Greiche & Scaff (“Greiche & Scaff”) and our affiliates and subsidiaries (collectively, “we”, “our” or “New Look Vision Group”) take protecting your identity and the personal information you provide very seriously. Our privacy policy applies to the personal information we collect in-store, through our website at www.greiche-scaff.com and any other online properties or applications that we operate on which this privacy policy is posted (collectively, “Websites”), and throughout our relationship with our customers, website users and visitors. 

This privacy policy (the “Policy") describes the personal information we may collect from you, the purposes for which we collect it, how we use it, when we may share it with third parties and how it can be deleted. This Policy also describes the choices you have regarding the collection, use, or disclosure of your personal information. Greiche & Scaff will not collect, use, or disclose your personal information other than in compliance with this Policy. 

By using the  Websites, making online purchases, visiting us in-store, or otherwise interacting with us, you agree to the terms and conditions of, and provide your consent to the collection, use and disclosure of personal information as set out in, this Policy. We may make changes to the Policy from time to time. Any changes we make will become effective when we post a modified version of the Policy on our Websites. We will notify our customers, website users and visitors of any changes made to the Policy by publishing an updated Policy on our website. If the changes we make are significant, we will provide a more prominent notice when required by applicable laws. Following publication, your continued use of one or more of the Websites, in-store options, or services, or other interaction with us will constitute your acceptance of the new policy. If you do not agree to the changes in our Policy, it is your responsibility to stop interacting with us, using our services, or purchasing our products. The “Last Updated” date shown at the top of the Privacy Policy indicates when it was last updated. 

We may offer the ability to connect to our Websites or use our applications, services, and tools using a mobile device either through a mobile application or via a mobile-optimized website. The provisions of this Policy apply to all such mobile accesses and uses of mobile devices. This Policy will be referenced by all such mobile applications or mobile-optimized websites. 

PROVISIONS OF OUR PRIVACY POLICY 

What is “personal information”? 

How do we collect personal information? 

What type of information is collected? 

For what purposes is this information collected? 

Is the information shared with third parties? 

Your choices about receiving promotional communications 

What are cookies and how are they used on this site? 

How to access or change your personal information, withdraw your consent, make inquiries, or lodge a complaint with regards to this Policy and Greiche & Scaff’s privacy practices? 

How long is your personal information retained? 

How is your personal information secured? 

Cross-border transfers 

Mobile privacy 

Children under the age of 14 

How to contact us 

WHAT IS “PERSONAL INFORMATION”? 

“Personal information” is any information about an identifiable individual. This may include, for example, your name, contact information, email address, personal identification numbers and information relating to your account with us or your prescription (as the case may be). It may also include technical information, such as an IP address, but only when this information can identify you as an individual.  

Information that is aggregated and/or cannot be associated with an identifiable individual is not considered to be personal information.  

WHAT TYPE OF INFORMATION IS COLLECTED? 

The type of information collected depends on the type of interaction we have with you. Personal information we collect may include: 

• identifiers and contact information, such as your name, address, e-mail, telephone, language, purchase information, lifestyle information, health information (including medications), ocular prescription information, and communication preferences; 
• insurance information, such as your health insurance number or insurance policy details; 
• demographic data, such as date of birth or gender; 
• transaction information, such as history of purchases made (e.g. the number and amount of transactions by type, location/store of purchase, product code information, brand, quantity purchased, date, time, payment method used, and promotional offers or discounts used in connection with the transaction). Please note that Greiche & Scaff does not collect financial data such as credit card or financing information; 
• browsing activity on our Websites, such as browser information, internet providers, operating system used, pages and offers viewed, app usage data, opt-out preferences, click-throughs, Internet protocol address (IP) or other identification means, and date and time of visits.  
• location information may be collected when you use our Websites, although this information may not always identify you as an individual; 
• biometric information, such as 3D facial and pupillary distance scans, which may be collected through our Websites or in-store services (e.g. when you use the virtual try-on and eyewear fitting features by uploading your photographs through such services);  
• information collected through technology used in our stores, including CCTV; and 
• any other information you provide to us. 

