Privacy Policy

EFFECTIVE DATE: 1 January 2023

CONTENTS OF THIS POLICY

WHO WE ARE
ABOUT THIS POLICY
WHAT TYPE OF PERSONAL INFORMATION DO WE COLLECT?
HOW DO WE USE YOUR INFORMATION?
HOW AND WHEN DO WE SHARE PERSONAL INFORMATION WITH THIRD PARTIES?
HOW LONG DO WE STORE PERSONAL DATA?
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
YOUR RIGHTS
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
CHANGES TO THIS POLICY
HOW TO CONTACT US
CHILDREN

California Notice at Collection/State Law Privacy Rights: See the State law privacy rights section below for important information about your rights under applicable state privacy laws.

WHO WE ARE

At The Cooper Companies, we are people helping people – applying our collective knowledge, experience and talents to improve lives, one person at a time. This means helping them see the world brightly, fulfill their dreams of having children and so much more through our range of products and services.

In this Privacy Policy, The Cooper Companies, Inc. may refer to itself as “we”, “us” or “our”, and doing so may also include our related companies.

ABOUT THIS POLICY

We are committed to providing professional and valuable products and services that help people improve the way they see while taking measures designed to safeguard your privacy.

This Privacy Policy describes how we collect, use, and share Personal Information about our business customers (including opticians), potential customers, consumers and users of our websites, applications and platforms that link to this Privacy Policy.

We may separately process Personal Information for and at the direction of our business customers and such processing is outside the scope of this policy. Our use of Personal Information that we process for or on behalf of our business customers may be governed by our agreements with such customers. If you have concerns regarding your Personal Information that we process for or on behalf of a business customer, please direct your concerns to that business customer.

For purposes of this Privacy Policy, the term “Personal Information” has the meaning given to “personal data”, “personal information” or other similar terms in applicable privacy laws and does not include information exempted from the scope of the State Privacy Laws (as defined in the State Privacy Rights section below). In some cases, we may provide a different privacy notice to certain categories of residents of these states, such as job applicants, in which case that notice will apply instead of this section.

This Privacy Policy also applies to consumer-related personal information we receive through your use of third-party sites or platforms (for example, if you choose to interact with us via your social media or other accounts) where your information may be provided. While those third-party sites or platforms may have their own privacy policies, the information we collect is covered by our privacy policy. Any privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications.

Please also keep in mind that our sites and applications may contain links to other sites not owned or controlled by us. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.

WHAT PERSONAL INFORMATION DO WE COLLECT?

The types of personal information we may collect are described below.

Below is a list of the categories of personal information (and an indication of what we collected during the last 12 months). Please note that the “Statutory Categories of Information” and the definitions of “share” and “sell” refer to those defined under the California Consumer Privacy Act (“CCPA”). For more information on the CCPA and other State Privacy Laws, please refer to Section H below. Note that our use services that help deliver interest-based ads to you may be classified under the State Privacy Laws as “selling” or “sharing” your Personal Information, however we do not otherwise “sell” Personal Information.

Statutory Categories of Information	Personal Information We May Collect	Categories of third parties to whom we “disclose” PI for a business purpose	Categories of third parties to whom we “sell” or “share” Personal Information
Identifiers	Name(s), an alias or unique personal/online identifier (such as username or login name), address, email address, username, password, date of birth, internet protocol (IP) address; national/state identification card number, passport number, signature, photograph or voice, travel arrangements information, dietary restrictions/requirements.	All of the third parties in Section E below	Marketing and advertising partners (All listed Identifiers except state identification card number and photo.)
Education Information	School, year of graduation, certifications	All of the third parties in Section E below	No
Professional or employment-related information	Business unit division, company entity, office location, role, individual NPI (national provider identifier), practice name, practice address, professional license number, state of licensure, certifications.	All of the third parties in Section E below	No
Commercial Information	Cooper account number, records, dates, locations and other details of services or products purchased/sold, obtained, or considered; business partner ID, group ID and business line; other purchasing/sale or consuming histories, details or tendencies; product or technology interest, invoices, claim amounts, offer codes, marketing opt-In status, opt-in contact details.	All of the third parties in Section E below	Marketing and advertising partners
Internet or Other Electronic Network Activity information (“Electronic Information”)	Browsing history; search history; information regarding a consumer’s interaction with an internet website, application, or advertisement; cookies; IP address of your device, information about the operating system and/or app you are using; unique device identifiers; online identifiers, pages that you navigate to and links that you click; your preferences and settings.	All of the third parties in Section E below	Marketing and advertising partners
Geolocation Data	Location information collected by a browser or inferred by IP addresses, mobile device signals.	All of the third parties in Section E below	Marketing and advertising partners
Sensory Information	Audio, electronic, visual, thermal or similar.	All of the third parties in Section E below	No
Inferences	Consumer type; potential purchasing behavior.	All of the third parties in Section E below	Marketing and advertising partners
Physical Description	Physical characteristics or description.	All of the third parties in Section E below	No
Medical Information	Health insurance and lens prescription information.	All of the third parties in Section E below	No
Financial Information	Bank account number and details, debit or credit card numbers, insurance policy number, and other financial information.	All of the third parties in Section E below	No

HOW DO WE USE YOUR INFORMATION?

