Nikon Difference App Privacy Policy

This Privacy Policy (“Policy”) is effective as of 22^nd of February 2023.

This Policy describes how Nikon-Essilor Co., Ltd (collectively “Nikon-Essilor”, “we,” “our,” or “us”), collect, use, and disclose information through the Nikon Difference App (“App”). Other “Nikon-Essilor websites, products, and services may have their own privacy policies.

How We Collect the Information

When using our App or our services, you may provide us with your personal information through a variety of methods, including the following: (1) when you use our technology; (2) download the App; or (3) when you interact with us for any other purpose.

We may collect certain information automatically when you use the App, as described below.

The Information We Collect

We collect information such as personal preferences relative to lens usage and vision, prescription formula to recommend the suitable products for consumers.

We also may automatically collect technical information when you use our App (for example, browser version, IP address, country, region, state, estimated location based on IP, Internet service provider, network connection, referring/exit pages, operating system, date/time stamp, clickstream data and reference site domain name, crash data, device sensor data, duration of App use, interaction with App, domain name, mobile ad identifiers, language settings, customer traffic patterns and website usage).

How We Use This Information

We may use the information we collect for any lawful purpose, including the following:

1) To process and fulfill any of your requests;

2) To administer services to you;

3) To operate and improve the App, for example, to analyze visits to the App and learn about our visitors so we can operate the App and improve our products and services and deliver the best user experience;

4) To research, and analyze for developing the market;

5) To create audiences for our advertisements, target our advertisements, and generate reports about the performance of our advertisements;

4) To communicate with you, including responding to your inquiries;

5) To comply with the law and to maintain the security of our App; and

6) As otherwise disclosed at the time of collection or use.

Disclosing Information to Third Parties

We engage service providers to perform services in connection with the operation of our business. We may disclose personal information with service providers so that they can perform these services. Examples of these services include product customization, App evaluation, data analysis and, where applicable, data cleansing.

Personal information collected through our App may be shared by Nikon-Essilor with other companies distributing Nikon-Essilor products worldwide. The name of the Nikon-Essilor distributor for any country can be obtained by simple request at =

Contact

We may also share your personal information if: (1) the law or legal process requires it; (2) we have received a valid administrative request from a government agency or law enforcement; or (3) we determine that such sharing is necessary or appropriate to protect the rights, property, or safety of Nikon-Essilor, or any of our respective affiliates, service providers, customers, or others.

We may also disclose your information with your consent or as otherwise specified at the time of data collection or disclosure.

We may also disclose your personal information to a third party in the context of any reorganization, financing transaction, merger, sale, joint venture, partnership, 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).

You may be allowed to provide comments in various sections of our App, such as the product reviews section. Please be aware that the information you post in these areas may be available to visitors of the App and to the general public.

We may disclose aggregated information, de-identified information, and technical information at our discretion. For example, we may disclose aggregated demographic information about the App’s visitors with our affiliates, service providers, or vendors, so that they can provide marketing analysis and consult on advertising strategies. We also may disclose technical information, such as the number of users who visited the App during a specific time period or who with our service providers and others from time to time.

Retention Period

We retain each category of personal information that we collect for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you (for example, for as long as you have a customer account with us) and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise;

Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or

Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

We may also work with service providers that collect data about your use of the App. We use analytics providers to gather and analyze aggregated anonymous user information.

We use analytics tools to enhance user experience by optimizing the efficiency, design, and quality of the App. Our analytics tools may use cookies and similar technologies to collect and analyze information related to user behavioral metrics on the App, clicks, user inputs, scrolling, access time, visit duration, pages viewed, IP address (including approximate location), operating system, and page reloading. These tools provide insight into what works and what doesn’t work for users of the App and they allow us to, for example, identify and repair technical errors that impair the App’s functionality. The analytics tools also help us reconstruct the user experience to better understand, for example, where users may be encountering frustration or impediments to using the App.

Children

The App is not intended for use by a child without supervision of the child’s parent or guardian, or of an eye care professional servicing the child.

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 “Contact Information” 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 maintain reasonable and appropriate safeguards to help protect your personal information from loss and from unauthorized acquisition. We monitor activity on our App to prevent any unauthorized disclosure of information.

Updates to Policy

We may change this Policy at any time in our discretion. If we decide to change our Policy, we will post the changes on this page. Please review this page periodically to see any updates to the information provided here. This Policy was last updated on 22^nd February 2023.

Your Choices

You acknowledge that this policy is available to you, and the public, at any time upon request or via this App. If you have any questions or concerns regarding this policy and consent, please contact us as described in the Contact Information section below. By using this App, you acknowledge that you have read this policy, understand it and agree to abide by it, in addition to Nikon Difference’s full Privacy Policy and its Terms and Conditions of Use.