HOW DO WE COLLECT PERSONAL INFORMATION? 

We collect personal information in a variety of ways, including directly from you, through online technologies, through technology used in our stores (such as CCTV) from our affiliates and eyecare professionals, through social networks and other third parties. We encourage you to review the privacy policies of third parties (please see the section entitled “Other Websites”). 

Directly from you 

We may collect personal information directly from you or your authorized representative in our stores, by mail, by email, over the telephone, through our Websites, or in any other direct manner, for instance when you make a purchase, schedule an examination or consultation, give us feedback on our stores and the products for sale in our stores, participate in a sweepstake or survey, or make a request for customer service. For example, we may collect personal information in the following cases: 

• Making an eye exam or other consultation appointment online, by telephone, or in-store 
• Making a frame fitting appointment online 
• Creating a patient file in-store 
• Creating an online customer account (through one of our Websites) 
• Purchasing in-store or online 
• Subscribing to our newsletters or promotional communications 
• Entering a sweepstake or answering a survey 
• E-mailing questions or comments 

Greiche & Scaff does not collect financial data such as credit card or financing information. 

Through online technologies 

We may collect certain types of information electronically when you interact with our Websites, emails, social media accounts, online advertising, or through the use of our or a third party’s technologies, which include cookies, web beacons or single-pixel gifs or analytics engines. This information helps us understand what actions you take on our Websites and how you interact with our social media accounts, advertisements, and communications with you. 

We may combine this information with other information collected in-store or online, such as your transaction history. We do this to support our customer understanding using analytics services and to provide you with more tailored advertising. This includes serving interest-based advertising to you, subject to your right to withdraw consent.  

The technologies we may use include: 

• Cookies, which are small data files that are saved on your computer when you visit a website. They keep a record of your preferences making your subsequent visits to the site more efficient. Cookies may store a variety of information, including the number of times that you access a site, registration information, the number of times that you view a particular page or other item on the site, your login credentials or language preferences. The use of cookies is a common practice adopted by most major sites to better serve their clients. Most browsers are designed to accept cookies, but they can be easily modified to block cookies; see your browser's help files for details on how to block cookies, how to know when you have received cookies, and how to disable cookies completely. You should know, however, that without cookies, some of the website's functions will not be available and the user will lose some of the benefits of the site.  
• Web beacons, and single-pixel gifs, which are small image files that may convey information about you, such as your IP address, that are downloaded when you visit a website or open an e-mail. This allows us to understand your online behaviour, monitor our email delivery, and provide you with interest-based advertising. These tools may also allow our third-party tracking tools to gather information, such as your IP address, and provide this back to us in an anonymized, aggregate form. 
• Web analytics tools, which may use cookies to analyze your use of our websites and apps, to create reports about visitor and user activities for us and to provide further services associated with the use of our websites and apps. 
• Analytics engines, which pull usage data from multiple sources and help manage and collect this data to use for personalization, interest-based advertising, customizing content and other methods to gain insights into our customers’ needs and preferences. 
• Tools that help protect against inappropriate uses, such as Google reCAPTCHA, which collects hardware and software information, such as device and application data and the results of integrity checks, as well as unique online identifications such as IP address, and sends that data to Google for analysis. 

From our affiliates and eye care professionals  

We may collect information from other sources, for instance from companies controlled by, or under common control with, Greiche & Scaff, such as information about orders or customer records. We may also receive information from optometrists, ophthalmologists and other eye care professionals, such as information related to your ocular prescription, medical procedures and other eyecare needs. However, we will never disclose such information to non-affiliated third parties, beyond what is provided by this Policy (including in the section below titled “Is The Information Shared With Third Parties?”) or without your prior consent. 

Through social networks 

We may collect your personal information if you interact with us through our social media pages and accounts. For example, we collect the personal information these social media platforms allow us to collect from our followers. We may also collect any content you upload to our social media pages and accounts (including photos or videos). 