We use personal information for some general purposes. The information allows us to provide you with products, services, and customer support, to bill you for products and services you request, to market products and services which we think may be of interest to you, or to communicate with you for other purposes. The types of general uses include:

record keeping, statistical analysis, internal reporting and research
hosting, maintaining and otherwise supporting the operation of our websites, applications and other communication platforms, and helping to customize and improve your experience with our websites, applications and other platforms
ensuring the quality of the products and services we provide to you
detecting, preventing and addressing technical issues
investigating, resolving or otherwise addressing complaints made by you or any disputes between you and us
detecting and preventing fraud or other criminal offenses
risk management
business and disaster recovery (e.g. to create back-ups)
network and information security
document and data retention/storage
to create aggregated, de-identified and/or anonymized data for our lawful business purposes, including to analyze and improve our services and promote our business

We also use Identifiers, Commercial Information, Electronic Information, Geolocation Data to help us establish and maintain a relationship with you, through things like:

creating an account(s) with us or for identification purposes
your request for us to send products to you or to provide services to you
communicating with you, including with non-marketing materials or marketing materials about our company or our products/services, and to provide you with email alerts or other notices concerning our products or services, events or news that may be of interest to you
linking your profile on a third-party site or platform with any account(s) with us
entering a promotion, contest, sweepstakes, etc.
requesting or submitting a rebate and rebate fulfillment
fulfilling orders, including delivery of contact lenses
processing a payment at your request or on your behalf
confirming your authorization of transactions

When you use our websites, applications or platforms or if you choose to interact with our us via third party platforms (such as your social media accounts), we may collect Identifiers, Electronic Information and Geolocation Data about your usage of or interactions with us for:

personalizing your experience with us
enabling your use of the services available on our websites, applications or platforms
contacting you about our products, services or other news

Cookies are small pieces of information sent to your browser and stored on your computer’s hard drive. We use information collected by cookies to help improve the contents of our websites and to compile aggregate statistics about people using our site for our internal usage statistics, market research purposes, as well as for marketing and advertising purposes. When installed, cookies collect the domain name of the user, your internet service provider, your operating system, and the date and time of access. You can set your browser to notify you when you receive a cookie, this will enable you to decide if you want to accept it or not. You can also refuse cookies altogether via your particular browser’s settings. However, if you do not accept our cookies, you may not be able to use all functionalities of our website.

We use Geolocation Data:

to enable you to use our “Find a Practitioner” tool
to identify where you are contacting us from

Geolocation Data may be collected from your computer, your devices, you telephone, and your use of applications or platforms.

We may be required to collect your personal information 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.

HOW AND WHEN DO WE SHARE PERSONAL INFORMATION WITH THIRD PARTIES?

We may share your Personal Information with members of our corporate group (here are details of our Affiliates) in order to provide the products and/or services or information that you have requested. We may also share your information with other members of our corporate group for the purposes of IT support and maintenance, internal governance and administration, and to comply with our legal or regulatory obligations.

We will not share your personal information with a third party outside our corporate group, except:

when you permit us to do so
where you have instructed us to share your personal information with third-party sites or platforms, such as social networking sites (Please note that once we share your personal information with another company, the information received by the other company is controlled by that company and becomes subject to the other company’s privacy practices)
when parties perform services on our behalf, like product delivery, customer service, IT services and solutions (e.g. providing data storage, assisting us with database management) or rebate fulfillment. We prohibit these companies from using your personal information for purposes other than those requested by us or required by law
when we share your personal information with third-parties in connection with the sale of a business; to enforce our Terms of Use or rules; to ensure the safety and security of you or others; to protect our rights and property and the rights and property of you and others; to comply with legal process; or in other cases if we believe in good faith that disclosure is required by law
when we share your personal information for direct marketing and advertising purposes.

We may also share your personal information 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 information in order to comply with any legal obligation, or to protect the rights, property and/or safety of our company, any of our 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
to protect the safety of any person, to address fraud, security, or technical issues, or to protect our rights or property or the rights or property of those who use our websites, applications and platforms. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third-party’s, including a government’s, request to disclose your personal information

HOW LONG DO WE STORE PERSONAL DATA?

It is our policy to retain your personal information 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 information 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 defense of legal claims (e.g., for the purposes of a potential dispute)

If you would like to find out how long we keep your personal information for a particular purpose, you can contact us at: dpo@coopervision.com.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We implement technical and organizational security measures designed to protect your personal information against the risk of loss, misuse, or unauthorized alteration or destruction.

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 that we take from you online we will use a recognized online secure payment system.

CHANGES TO THIS POLICY

We may revise this Privacy Policy from time to time to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will notify you of changes by posting changes on our relevant website, application or platform, or by other appropriate means. Any changes to the Privacy Policy will become effective when the updated policy is posted on the relevant website, application or platform. Your use of the services on our websites, applications or platforms, or your provision of information to us following such changes indicates your acceptance of the revised Privacy Policy.

