial offers based on the analysis of your personal information related to spending volume, product category, and methods of purchase;
  • Fulfil your requests via e-mail, chat, phone, postal service (e.g. management of requests for information, responding to inquiries and exercise of your rights stated in the section ā€œYOUR STATE PRIVACY RIGHTSā€, booking of webinars, events, providing the ā€œshare with a friendā€ feature, etc.);
  • Managing of personalized content and communications;
  • Carry out statistical analyses on the customer audience;
  • Analyze the performance of our Sites, our media investments and marketing campaigns, and our web orders;
  • Market research;
  • Improvement and development of our products, services and operations;
  • Comply with the requirements of the laws, regulations, directives, protocols, recommendations from authorities, industrial standards and internal regulations, risk management and corporate governance (certain automatic or manual processes are designed to conduct checks in relation to economic sanctions, export control and anti-money laundering legislation);
  • Implement the decisions of public authorities;
  • Data retention with regard to accounting and tax obligations;
  • Prevention and control of crime and fraud (certain automatic or manual processes are designed to verify your online payments and to combat fraud involving payment methods and identity theft);
  • Send you commercial communications via e-mail, chat, phone, postal service on similar products, events and services already provided to you, unless you object to such a processing at the time of the collection or on the occasion of each communication;
  • Attracting, identifying and sourcing talents and processing and managing applications for roles at Satisloh, including the screening and selecting of candidates;
  • Managing trainings, providing instruction;
  • Exercise or defend legal claims in court proceedings or in administrative or out-of-court procedures, investigations, relating to our rights, of our group companies and/or of our representatives, shareholders, officers and directors;
  • Enable the technical management of the Sites and its operational functions, including solving any technical problems, providing support, reporting and hosting of data or performing tests, maintenance, improvements, updates and upgrades that cannot be performed through non-personal information;
  • Prevent or identify fraudulent activities or misuses of the Sites or against the EssilorLuxottica group and/or the users of the Sites;
  • Complete a potential merger, sale of assets, transfer of all or a material part of its business, or financing transaction by disclosing and transferring the personal information to the third party or parties involved in the transaction as part of the transaction;
  • Conduct, surveys and market research relating to our products and services by post or e-mail;
  • Anonymize personal information in order to perform statistical analysis.

SHARING INFORMATION WITH THIRD PARTIES

We may share the personal information that we collect about you in the following ways:

  • We engage service providers to perform services in connection with the operation of our business. We may share personal information with service providers so that they can perform these services. Examples of these services include payment processing and authorization, text messaging services, fraud protection and credit risk reduction, product customization, order fulfillment and shipping, marketing and promotional material distribution, website evaluation, data analysis and, where applicable, data cleansing.
  • In proceeding with your online order, you agree that any information associated with the order, such as the delivery name and address (if different from yours), will be processed using service providers.
  • In conducting our business relationship with you we share Personal information with other brands and affiliates of Satisloh.
  • Personal information, other than customer data, is partly shared and processed within a range of global applications that are used globally by the affiliates of EssilorLuxottica.
  • We may release personal information if we believe in good faith that: (i) the law or legal process requires it; (ii) we have received a valid administrative request from a law enforcement agency; or (iii) such release is necessary or appropriate (in our sole discretion) to protect the rights, property, or safety of Satisloh, or any of our respective affiliates, service providers, customers, or (iv) as Satisloh deems necessary to resolve disputes, troubleshoot problems, prevent fraud and otherwise enforce the terms specified in the Legal Notice.
  • We may also share your information with your consent or as otherwise disclosed at the time of data collection or sharing.
  • As with any business, it is possible that as ours develops, we might go through a business transition, such as a merger, acquisition by another company, or the sale of all or a portion of our assets, or buying online stores or other assets, including at bankruptcy. In such transactions, information about customers will likely be transferred.
  • The Sites may allow you to provide comments in various sections of our Sites, such as in product reviews. Please be aware that the information you post in these areas may be available to visitors of the Sites and to the general public. To the fullest extent allowed under applicable law, we do not monitor such content and are not responsible for material posted by you or others in these public forums.
  • We are a multi-national organization with locations in many countries around the world. Your personal information may be stored and processed outside of your country, province or state of residence, in any jurisdiction where we have facilities or in which we engage service providers, to the extent allowed in accordance with applicable law. This means that your personal information may be transferred in jurisdictions that have less restrictive privacy laws than your country, province, or state of residence, in which case we will ensure, through contractual means or otherwise, that it will receive an adequate protection in compliance with generally accepted data protection principles. We take steps to process personal information according to the provisions of this U.S. Privacy Notice and the requirements of applicable law.