In addition, our Websites may provide interactive plug-ins to enable social network features (e.g., to connect to Facebook). These plugins may use cookies to gather information on your use of the Websites. How this collected data is used by a third party is dependent on the privacy policy of the social network which is available on the applicable social network website. We may also obtain and use analytical and statistical information from third-party social networks to help us measure performance and effectiveness of content we display on social networks. 

From other third parties 

We may collect personal information from other categories of third parties, but only with your consent or as permitted or required by applicable law.  

FOR WHAT PURPOSE IS THIS INFORMATION COLLECTED? 

We may use all categories of personal information detailed in the section entitled “What type of information is collected?” to provide you with our products and services, to manage our business operations, to communicate offers and information we think might interest you, to generally enhance your customer experience with us, and as otherwise permitted or required by law.  

For example, if you are a customer, your identifiers, insurance, demographic and transaction information is stored in your file and is used by us to provide you and our managers, associates and affiliated professionals with a historical record of your eye health and your eyewear purchases.  

More generally, Greiche & Scaff may use your personal information for but not limited to the following purposes: 

Providing services 

• Offering and providing you with eyewear and related products and services, including virtual try-on and eyewear fitting services; 
• Offering and providing optometric and ophthalmology services; 
• Creating a patient file or online account; 
• Processing your orders for products and services or answering your questions regarding such orders; 
• Confirming your eye exam, procedure or frame fitting appointment; 
• Sending eye exam and appointment reminders; 
• Manufacturing a product purchased online or in-store; 
• Processing your returns and repairs; 
• Responding to your requests, instructions, inquiries or other communications; 
• Enabling your participation in contests, sweepstakes, or promotions; 
• Contacting you to answer a survey in order to improve our products or customer service; 

Managing our operations 

• Notifying you of changes to our services, Website terms and conditions or policies and to communicate administrative messages, legal or technical notices or security alerts; 
• Managing our information technology applications and systems, including our Websites; 
• Make pricing and inventory decisions; 
• Maintaining our products and services; 
• As we believe to be necessary or appropriate: (a) as permitted or required by applicable law, including laws outside your country of residence; (b) to comply with legal process and law enforcement requests; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to meet our contractual, legal and regulatory obligations, (f) to protect our operations or those of any of our affiliates; (g) to protect the rights, interest, privacy, safety or property of Greiche & Scaff and New Look Vision Group, you or others, including from error and fraud; and (h) to allow us to investigate incidents, manage claims, pursue available remedies or limit the damages that we may sustain; 

Marketing 

We may use your personal information to send promotional communications such as newsletters, sales or exclusive offers, or to invite you to enter a contest or sweepstake or otherwise to market our stores and brands, and those of third parties whose products are sold in our stores, by communicating with you by email or other electronic communications, telephone, social media, or direct mail, or by delivering online advertisements that may be of interest to you. 

You can unsubscribe to our promotional communications at any time. Refer to the “Your choices about receiving promotional communications” section. 

Research 

We may use your personal information in order to conduct research and analytics for the following purposes: 

• Improving or developing new products and services, and to better understand our customer base and preferences; 
• Managing, developing and improving our business operations, products and services; 
• Understanding customer needs and interests, and tailoring our marketing, Websites, products and services; and 
• Evaluating the effectiveness of our marketing.  

Where possible, we will use your information in an aggregated and/or de-identified format. 

IS THE INFORMATION SHARED WITH THIRD PARTIES? 

Within New Look Vision Group 

We may share your personal information with the head office of New Look Vision Group – if you visit one of our Websites, make in-store or online purchases, enter a sweepstake, answer a survey or receive promotional communications. New Look Vision Group can communicate with you (by e-mail, mail, or otherwise) and provide you with information about the Group’s product or services that might interest you, or collect additional information and use that information subject to and for other purposes contemplated by this Policy. We may also share your personal information to our affiliates for the purposes described in this Policy. 

With our service providers 

We may share your personal information with our third-party service providers who provide services such as website hosting, virtual eye exams, virtual frame try-ons, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, e-mail delivery services, credit card processing, auditing services and other services, to enable them to provide such services. Any third-party service providers we may share your personal information with is bound by confidentially obligations.  

