DATA PRIVACY POLICY

A.ABOUT THIS POLICY

We are committed to providing you with professional and valuable products and services whilst safeguarding your privacy.

This Data Privacy Policy (also “Policy”) outlines when, why and how we collect, use, disclose and/or otherwise handle (collectively “process”) personal data relating to users of our websites (“Data Subjects”).

The provision of your personal data in connection with your use of the CooperVision website at www.coopervision.com.sg (or such other domain as we may choose from time to time) is voluntary. If you do not provide such information, we may not be able to provide you with access to or full use of our websites, or fulfil any other applicable purposes of collection.

Personal Data” is any information relating to you, whether true or not, which can be used to personally identify you, either directly or indirectly. We will process your Personal Data, as described in this Data Privacy Policy and as described when we collect data from you. Our Privacy Policy must be read together with any other legal notices or terms and conditions provided or made available to you when we collect data from you (or at a later stage) or that are available on other pages of our websites.

In this Data Privacy Policy

  • references to “we”, “us” or “our” means CooperVision, Inc. and/or the Affiliates (defined below); and
  • references to “you” and “your” are to the Data Subjects.

We collect Personal Data from you when you use our websites. We will also collect and process your Personal Data by using cookies in accordance with our Cookie Policy.  For more information on Cookies, please see the "Cookies" paragraph of Section C (What personal data do we process and why?) below and click here to view our Cookie Policy: https://coopervision.co.uk/cookie-policy. We also collect personal information when you contact us in connection with our websites.

B.WHO IS RESPONSIBLE FOR YOUR DATA?

CooperVision, Inc., with its place of business at: 6101 Bollinger Canyon Rd, Suite 500, San Ramon, USA with company number C1893655 (“CooperVision”) is the data user in relation to your Personal Data.

We can be contacted by email at: dpo@coopervision.com or by post using the address set out above.

Where CooperVision shares Personal Data with CooperVision affiliates (“Affiliates”, which means our subsidiaries, our ultimate holding company and its subsidiaries), the Affiliates are also data users as explained in this Data Privacy Policy. Details of the Affiliates, including their locations, are listed here: https://coopervision.com.sg/APAC-Affiliates.

C.WHAT PERSONAL DATA DO WE PROCESS AND WHY?

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, date of birth.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We set out below a table below which provides a non-exhaustive list of the types of Personal Data that we collect and hold, the purposes for which that Personal Data is processed.

Data Subject category

Type of information

Purposes of processing

Users who register for an account via our website

  • Identity Data
  • Contact Data

To register you as a new customer

Users who register for an account via our website

  • Identity Data
  • Contact Data
  • Profile Data
  • Marketing and Communications Data

To manage our relationship with you which will include:

  • Notifying you about changes to our terms or privacy policy
  • Sending non-marketing communications to you concerning your account

Users who purchase products via our website

  •  Identity Data
  • Contact Data
  • Financial Data
  • Transaction Data
  • Marketing and Communications Data

To process and deliver your order including:

  • Managing payments, fees and charges
  • Collecting and recover money owed to us

All users of our websites

  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data
  • Marketing and Communications Data
  • Technical Data
  • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • Asking you to leave a review or take a survey or complete a questionnaire

Registered users who consent to receiving marketing

  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data
  • Marketing and Communications Data
  • Technical Data

With your express opt-in consent only, to send by email or SMS suggestions and recommendations to you about goods or services that may be of interest to you

All users of our websites

  • Cookies
  • Technical Data
  • Usage Data
  • Contact Data
  • Administering and protecting our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data and ensuring network and information security)
  • for business and disaster recovery (e.g. to create back-ups)
  • personalising and customising our websites
  • using data analytics for research to improve our website, products/services, marketing, customer relationships and experiences and to ensure the quality of the services we provide to our customers
  • enabling your use of the services available on our websites

Our business purposes – we will also use your Personal Data for our internal business purposes including:

  • to investigate any complaints you make;
  • to provide evidence in any disputes or anticipated disputes between you and us;
  • for the detection and prevention of fraud, other criminal offences and for risk management purposes; and
  • to protect the rights, property, and/or safety of CooperVision, any of its Affiliates, its personnel and others.

We may also be required to process your personal data to comply with our legal requirements, to enable us to fulfil the terms of any contract that we have with or in preparation of us entering into a contract with you.

Cookies

Our website use cookies and other similar technologies (e.g. pixels and web beacons) (collectively, “Cookies”) to distinguish you from other users of our website in order to enhance your experience of our website and to allow us to improve our website.

Cookies are small files which, when placed on your browser or the hard drive of your device, are used to collect data, including personal data, from you, and enable us to provide certain features and functionality in our website. Cookies do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies are stored on your browser by websites or apps that you visit. When you return to that website or app (or visit websites or apps that use the same cookies) these platforms recognize the Cookies and your browsing device. 

We will obtain your consent to the use of Cookies where required under applicable law.