COOKIES AND OTHER TRACKING TECHNOLOGIES WE USE

Like many other companies, Satisloh uses cookies and other tracking technologies (collectively, ā€œCookiesā€) when you visit our Sites

ā€œCookiesā€ are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).

We may use the following types of Cookies:

Technically Necessary Cookies

These Cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these Cookies, but some parts of the Sites will not then work. These Cookies do not store any personally identifiable information.

Functional Cookies

These Cookies enable the website to provide enhanced functionality and personalization. They allow the Sites to remember choices you make or information you enter (such as your username, language or the region you are in) and provide enhanced, more personal features. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these Cookies, then some or all of the Services may not function properly.

Measurement Cookies

These Cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Sites. They help us to know which pages are the most and least popular and see how users move around the Sites. All information these cookies collect is aggregated and can normally not be linked to a specific natural person. However, in certain cases the collected information can be linked to you directly (provided you disclosed your identity to Satisloh, e.g. when creating an account or filing a request with us).

HOW YOU CAN MANAGE COOKIES

Your Preferences

When you first visit our Sites, you may be presented with a banner that offers you choices about whether to accept or reject Cookies or tracking technologies of different types. You can consent to or reject cookies other than to technically necessary cookies for our Sites through our cookie settings in the footer of dacvision.com.

Browser Settings

Cookies can be blocked by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Sites.

You can find out more about Cookies and how to manage them by visiting www.AllAboutCookies.org.

Platform Controls

You can opt out of Cookies set by specific entities following the instructions found at these links:

Advertising Industry Resources

You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt-out of some of those Cookies by accessing the Network Advertising Initiative's website or the Digital Advertising Alliance's website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative's Mobile Choices website.

Please note that these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.

DIGITAL ANALYTICS

We may work with service providers that collect data about your use of the Sites and other sites or apps over time for non-advertising purposes subject to their privacy policies. We use analytics providers such as Matomo to gather and analyze aggregated anonymous user information. For more information about Matomo, please visit matomo.org/.

THIRD-PARTY LINKS & PLUG-IN

The Sites may provide links to third-party websites or apps, including our social media pages. We do not control the privacy practices of those websites or apps, and they are not covered by this U.S. Privacy Notice. You should review the privacy policies of other websites or apps that you use to learn about their data practices.

The Sites may also include integrated social media tools or ā€œplug-ins,ā€ such as social networking tools offered by third parties. If you use these tools to share information or you otherwise interact with social media features on the Sites, those social media companies may collect information about you and may use and share such information in accordance with their own policies, including by sharing such information with us or the general public. Your interactions with third-party social media companies and the use of their features are governed by the privacy policies of the companies that provide those features. We encourage you to read the privacy policies for any social media accounts you create and use.

YOUR STATE PRIVACY RIGHTS

Depending on the state in which you reside, you may have certain privacy rights regarding your personal information. Please review the sections below if you are a California, Nevada, or Virginia resident. For other state residents, your privacy rights may include (if applicable):

  • The right to confirm whether or not we are processing your personal information and to access such personal information;
  • The right to obtain a copy of your personal information that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
  • The right to delete personal information that we collected from and/or about you, subject to certain exceptions;
  • The right to correct inaccurate personal information that we maintain about you, subject to certain exceptions;
  • The right, if applicable, to opt out of the processing of your personal information for purposes of (1) targeted advertising; (2) the ā€œsaleā€ of your personal information (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
  • If we are required by applicable law to obtain your consent to process sensitive personal information, the right to withdraw your consent; and
  • The right not to receive discriminatory treatment by us for the exercise of your privacy rights.

