Industria Optica Rodenstock Chile S.A. – United States Privacy Policy

This Privacy Policy (“Privacy Policy” or “Policy”) explains how Industria Optica Rodenstock Chile S.A. (“Rodenstock,” or “we,” or “us,” or “our”) collects personal information based on your interactions with us online, including on our website, and offline (for example, when you interact with Rodenstock products at partnering opticians’ offices)  (collectively, the “Services”).  
This Policy describes our practices with respect to the collection and use of personal information and describes rights you may have with respect to your personal information. 
This Policy addresses the personal information we collect about you in different interactions with Rodenstock, including when you interact with the Services (“consumer personal information”) and if you are a business contact (“B2B personal information”). The personal information we collect, and how we use that personal information, will vary depending on the context with which you interact with us.  The Policy clarifies where the treatment of your personal information will vary based on the type of interaction. 
“Personal information” includes any data that identifies, relates to, or could reasonably be linked to you or your household, directly or indirectly.

We collect, share, sell, use, and retain personal information for various purposes related to the Services and your interaction with us.

Personal Information We Collect and Purposes for Collection
We collect the following categories of personal information for the purposes described below, depending on how you interact with us:
 

We have collected the same categories of personal information in the 12 months prior to the “last updated” date of this Policy.   

Retention Periods

We retain the categories of personal information we collect for the length of time necessary to provide our Services, operate our business, to comply with legal obligations, or to protect our legal rights. We retain your biometric identifiers (retinal scans) no longer than one year after the business purpose for collecting the retinal scan to maintain your scan and prescription file, unless required to be further retained for legal purposes.

Categories of Personal Information We Sell or Share or Use for Targeted Advertising 
When we engage in digital advertising, we may sell the following categories of consumer personal information (according to the broad definition of “sell” under select state privacy laws), share them for purposes of cross-context behavioral advertising, or use them for targeted advertising: personal identifiers (including, for example, IP address, mobile advertising IDs, etc.) and internet or other electronic activity information.  
These categories of consumer personal information are sold to or shared for cross-context behavioral advertising or targeted advertising with advertising networks, data brokers and other companies that facilitate or engage in digital advertising. We engage in such sales and sharing to facilitate personalized advertising.  We do so by allowing third parties to place cookies or other tracking technologies on our website that may collect information about your online activities over time and across different websites or applications.  For more information about the use of cookies and other tracking technologies, see the section “Our Use of Cookies and Analytics” below.  
To opt out of such sales and sharing of personal information, click here: Do not sell my personal information.
We do not sell or share for cross-context behavioral or targeted advertising any of the other categories of personal information we collect. We do not engage in any other “sale” outside the use of cookies or web tracking technologies.

Categories of Third Parties To Whom We Disclose Personal Information 
We disclose consumer personal information to the following categories of entities that do not operate as our processors and are not our affiliates: Advertising companies and related companies that process consumer personal information for purposes of providing advertising and marketing services to us and other parties. 

Sources From Which We Collect Personal Information
We collect consumer personal information directly from our you when you visit our website or interact with us directly through another channel or a third-party vendor supporting our business, and representatives of entities with which we do business or may do business. We also collect personal information from data aggregators and data brokers.

Use or Disclosure of Sensitive Personal Information 
We do not use or disclose sensitive personal information to create profiles about or infer characteristics about individuals, or for any purposes other than providing our Services.  

No Profiling to Facilitate Decisions with Legal or Other Significant Effects
We do not engage in the automated processing of personal information to create profiles about individuals that are used in furtherance of decisions with legal or other similarly significant effects, such as the provision or denial of financial or lending services, housing, insurance, or access to essential goods or services.

Disclosure of Personal Information For Business Purposes in the Past 12 Months
The following chart describes the categories of personal information we disclosed for a business purpose in the 12 months prior to the date of this Policy:
 

Business Purposes for Such Disclosures 
We disclosed the aforementioned categories of personal information to the categories of third parties identified above for the following purposes: to manage customer, supplier and vendor accounts and relationships; to facilitate scheduling and email communications; to process payments; to verify customers’ identities; to fulfill orders and transactions; to provide cloud-based storage; to operate our IT systems and secure our systems; to engage in advertising and marketing; to prevent fraud and other illegal activities; and to obtain professional advice about legal and accounting matters.    