With our business partners and eye care professionals 

We may share your personal information with third-party business partners and professionals with whom we associate to provide certain products or services. We only share the personal information required for our business partners to offer the relevant products or provide the relevant services. For example, we may share your personal information with optometrists, ophthalmologists or other eyecare professionals with whom we work to meet your needs. 

In the course of a sale of our business or other transaction 

In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may transfer or disclose your personal information to a purchaser or prospective purchaser, who may collect, use and disclose such information for the purposes of evaluating the proposed transaction or operating and managing the affairs of the acquired business, or for other purposes identified in this Policy. We do not otherwise sell or lease your personal information to non-affiliated third parties except as permitted by law.  

As otherwise permitted or required by law 

We reserve the right to disclose your personal information as we believe to be necessary or appropriate, including: (a) as permitted or required by applicable law, including laws outside your country of residence; (b) to comply with legal process and law enforcement requests; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to meet our contractual, legal and regulatory obligations, (f) to protect our operations or those of any of our affiliates; (g) to protect the rights, interest, privacy, safety or property of Greiche & Scaff and New Look Vision Group, you or others, including from error and fraud; and (h) to allow us to investigate incidents, manage claims, pursue available remedies or limit the damages that we may sustain. 

With your consent 

In addition to the circumstances described above, we may, with your implied or express consent, share or disclose your personal information outside of our group of companies, in accordance with applicable laws. 

YOUR CHOICES ABOUT RECEIVING PROMOTIONAL COMMUNICATIONS 

We want to communicate with you only if you want to hear from us. If you prefer not to receive promotional information from us or from our head office (New Look Vision Group), please let us know by using one of the following methods: call us at 1 877 667-2020, e-mail us at infoweb@greiche-scaff.com or send a request to Greiche & Scaff Customer Service at 4405 Chemin Bois Franc, Saint-Laurent, Qc, H4S 1A8. Please be sure to include your full name, telephone number and e-mail address. It may take up to two (2) weeks to process your postal mail request, during which period you may continue to receive promotional communications from Greiche & Scaff. You may also unsubscribe from our promotional e-mail services by using the unsubscribe link at the bottom of any promotional message you receive from Greiche & Scaff. 

Please be aware that, even if you have opted out of receiving promotional communications from us, we may still contact you for transactional purposes. For example, we may contact you for customer service, product information, service or reminder notices, or recalls. We may also need to contact you with questions or information regarding your order, such as regarding order status, shipment, or refunds. 

HOW TO ACCESS OR CHANGE YOUR PERSONAL INFORMATION, WITHDRAW YOUR CONSENT, MAKE INQUIRIES OR LODGE A COMPLAINT REGARDING THIS POLICY AND GREICHE & SCAFF’S PRIVACY PRACTICES 

Greiche & Scaff will ensure that the personal information it collects is as accurate, complete, and up to date as is necessary for the purposes for which it is to be used. You are entitled to request access to or correction of your personal information in our custody or control.  

In order to make such a request, or if you have any questions or complaints in relation to this Policy and Greiche & Scaff’s privacy practices, please contact our Privacy Officer as provided below. Your right to access or correct your personal information is subject to applicable legal restrictions. Upon request, we will provide you with access to your personal information as soon as reasonably practicable, in compliance with applicable laws. We may take reasonable steps to verify your identity before granting access or making corrections.  

If you have consented to the collection, use and/or disclosure of personal information as identified herein, please note that you can also withdraw your consent at any time by communicating with our Privacy Officer as provided below.  

Please note that we may retain certain information to the extent required by law and applicable professional orders as well as for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.  

HOW LONG IS YOUR PERSONAL INFORMATION RETAINED? 

We will keep your personal information as long as is reasonably necessary for the purposes described in this Policy or for a longer period as may be required by applicable law. 

HOW IS YOUR PERSONAL INFORMATION SECURED? 

Greiche & Scaff has adopted appropriate measures to ensure the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copy, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used. Furthermore, each and every Greiche & Scaff employee, mandatary or agent must abide by this Policy. 