We do not use personal information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals.

To exercise your rights, please submit a request through our webform available here or by emailing us at privacy@satisloh.com. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting a request on behalf of another individual, please use the same contact methods described above. If we refuse to take action regarding your request, you may appeal our decision through our available here or by emailing us at privacy@satisloh.com.

Universal Opt-Out Mechanisms

The Sites recognize the Global Privacy Control (ā€œGPCā€) signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use. See the ā€œDO NOT TRACK SIGNALSā€ section below for information on our treatment of do not track signals.

NOTICE TO NEVADA RESIDENTS

Nevada law allows Nevada residents to opt out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines ā€œsaleā€ to mean the exchange of certain types of personal information for monetary consideration to another person. We currently do not sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and we will record your instructions and incorporate them in the future if our policy changes. You may send opt-out requests to privacy@satisloh.com.

NOTICE TO VIRGINIA RESIDENTS

The Virginia Consumer Data Protection Act (ā€œVCDPAā€) provides Virginia residents with the right to receive certain disclosures regarding the personal data we process about them. For purposes of this section, personal data means any information that is linked or reasonably linkable to an identified or identifiable natural person. Personal data does not include de-identified or publicly available information as the VCDPA defines those terms.

For a discussion of the categories of personal data we process, the purposes for our processing, the categories of personal data that we share with third parties, and the categories of third parties with whom we share personal data, please see Sections above and below.

If you are a Virginia resident, the VCDPA grants you the right to: (1) confirm whether or not we are processing your personal data to access such personal data; (2) correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data; (3) delete personal data you have provided or we have obtained about you; (4) obtain a copy of your personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means; and (5) opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

To exercise your rights, please email us at privacy@satisloh.com, with your name, the fact that you are a Virginia resident, and specifying the right(s) you wish to invoke. If we refuse to take action regarding your request, you may appeal our decision by email us at privacy@satisloh.com.

NOTICE TO CALIFORNIA RESIDENTS

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (ā€œCCPAā€), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the U.S. Privacy Notice is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.

The CCPA defines ā€œpersonal informationā€ to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this ā€œNOTICE TO CALIFORNIA RESIDENTSā€ section we will refer to this information as ā€œPersonal Information.ā€

If you are a California resident and a current or former employee, job applicant, or independent contractor of ours, please see our privacy notice available on our job applicant website(s) for more information on our collection and use of your Personal Information in that capacity.

Notice at Collection of Personal Information

We currently collect and, in the 12 months prior to the ā€œLast Updateā€ date displayed at the top of this U.S. Privacy Notice, have collected the following categories of Personal Information:

  • Identifiers (name, postal address, online identifier, internet protocol address, email address)
  • Unique personal identifiers (device identifier; cookies, mobile ad identifiers, or other similar technology; customer number)
  • Telephone number
  • Credit card number
  • Internet or other electronic network activity information (browsing history; search history; and information regarding consumerā€™s interaction with website, application, or advertisement)
  • Geolocation data
  • Commercial information (records of personal property, products or services purchased, obtained, or considered; other purchasing or consuming histories or tendencies; or other commercial information)
  • Education information
  • Professional or employment-related information (including employment history)
  • Characteristics of protected classifications under California or federal law (gender, age (40 and older))
  • Inferences drawn from above information to create a profile about a consumer reflecting the consumerā€™s preferences

We collect Personal Information directly from California residents and from advertising networks, data analytics providers, and operating systems and platforms. We do not collect all categories of Personal Information from each source.