Additional Information About How We May Disclose Personal Information and Purposes for Disclosures
We may also disclose your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies and to judicial and regulatory authorities. We may also disclose your personal information to third parties to help detect and protect against fraud or data security vulnerabilities. And, we may disclose or transfer your personal information to a third party in the event of an actual or potential sale, merger, or reorganization of our entity or other restructuring.
 

Our Use of Cookies and Analytics
We may use cookies, pixel tags, web beacons and other similar tracking technologies (“tracking technologies”) to automatically collect information through our website. Tracking technologies are small data files placed on your computer, tablet, mobile phone, or other devices in conjunction with code that runs on our website that record certain pieces of information when you visit our website. We may use these tracking technologies to help identify irregular behavior, prevent fraudulent activity and improve security, as well as to make it possible for you to save your preferences and help us understand how you interact with our Services.  
We also allow third parties (including Google) to use third party cookies, web beacons, and other tracking technologies to collect or receive information about how you interact with our website and unaffiliated third-party websites on the Internet and use that information to provide analytics and other measurements services, and to deliver and target advertisements tailored to you. Third parties may also use some of these technologies to assist us in determining if you require assistance or are having problems navigating on our website, and this may include technologies that record your interactions with the website, including without limitation, your keystrokes, mouse clicks, screen touches, and information about when, how and from where you accessed our website.  
You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. You can disable cookies from your computer system by following the instructions on your browser or at www.youradchoices.com.
We use Google Analytics to evaluate the use of our website. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to visiting our website. For information about Google’s privacy practices, please refer to the Google Privacy Policy: https://policies.google.com/privacy?hl=en-US#infocollect.

Personal Information of Minors
Our website is not directed to minors under the age of 13 and we do not knowingly sell or share for purposes of behavioral advertising the personal information of minors, including minors under 16 years of age. 

Third Party Websites 
Our website may contain links to third-party websites. This Policy does not govern how those third parties collect or use personal information and we do not endorse or have control over their practices. The privacy policies and terms of use for those third parties’ websites/apps govern those companies’ privacy practices. We are not responsible for the content or privacy practices of any third-party websites.

How We Keep Your Personal Information Secure
We implement and maintain reasonable security appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process.  However, there is no perfect security, and reasonable security is a process that involves risk management rather than risk elimination.  While we are committed to maintaining a reasonable information security program, no such program can be perfect; in other words, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to factors that cannot reasonably be prevented. Accordingly, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.

Changes to This Policy
We will review and update this Policy from time to time. If changes are made, we will update the Policy and reflect the date of such modification at the top of the Policy. If the changes are material, you will be notified via a notice on our website.

Accessibility
To make accessibility-related requests or report barriers, please contact us at info@rodenstock.com. 

U.S. State Data Privacy Rights 
Consumer Rights Under Comprehensive U.S. State Data Privacy Laws 
Depending on your state of residence, you may have certain qualified rights with respect to many types of personal information we collect, with some exceptions. The rights provided under various state laws are similar in many respects, with some differences from state to state. These rights may include: 
Right to Know: The right to confirm whether or not we are processing your personal information and to access such data, and in certain states, the right to know more detailed information.  For example, California’s privacy law gives residents the right to request the following additional information: Categories of personal information we have collected about them; categories of sources from which such personal information was collected; categories of personal information that the business sold or disclosed for a business purpose about the consumer; categories of third parties to whom the personal information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling your personal information.  Oregon’s privacy law gives residents the right to request a list of third party entities to which we have disclosed personal information. 
Right to Access / Copy: The right to access or request a copy of the personal information we have collected, subject to certain exceptions.
Right to Delete: The right to request deletion of the personal information that we have collected from or about you and to have such information deleted, subject to certain exceptions.
Right to Correct: The right to request that we correct inaccuracies in your personal information, taking into account the nature of personal data and purposes of processing such information. 
Right to Limit the Use of Sensitive Personal Information: The right to request that we not use or disclose sensitive personal information for inferring characteristics about you or for purposes other than to provide goods and services, protect and investigate fraud and other security-related issues, nonpersonalized advertising, and similar purposes described in the law.   
Rights to Opt Out:  Various rights to request that we stop using your personal information for one or more of the following purposes: 
•    Sale of Personal Information: The right to request that we stop “selling” your personal information (which is often defined broadly to include the exchange of personal information for anything of value and can include common website practices such as certain third party advertising cookies). 