CROSS-BORDER TRANSFERS 

We and our service providers may access, process or store your personal information outside of the country where we are located and where you reside. When your personal information is accessed, processed or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, and accessible to the courts, law enforcement or government agencies of that jurisdiction. 

MOBILE PRIVACY 

When you use our mobile-optimized website or our mobile application, we may receive information about your location and your mobile device, including a unique identifier for your device. Greiche & Scaff and our service providers may use and store this information to provide you with location-based services, search results, and other personalized content. Greiche & Scaff will provide notifications only to those customers who accept to receive such notifications. Most mobile devices allow you to control or disable location services in the device's settings menu. If you have questions about how to disable your device's location services, we recommend you contact your mobile service carrier or the manufacturer of your particular device. 

OTHER WEBSITES 

THE WEBSITES MAY CONTAIN LINKS TO OTHER WEBSITES THAT ARE NOT OPERATED BY US. THE POLICY DOES NOT APPLY TO THE PRACTICES OF THIRD PARTIES AND WE DO NOT ASSUME ANY RESPONSIBILITY FOR ANY SUCH THIRD PARTY PRACTICES OR FOR THE PRIVACY PRACTICES OF THE WEBSITES THAT WE DO NOT OPERATE. BY USING OUR WEBSITES AND/OR ACCESSING A THIRD PARTY’S WEBSITE FROM OUR WEBSITES, YOU RELEASE US OF ANY RESPONSIBILITY FOR THE ACTIONS, PRACTICES AND OMISSIONS OF THIRD PARTIES. BY CLICKING ON ANY HYPERLINKS TO OTHER WEBSITES FROM OUR WEBSITES, YOU MAY AUTOMATICALLY SUBMIT TO THE PRIVACY PRACTICES OF THOSE WEBSITES. WE ENCOURAGE YOU TO REVIEW THE PRIVACY POLICIES OF THESE THIRD-PARTY WEBSITES. IN NO EVENT SHALL WE OR ANY OF OUR AFFILIATES BE LIABLE TO YOU OR ANYONE ELSE FOR ANY DAMAGES OR INJURY WHATSOEVER (INCLUDING BUT NOT LIMITED TO DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY OR PUNITIVE DAMAGES) ARISING OUT OF OR IN CONNECTION WITH THE MISUSE OF PERSONAL INFORMATION BY THOSE WEBSITES. 

PRIVACY POLICY CHANGES 

If we change the Policy, we will post the updated Policy on our Websites so that you can be updated as to what information we gather, how that information may be used and whether (and how) it may be disclosed to any third parties. If the changes we make are significant, we will provide a more prominent notice when required by applicable laws. Following the posting of such changes, you will be bound by such changes unless you advise us in writing, by phone or by e mail that you wish to withdraw your consent (as per the procedure outlined above). You are responsible for regularly reviewing the Policy and any changes thereto. 

CHILDREN UNDER THE AGE OF 14 

We do not knowingly collect personal information from children, or send them unsolicited promotions, without consent of the child’s parent or legal guardian and complying with any other legal requirements. If we become aware that we have unknowingly collected personal information about a child without parental or legal guardian consent, we will delete this information from our records or take reasonable steps to de-identify the information. 

HOW TO CONTACT US 

If you have questions or complaints regarding our Policy and practices or if you wish to request access to, or to correct your personal information under our care and control, please let us know by using one of the following methods: call us at 1 877 667-2020, e-mail us at infoweb@greiche-scaff.com or send a request to Greiche & Scaff Customer Service at 4405 Chemin Bois Franc, Saint-Laurent, Qc, H4S 1A8. Please consult the “How to Access or Change your Personal Information, Withdraw your Consent, Make Inquiries or Lodge a Complaint with Regards to this Policy and Greiche & Scaff’s Privacy Practices” section above for more information on submitting a request, question or complaint. 

If you believe the privacy legislation relating to the protection of your personal information or our Policy has not been respected, you may file a complaint with our Privacy Officer at privacy@newlookvision.ca. We will investigate all complaints. If, after an investigation, your complaint is deemed justified, we will take appropriate steps to correct the situation, including, if necessary, amending our policies and practices.