In addition to the purposes stated above in the Section ā€œHOW WE USE YOUR INFORMATIONā€ we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

  • Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
  • Debugging to identify and repair errors that impair existing intended functionality
  • Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us, provided that your Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your individual consumerā€™s experience outside the current interaction with us, including, but not limited to, the contextual customization of ads shown as part of the same interaction
  • Performing services including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services
  • Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the Personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with Personal Information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you
  • Undertaking internal research for technological development and demonstration
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
  • Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction

Sharing, and Disclosure of Personal Information

We have not sold or shared Personal Information to third parties in the 12 months preceding the ā€œLast Updateā€ date displayed at the top of this U.S. Privacy Notice.

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the ā€œLast Updateā€ date displayed at the top of this U.S. Privacy Notice and, for each category, the categories of recipients to whom we disclosed Personal Information.

Category of Personal Information

Categories of Recipients

Identifiers (name, postal address, online identifier, internet protocol address, email address)

Subsidiaries and affiliates; operating systems and platforms; sales agencies

Payment information, Credit card information

Payment processors

Internet or other electronic network activity information (browsing history; search history; and information regarding consumerā€™s interaction with website, application, or advertisement)

Subsidiaries and affiliates; operating systems and platforms; social media networks; sales agencies

Geolocation information

Subsidiaries and affiliates; operating systems and platforms; sales agencies

Commercial information (records of personal property, products or services purchased, obtained, or considered; other purchasing or consuming histories or tendencies; or other commercial information)

Subsidiaries and affiliates; operating systems and platforms; sales agencies

Education information

Subsidiaries and affiliates

Characteristics of protected classifications under California or federal law (gender, age (40 and older))

Subsidiaries and affiliates; operating systems and platforms; sales agencies

Inferences drawn from above information to create a profile about a consumer reflecting the consumerā€™s preferences

Subsidiaries and affiliates; operating systems and platforms; sales agencies

We disclosed Personal Information for the following business or commercial purposes:

Performing services including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services.

We do not knowingly collect, sell, or share the Personal Information of consumers under 16 years of age. We do not use Sensitive Personal Information for purposes other than those the CCPA and its regulations allow for.

Retention of Personal Information

We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.

Your Rights

If you are a California resident, you have the following rights with respect to your Personal Information:

  • The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
  • The right to delete Personal Information that we collected from you, subject to certain exceptions;
  • The right to correct inaccurate Personal Information that we maintain about you;
  • If we sell or share Personal Information, the right to opt out of the sale or sharing;
  • If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure;
  • The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.

How to Submit a Request to Know, Delete, and/or Correct

If you are a California resident, you may submit a request to know, delete, and/or correct through our available here or by calling us toll free at 1-800-866-5640.

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.

Our Process for Verifying a Request to Know, Delete, and/or Correct

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.

We will verify your identity either to a ā€œreasonable degree of certaintyā€ or a ā€œreasonably high degree of certaintyā€ depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable.

For requests to access categories of Personal Information and for requests to delete or correct Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion or correction, we will verify your identity to a ā€œreasonable degree of certaintyā€ by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

For requests to access specific pieces of Personal Information or for requests to delete or correct Personal Information that is sensitive and poses a risk of harm by unauthorized deletion or correction, we will verify your identity to a ā€œreasonably high degree of certaintyā€ by verifying at least three pieces of Personal Information you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you must submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Notice of Financial Incentive

Satisloh does not offer programs, benefits, and other offerings related to the collection, retention, use, or sale of your Personal Information that may be deemed a ā€œfinancial incentiveā€ or ā€œprice or service differenceā€ under the California Consumer Privacy Act (ā€œCCPAā€).