•    Targeted Advertising or Cross-Context Behavioral Advertising: The right to request that we stop processing your personal information for targeted advertising or cross-context behavioral advertising.

•    Profiling In Furtherance of Legal or Significant Decisions: The right to request that we stop processing personal information for the purpose of profiling in furtherance of decisions that produce legal or similarly significant effects. 

California Shine the Light
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents who have an established business relationship with us to annually request information about the personal information disclosed to third parties for their direct marketing purposes in the preceding calendar year. We do not and did not make such disclosures. 

Exercising Your Rights
We will respond to requests from residents of states with data privacy laws that apply to us and will do so with respect to the rights that are provided under the requestor’s state law as of the effective date of that law.  
To exercise rights to know, access/copy, delete, correct, or know third parties to whom personal information is disclosed, submit a request by contacting us at privacy@rodenstock.com or by telephone on (0049) 89 7202 643. We will provide a substantive response to these requests within 45 days of the date on which we receive your request. If we require additional information or time to process your requests, we will contact you.

You have the right to direct us not to share, disclose, or sell your personal information. To exercise this right, please send your request here: Do not sell my personal information.  

Opt-out Preference Signals and Do Not Track
An opt-out preference signal is sent by a platform, technology, or mechanism on behalf of individuals and communicates an individual’s choice to opt out of the sale and sharing of personal information for cross-context behavioral advertising with all businesses that recognize the signal, without having to make individualized requests. The signal can be set on certain browsers or through opt-out plug-in tools.  

We recognize the Global Privacy Control signal and do so at the browser level and it does not apply to personal information we may collect offline or that we may associate only with your name or email address. This means that if the signal is sent through a specific browser, we will recognize it for that browser only, and only with respect to the identifiers for that browser.  If you would like more information about opt-out preference signals, including how to use them, please refer to the Global Privacy Control website (https://globalprivacycontrol.org/). 

We will respond to opt-out requests and requests to limit the use of sensitive information as soon as feasibly possible, but no later than 15 business days after receipt of your request.  If we require additional information or time to process your requests, we will contact you. 

We do not respond to the DNT or “Do Not Track” signal.  

Exercising Your Rights Using Authorized Agents
Agents may submit opt-out requests on behalf of individuals under several state data privacy laws; this is not an option that is available under laws in certain states (for example, Texas, Utah, or Virginia).  If your agent submits an opt-out request on your behalf, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf. You may also be required to verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request. Agents can submit opt-out requests by contacting us at privacy@rodenstock.com. 
An agent may also be authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with state law pertaining to powers of attorney.

Verification of Requests 
When you exercise rights other than opt-out rights and the right to limit collection of sensitive personal information beyond what is necessary to provide the services, we will take steps to verify your identity. We will ask you for at least two pieces of personal information, depending on the nature of the request, and attempt to match those to information that we maintain or collect about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request and will deny it. We will notify you to explain the basis of the denial.

When We Do Not Act on a Request – Appeal Process 
In some cases, we may not act on your requests (for example, if we are prohibited from acting on your request under other laws that apply). When this is the case, we will explain our reasons for not providing you with the information or taking the action (for example, correcting data) you requested.    
Additionally, you have the right to appeal our decision by contacting us at same method used to submit requests within 30 days after your receipt of our decision.  

Non-Discrimination
If you exercise any of the rights explained in this Privacy Policy, we will continue to treat you fairly.  If you exercise your rights under this Privacy Policy, you will not be denied or charged different prices or rates for goods or services or provided a different level or quality of goods or services than others.

Contact Us
If there are any questions regarding this Privacy Policy or to request a copy of this Privacy Policy in another format you may contact us at privacy@rodenstock.com.