For more information about how we use Cookies, please refer to our Cookies Policy at https://coopervision.co.uk/cookie-policy.

D.HOW AND WHEN DO WE SHARE PERSONAL DATA WITH THIRD PARTIES?

This section describes with whom we may share your Personal Data.

  1. Data sharing within CooperVision group

CooperVision may share your Personal Data with its Affiliates (details of the Affiliates, including their locations, are listed here: https://coopervision.com.sg/APAC-Affiliates):

  • where we need to do so in order to provide the products and/or services or information that you have requested; for example, we may transfer your Personal Data to CooperVision, Inc. in the United States of America for central support services; or
  • for the purposes of IT support and maintenance; or
  • internal governance and administration; or
  • if you consent to us doing so; or
  • to comply with our legal or regulatory obligations; for example, we may transfer your Personal Data to CooperVision Inc. in the US, which hosts our database of product and patient regulatory information.
  1. Data sharing with service providers

We also share your Personal Data with our third party service providers, whom we engage to provide various services, which include but are not limited to:

  • delivery of our products (e.g. couriers);
  • our websites (e.g. hosting and maintaining our websites); and
  • IT services and solutions (e.g. providing data storage, assisting us with database management).
  1. Data sharing with other recipients

We may also share your Personal Data with:

  • our accountants, auditors, lawyers or other professional advisers when we ask them to provide us with professional advice;
  • any other third party if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or to protect the rights, property and/or safety of CooperVision, any of its Affiliates, its personnel and others;
  • any other third party for the purposes of acting in accordance with the requirements of a court, regulator or government agency, for example, complying with a court order or acting in accordance with an applicable law or regulation;
  • police and other law enforcement agencies in connection with the prevention and detection of crime; or
  • prospective and actual investors and other relevant third parties in the event of a potential sale or other corporate transaction related to CooperVision and/or any of its Affiliates.

 

E.INTERNATIONAL TRANSFERS OF PERSONAL DATA

The transfer of your Personal Data to and between the Affiliates, service providers or other recipients may involve your Personal Data being sent outside of your jurisdiction to recipients in Australia, Japan, Singapore, and the United States of America. Where we transfer Personal Data overseas, we will implement appropriate and suitable safeguards to ensure that such Personal Data will be protected as required by applicable data protection law. 

F.HOW LONG DO WE STORE PERSONAL DATA?

It is our policy to retain your Personal Data for the length of time required for the specific purpose or purposes for which it was collected (e.g., for the fulfilment of an agreement with you). However, we may be obliged to store some Personal Data for a longer time, taking into account factors including: 

  • legal obligation(s) under applicable law to retain data for a certain period of time (e.g. compliance with tax and accountancy requirements);
  • the establishment, exercise or defence of legal claims (e.g., for the purposes of a potential dispute).

For more information on how long cookies are stored, please refer to our Cookie Policy: https://coopervision.co.uk/cookie-policy.

 

G.HOW DO WE PROTECT YOUR PERSONAL DATA?

We implement technical and organisational security measures to protect your Personal Data against the risk of accidental or unauthorised access, processing, erasure, loss, misuse, alteration or destruction. Such measures may include the use of firewalls, encryption (where appropriate), access rights management processes, careful selection of processors and other technically and commercially reasonable measures to provide appropriate protection for your Personal Data.  Where appropriate, we may also make backup copies and use other such means to prevent accidental damage to or destruction of your Personal Data. 

Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure. For any payments which we take from you online we will use a recognised online secure payment system.

H.YOUR RIGHTS  

The following section explains your data protection rights that you can exercise. The rights may only apply in certain circumstances and are subject to certain exemptions.  Please see the table below for a summary of your rights. You can exercise these rights using the contact details set out in Section I (How to Contact Us).

  • The right to be informed – you have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Data. This is why we are providing you with the information in this Data Privacy Policy and in any legal notices or terms and conditions provided to you.

·The right of access – you have the right to access and to receive a copy of your Personal Data that we hold about you, subject to certain exemptions.

·The right to rectification – you can ask us to take measures to correct your Personal Data if it is inaccurate or incomplete (e.g. if we have the wrong name or address for you).

Before assessing your request, we may request additional information in order to identify you.  If you do not provide the requested information and, as a result, we are not in a position to identify you, we may refuse to action your request.

We may charge a fee that is not excessive in order to comply with a data access request.

I.THIRD PARTY LINKS

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for how they handle your Personal Data. When you leave one of our websites, we encourage you to read the privacy notice of every website you visit.

 

J.HOW TO CONTACT US

If you wish to request further information regarding this Data Privacy Policy or the way we use your Personal Data, or if you wish to exercise any of the above rights set out in Section H or to make a complaint, you can contact our Data Protection Officer at: dpo@coopervision.com.

We will endeavour to respond to your enquiry or complaint within a reasonable period. If we fail to respond to a complaint within a reasonable time or if you are dissatisfied with our response, you may submit a complaint to your local data protection authority.