HOW TO CONTACT US

If you wish to request further information regarding this Privacy Policy or the way we use your personal information you can contact dpo@coopervision.com.

CHILDREN

Our websites, applications and platforms are not intended for use by anyone under 13 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through our websites, applications and platforms from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

STATE PRIVACY RIGHTS

This section applies to residents of California and Virginia and provides additional information to residents pursuant to applicable state privacy laws including the California Consumer Privacy Act (“CCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”) (collectively the “State Privacy Laws”). In this section, the term “Personal Information” means information defined as “personal information,“ “personal data,” or other similar term under the State Privacy Laws. The State Privacy Laws may provide residents with some or all of the rights listed below. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of one of these states listed above, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it. We may decline your request in certain cases as permitted by law.

- Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
  - The categories of Personal Information that we have collected.
  - The categories of sources from which we collected Personal Information.
  - The business or commercial purpose for collecting and/or selling Personal Information.
  - The categories of third parties with which we share Personal Information.
  - The categories of Personal Information that we sold or disclosed for a business purpose.
  - The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
- Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.

Appeal. You can appeal our denial of any request validly submitted.

- Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
- Deletion. You can ask us, subject to certain exceptions, to delete the Personal Information that we have collected from you.

Opt-out of certain processing for targeted advertising purposes. You can opt-out of certain processing of personal information for targeted advertising purposes.

Opt-in. If we know that you are 13-15 years of age, we will ask for your affirmative authorization to sell your Personal Information or share your Personal Information for targeted advertising purposes before we do so.
Non-discrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.

Exercising your right to information/know, access, appeal, correction, deletion and limit processing of Sensitive Personal Information. You may submit requests to exercise your right to information/know, access, appeal, correction, deletion or limit processing at HERE or by calling us toll free at (855) 526-6737.

Exercising your right to opt-out of processing for targeted advertising purposes. While we do not sell personal information for money, like many companies, we use services that help deliver interest-based ads to you as described above. The State Privacy Laws may classify our use of some of these services as “selling” or “sharing” your Personal Information with the advertising partners that provide the services. You can opt-out of tracking for targeted advertising purposes or other sales of Personal Information by clicking the Opt Out Link and toggling the advertising and targeting category to the off mode. Your request to opt-out will apply only to the browser and the device from which you submit the request. You can also broadcast the Global Privacy Control (GPC) to opt-out for each participating browser system that you use. Learn more at the Global Privacy Control website.

Verification of Identity; Authorized agents. We may need to verify your identity in order to process your information/know, access, appeal, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law.

Under the State Privacy Laws, you may be permitted to authorize an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your CCPA rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

Sensitive personal information. We do not use or disclose Sensitive Personal Information for purposes that California residents have a right to limit under the California Consumer Privacy Act.

The Cooper Companies Group

The Cooper Companies, 6101 Bollinger Canyon Rd #500, San Ramon, CA 94583 USA
Eye Care Prime, LLC, 5870 Stoneridge Drive, Suite 1 Pleasanton, CA 94588
Blanchard Vision Corp., 1552 Rue King Ouest, Sherbrooke, Quebec J1J 2C3, Canada
Paragon Vision Sciences, Inc., 2120 W. Guadalupe Rd., Suite 112, Gilbert, AZ 85233 USA
CooperVision Limited (company number 03685161) with its registered address at Delta Park, Concorde Way, Segensworth North, Fareham, Hampshire, PO15 5RL, UK
CooperVision Manufacturing Limited (company number 02737396) with its registered address at Delta Park, Concorde Way, Segensworth North, Fareham, Hampshire, PO15 5RL, UK
CooperVision Singapore Pte Ltd (company number 200507296Z) with its registered address at 8, Temasek Boulevard #19-03 Suntec Tower 3, Singapore 038988
CooperVision SAS (company number 392 002 218) with its registered address at Les Collines De Sophia, 1800 Route Des Cretes, Sophia Antipolis 06905, Cedex, France
CooperVision Italia, S.R.L. (company number 10653750157) with its registered address at Via Meravigli, 16 – 20123 Milan, Italy
CooperVision Iberia, S.L. (company number 79424594) with its registered address at Ronda de Poniente, 12, 28760 Tres Cantos, Madrid, Spain
CooperVision Nordic AB (company number 556568-1243) with its registered address at Johan Willins gata 8, SE-41664 Goteborg, Sweden
CooperVision GmbH (company number HRB 33358) with its registered address at Siemensstraße 3, 64859, Epperthausen, Germany
CooperVision Nederland B.V. (company number 23075034) with its registered address at Avelingen - West 40, 4202, MS Gorinchem, Netherlands
CooperVision Poland Sp. z o.o. (company number 0000464435) with its registered address at Przemysława Gintrowskiego 53, 02-697 Warsaw, Poland
CooperVision Kft (company number 01-09-166734) with its registered address at Sopron ut 25-27, Budapest, 1117, Hungary
CooperVision Limited, organizacni slozka (company number 24838411) with its registered address at Na Pankráci 1724/129, Praha 4, 140 00, Czech Republic
CooperVision Distribution Sprl (company number 0879.484.449) with its registered address at Premiere Avenue 32, B-4040, Belgium