NOTICE TO CANADA RESIDENTS

Please see above, for a description of the personal information held by us, a general account of its use, and what personal information we make available to related organizations. Subject to exceptions set out in privacy legislation, residents of Canada may request to view, update, or correct their personal information by contacting our privacy officer at the information provided in the "CONTACT" section below. In order to protect your privacy, we will take steps to verify your identity before granting you access to the information or enabling you to make corrections. Please keep in mind that certain information may be subject to exceptions if, for example, the information is protected by solicitor-client privilege, part of a formal dispute resolution process, about another individual that would reveal their personal information or confidential commercial information, or would be prohibitively expensive to provide. In some instances, you may have consented to the collection of your personal information. Subject to legal and contractual requirements and reasonable notice, you may withdraw your consent at any time; however, without your consent, we may not be able to provide you with our services or products if your personal information is necessary for us to be able to provide them.

YOUR CHOICES

To opt out of our email marketing or to unsubscribe from our email newsletters, you can contact our customer service department using the information in the ā€œCONTACTā€ section below, or you can use the link provided at the bottom of each marketing message or newsletter. If you choose to opt out, you will continue to receive all email communications related to our transaction with you.

If you would like to update your mailing information or want your name and address removed from our direct mailing list, you can contact our customer service department using the information in the ā€œCONTACTā€ section below.

You can control the tools on your mobile devices. For example, you can turn on and off the GPS locator or push notification on your phone. Please consult your mobile deviceā€™s user guide for instructions on clearing cookies, enabling and disabling location services, and disabling push notifications.

When you make a purchase, you can choose to save your information to obtain a faster checkout for purchases and/or you can choose to receive emails or texts, which provide you with information regarding our other products and services. We obtain your consent before contacting you with certain non-emergency, automated, autodialed, prerecorded, or other telemarketing phone calls or text messages. You are not required to grant consent to telemarketing calls or texts as a condition of buying any goods or services. Also, you may revoke your consent at any time at the contact information listed at the end of this U.S. Privacy Notice. Message and data rates may apply. We will retain your personal information for the period necessarily to fulfill the purposes of your personal information collection, unless a longer retention period is required or permitted by law.

CHILDRENā€™S PRIVACY

We understand the importance of protecting childrenā€™s privacy, especially in an online environment. Our Sites are not intentionally designed for or directed at children less than 16 years of age. We do not knowingly collect personal information from children under the age of 16 without the consent of the childā€™s parent or guardian. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any personal information relating to children that we have collected, we will take steps to securely remove it from our systems.

UPDATING YOUR INFORMATION

You may request to view, update, or correct your personal information by contacting our privacy office at the information provided in the ā€œCONTACTā€ section below. In order to protect your privacy, we will take steps to verify your identity before granting you access to the information or enabling you to make corrections.

SECURITY

We take appropriate physical, technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, use, or alteration and against unauthorized disclosure or access. We limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.

Furthermore, a secure system for authorizing credit card payments and identifying fraudulent activities is used.

DO NOT TRACK SIGNALS

Your browser settings may allow you to automatically transmit a ā€œDo Not Trackā€ signal to online services you visit. Note, however, there is no consensus among industry participants as to what ā€œDo Not Trackā€ means in this context. Like many online services, we currently do not alter our practices when we receive a ā€œDo Not Trackā€ signal from a visitorā€™s browser. To find out more about ā€œDo Not Track,ā€ you can visit http://www.allaboutdnt.com/, but we are not responsible for the completeness or accuracy of this third-party information.

CONSUMERS WITH DISABILITIES

We are committed to ensuring this U.S. Privacy Notice is accessible to individuals with disabilities. To request this U.S. Privacy Notice in an alternative format, please reach out to us at the information provided in the ā€œCONTACTā€ section below.

CONTACT

If you have questions or wish to contact us about this Policy, please direct inquiries to:

Satisloh North America, Inc.
N106 W13131 Bradley Way, Suite 200
Germantown, WI 53022
U.S.A.
Phone: 1-800-866-5640
Email: privacy@satisloh.com

DAC Vision Incorporated
3630 W. Miller Road, Suite 350
Garland, Texas 75041
U.S.A.

Phone: +1 (972) 677.2700
Email: privacy@satisloh.com