Last updated January 1, 2020

This Privacy Policy describes how Alcon Vision LLC and its affiliates under common ownership and control (collectively, “Alcon”) use and disclose the information we collect from you through our U.S. websites, social media forums, and other online services that link to, incorporate, or for which you are provided a copy of this Privacy Policy (collectively, the “Services”), and the choices you have about how we use your information.

What Information Do We Collect?

• Information You Provide: We collect information that you voluntarily provide when you use the Services, such as when you register for an Alcon program or service, participate in a survey, provide a testimonial, order a product, participate in an interactive feature or forum (such as chat features), or contact us with a question, comment, or request. The type of information that you provide is based on the specific function of the Services that you use or the Alcon program or service for which you register, and might include, for instance, your name, address, age, birth date, gender, email address, phone number, photo, social media account ID, zip code, education, professional experience, demographic information, information about your health and/or medical conditions, product usage and preferences.
• Information We Receive from Third Parties: We may combine the information we collect from you with information that we receive about you from other sources, such as public databases, providers of demographic information, joint marketing partners, social media platforms, people with whom you are connected on social media platforms, and other third parties.

What Information Do We Collect Automatically From Your Device and How Do We use It?

We and our third party service providers may collect information automatically from your device in a variety of ways including:

• Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, device type, screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
• Using cookies: Cookies are small text files that are stored directly on your device when you visit a website. For more information about Cookies, pixel tags or similar technology, or our use of that technology, click here.

How Do We Use Your Information?

In addition to using your information to deliver the programs, services, products, or information you request, and for the purposes described above, we may also use it:

• to provide customer support;
• to fulfill purchases or other transactions made by you;
• to deliver marketing communications that may be of interest to you;
• to send administrative information to you, such as information about the Services and our terms, conditions and policies;
• to permit you to participate in polls, surveys, promotions, or other interactive features, such as chat features, and to administer these activities;
• to personalize your experience and better tailor content and offers to you;
• to facilitate social sharing functionality;
• to allow you to send messages to another person through the Services;
• to help us and our business partners better understand our audiences, evaluate user interest in the Services, improve the Services, and perform other market research activities;
• for our business purposes, such as data analysis; audits; monitoring and prevention of fraud, infringement, and other potential misuse of the Services; modifying the Services; determining the effectiveness of our promotional campaigns; and operating and expanding our business activities; and
• as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (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 protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

In addition to those purposes listed above, we may use your information for any other purpose disclosed to you at the time of collection or that you have previously authorized. We may combine, aggregate, or anonymize any of the information we collect from you with other information we may collect from or abut you from any other online or offline source. We may use information that does not personally identify you for any purpose, except where we are required to do otherwise under applicable law.

When and to Whom Do We Disclose Your Information?

The information we collect from and about you may be disclosed:

• to the subsidiaries and affiliates within the Alcon group of companies, for the purposes described in this Privacy Policy;
• to third parties that provide services to us, such as those that fulfill requests for information, answer calls, administer programs or projects, assist in research and development, or deliver advertisements or other communications;
• to business partners who offer products or services jointly with Alcon;
• to permit a third party business partner to deliver marketing communications or products that may be of interest to you, subject to any choices you have expressed;
• to identify you to any person to whom you send messages through the Services;
• to any person you direct us to contact, such as your designated caregiver(s);
• by you, on message boards, chat, profile pages, blogs, and other services to which you post information and materials. Because any information you post may become public, we urge you to be very careful when deciding to disclose any information on or through the Services;
• to your friends associated with your social media accounts, to other Services users, and to your social media account providers, in connection with your social sharing activity, such as if you connect your social media account to your Services account or log into your Services account from your social media account. By connecting your accounts, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media provider’s own privacy policy;
• as required by law, such as to law enforcement, to health authorities to report possible adverse events, during government inspections or audits, as ordered or directed by courts or other governmental agencies, or in order to comply with a subpoena or other legal process;
• when we believe in good faith that disclosure is necessary to protect legal rights or the security or integrity of our operations or the Services; protect your safety or the safety of others; investigate fraud, a breach of contract, or a violation of law; respond to a government request; or allow us to pursue available remedies or limit the damages that we may sustain; and
• to third parties, advisors, and other entities to the extent reasonably necessary for development of or to proceed with the negotiation or completion of a corporate or commercial transaction, including a reorganization, merger, acquisition, joint venture, sale or other disposition of all or a portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

We may disclose information that does not personally identify you for any purpose, except where we are required to do otherwise under applicable law.