If you choose to exercise these rights, we will not discriminate against you because of it.

You or your authorized agent have the right to

1) Know what personal information is being collected;

2) Access your personal information we collect;

3) Request deletion of your personal information we have collected;

4) opt-out of the sale or sharing of your personal information;

5) To correct inaccurate personal information;

6) Know which personal information is sold or shared; and to whom

7) Limit use and disclosure of sensitive personal information (“SPI”).

If you choose to submit a request through an authorized agent, we will require proof that the authorized agent has your written permission to submit a request on your behalf. Additionally, we may require you to verify your identity with us through the verification process detailed below.

Requests to Know and Access

You have the right to request that we disclose certain information to you about the collection, use sale and sharing of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you, if any;

The categories of sources from which personal information were collected;

The business or commercial purpose for collecting, sharing, or selling personal information;

The categories of recipients to whom we disclose, share, or sell personal information;

The specific pieces of personal information we have collected about you;

If we sold, shared, or disclosed your personal information for a business purpose to any entity other than Nikon-Essilor distributors and suppliers processing data for the benefit of Nikon-Essilor distributors.

Request to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request to delete, we will delete (and direct our service providers and contractors to delete) your personal information from our records, unless an exception applies. Subject to certain exceptions, we will also notify all third parties to whom we have sold or shared personal information of your request to delete.

Note: for requests to delete, we will require you verify your identity including requiring you to provide your name and email and to confirm your identity through a confirmation email message. For some requests, we may also require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. Once submitted, you will receive an email within several days that we will use to verify your identity and provide confirmation of your request. If we cannot verify your identity within 45 days, we may deny your request. We will respond to your request to delete within 45 days from the day we receive the request. If necessary, we may extend the time period to a maximum total of 90 days from the day we receive the request. In such case, you will receive an email notifying you of the extension and explaining the reason for the extension. Any disclosure in response to a request to know will cover the 12-month period preceding the business’s receipt of the request, unless otherwise specified, and will be delivered in a readily useable digital format, or by mail at your request.

Your request to delete may be denied for any reason permitted under applicable law.

Right to Opt-Out of the Sale of Personal Information

You have the right, at any time, to opt of the sale or sharing of your personal information to third parties (as “third parties” is defined as entities other than Nikon-Essilor distributors and suppliers processing data for the benefit of Nikon-Essilor distributors.).

We will act upon your request in accordance with the requirements set forth in the local laws and regulations. Note that we may deny a request to opt-out if we have a good-faith, reasonable, and documented belief that the request is fraudulent. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.

Requests to Correct Inaccurate Information

You have the right to request correction of inaccurate information. Once we receive and verify your request, we will undertake commercially reasonably efforts to correct inaccurate information, taking into account the nature of and the purposes for processing the personal information.

Business or Commercial Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To provide you with the service that you request from us;

To improve our App and present its contents to you;

For testing, research, analytics, and development;

To create audiences for our advertisements, target our advertisements, and generate reports about the performance of our advertisements;

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;

As described to you when collecting your personal information or as otherwise set forth in the local laws and regulations;

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Disclosure, Sale, or Sharing of Personal Information

In the preceding twelve (12) months, we have disclosed, or shared personal information to third parties for a commercial or business purpose, as authorized under applicable law.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose to the following categories of third parties indicated in the chart below.

Identifiers

Parent or Subsidiary Organizations
Affiliates
Service Providers
Operating Systems and Platforms
Data Analytic Providers

Your Rights

You have the right to

1) Confirm whether your personal data is being processed and to access that data;

2) To correct inaccuracies in your personal data taking into account the nature of and the purposes for processing the personal data;

3) Delete personal data provided by you or obtained from you;

4) Obtain a copy of your personal data that you previously provided to us in a portable, and to the extent feasible, readily usable format that allows you to transmit the data to another controller without hindrance;

5) To opt out of the processing of 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; and

6) The right to not be discriminated against for exercising any of the foregoing rights.

Please know that we will not discriminate against you because of your decision to exercise any or all of these rights.

Purpose for Processing Personal Data

We process personal data for one or more of the following purposes:

To provide you with the services that you request from us.

To improve our App and present its contents to you.

For testing, research, analytics, and development.

To create audiences for our advertisements, target our advertisements, and generate reports about the performance of our advertisements.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

As described to you when collecting your personal information or as otherwise set forth in the local laws and regulations.

How to Exercise Your Rights

You may exercise your rights as described in the “How to Exercise Your Rights” section above. You may appeal our decision with regard to your request by submitting the request to https://www.nikonlenswear.com/contact/, identifying the request as an appeal, and describing the reason for the request.

Contact Information

If you have questions or wish to contact us about this Policy, please direct inquiries to:
Privacy Office
Nikon-Essilor Co., Ltd