Your Choices

Where you have elected to participate in one of our programs or services or to receive marketing communications from us, we offer you the ability to discontinue your participation or to opt out of receiving those communications in the communication itself. Alternatively, you can contact us to opt out using the contact information found in the “How to Contact Us” section at the end of this Privacy Policy.

We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across websites or other online services.

Information Security

We seek to use appropriate technical, administrative, and physical safeguards to protect the information collected through the Services. Unfortunately, no organization can guarantee the absolute security of electronic information, especially information transmitted over the Internet.

Children's Information

The Services are not directed to children under the age of sixteen (16), and we do not knowingly collect personal information from such children.

Your California Privacy Rights

If you reside within California, and wish to know more about how we handle your personal information, or your privacy rights with respect to that information, it may be different than described above. You may click here to learn more.

If you have a disability, and need this Notice in a more accessible format, you may contact us at 1-800-253-1462 or [email protected], and we will endeavor to provide this notice in a more accessible format.

Information We Collect about California Residents

In particular, we have collected the following categories of personal information from California residents within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

YES

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Specific physical location or movements.

NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

YES

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

YES

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our clients or their agents. For example, from records that our clients provide to us related to the services for which they engage us.
• Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
• Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically.
• From third-parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.

Use of Personal Information

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

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to provide guidance related to a medical device.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To audit related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with laws and other standards.
• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
• To perform services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business;
• For debugging to identify and repair errors that impair existing intended functionality.
• For short-term, transient use, provided your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
• To undertake internal research for technological development and demonstration.
• To perform activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the company, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
• To carry out our obligations and enforce our legal rights.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• 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 CCPA.
• 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.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Your California Privacy Rights and Choices

The CCPA provides California resident consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use 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.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion or Sale Restriction Request Rights

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. You also have the right to request we not sell your personal information, if it is being sold. The definition of “selling” under the California Consumer Privacy Act is broad, and includes” selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.” Once we receive and confirm your verifiable consumer request, we will restrict the sale of, or delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it, or as otherwise permitted under applicable law.

Exercising these Rights

To exercise the rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 1-800-253-1462.
• Emailing us at [email protected]

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-800-253-1462
email: [email protected]

If you reside in California, are under 18 and are a registered user of the Services, you may contact us by using the contact information found in the “How to Contact Us” section at the end of this Privacy Policy to remove content or information that you have posted to the Services. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, if you posted in a public forum, like social media, some of your content may have been reposted by another user.

Accessing and Updating Your Information

We encourage you to update the personal information you provide to us to help us continue to provide information that best meets your needs. You may be able to access and update this information through the member or account section of the service for which you registered, or you can contact us by using the contact information found in the “How to Contact Us” section at the end of this Privacy Policy. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.

Links to Third Party Websites

The Services may contain links to third party services that are not under our control. We are not responsible for the collection and use of your information by such services, and we encourage you to review their privacy policies. In addition, we are not responsible for the information collection, use, disclosure, or security practices of other organizations, such as Facebook, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including in connection with any information you disclose to such other organizations through or in connection with the Services.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time by posting a new Privacy Policy on our website. If we make a material change to our Privacy Policy, we will take reasonable steps to notify you, for example, by posting a banner or pop-up notice on the website.

How to Contact Us

If you have any questions about our Privacy Policy, please contact us by emailing [email protected] or by writing to Alcon Global Privacy Office, Alcon Vision LLC, 6201 South Freeway, Fort Worth, TX 76134 USA.

Timekeeping Biometric Information Privacy Policy