TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE USE YOUR INFORMATION?

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

5. HOW LONG DO WE KEEP YOUR INFORMATION?

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

7. DO WE COLLECT INFORMATION FROM MINORS?

8. WHAT ARE YOUR PRIVACY RIGHTS?

9. CONTROLS FOR DO-NOT-TRACK FEATURES

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

11. DO NEVADA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

12. DO WE MAKE UPDATES TO THIS POLICY?

13. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?

14. DO I CONSENT TO DATA TRANSFER IF I AM A NON-US RESIDENT?

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA THAT WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us such as name, address, contact information, passwords, and security data.

We collect personal information that you voluntarily provide to us when registering with the Digital Services expressing an interest in obtaining information about us or our products and services when participating in activities on or in conjunction with the Digital Services or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the choices you make with respect to the Digital Services you request. The personal information we collect can include the following:

Publicly Available Personal Information. We may collect first name, last name, nickname, phone numbers, email addresses, business email, business phone number, and other similar data.

Credentials. We collect passwords, password hints, account number and similar security information used for authentication and account access. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Scholarship Applicants.  If you participate in the Walman Scholarship Program, we will obtain your first name, last and middle name, school or college of Optometry attendance, academic level, transcript including grade information and any other information that you may include on the application that you upload through the Scholarship America® portal including, optional information including your race and other demographic information and any PII you provide in the comments section.

Credit Applicants. If you submit an Application for Credit, we will collect your business name, mailing address including city, state and zip code information, email address, name and telephone contact information for your employee-designee(s) and certain business information including years of service, type of business, type of practice and owner name and contact information including mailing address and zip code, tax identification numbers, trade reference information including banking account number and bank contact information, together with the credit limit requested.

Eyecare Provider Account Login. If you register your practice for one of our Digital Services, we will collect your name and email address as well as your practice name, address(es) and telephone number.  Users will login with a username and password.   We may also collect other information such as title, practice owner name, and employee names.

Walman Optical Safety Eyewear Program. If you elect to participate in the Walman Optical Safety Eyewear Program, we will collect your name, address, telephone number, employee information, participating location information and program billing parameters and details and other information necessary for us to provide the Digital Services. 

Employment.   If you apply for employment, we will collect your name, email address, mailing address, telephone number, work authorization information, visa status, desired salary, academic level, employment history including salary, and any other information you include on the resume you upload to the Digital Services.  You may also choose to provide optional information such as race, gender, and whether you are disabled or your Veteran status.

Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Digital Services.

We automatically collect certain information when you visit, use or navigate the Digital Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser, and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Digital Services and other technical information. This information is primarily needed to maintain the security and operation of our Digital Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies – See “Online Identifiers” in this Section 1. below for additional information.  

Online Identifiers. We collect devices, tools and protocols, such as IP (Internet Protocol) addresses, cookie identifiers, or others such as the ones used for analytics and marketing, device's geolocation, and other similar data.   See our separate Cookie Policy which is part of our Privacy Policy for an explanation of how we use cookies, online identifiers and similar technologies with respect to our Digital Services, an explanation of cookies and similar technologies and why we use them, as well as your rights to control our use of them.

2. HOW DO WE USE YOUR INFORMATION?

In Short:  We process and use your information for our purposes based on legitimate business interests, the fulfillment of our Digital Services, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Digital Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

• To send you marketing and promotional communications.  We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS" below).
• To send administrative information to you. We may use your personal information to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
• Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Digital Services.
• To post testimonials. We post testimonials on our Digital Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update or delete your testimonial, please contact us with our data protection officer at dpo@walman.com and be sure to include your name, testimonial location, and contact information.
• Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
• Request Feedback. We may use your information to request feedback and to contact you about your use of our Digital Services.
• To protect our Digital Services. We may use your information as part of our efforts to keep our Digital Services safe and secure (for example, for fraud monitoring and prevention).
• To manage user accounts . We may use your information for the purposes of managing our account and keeping it in working order.
• To deliver services to the user. We may use your information to provide you with the requested Service.
• To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Digital Services.
• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Digital Services, products, marketing, and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end-users and does not include personal information. We will not use identifiable personal information without your consent.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with Digital Services, to protect your rights, or to fulfill business obligations. 

We may process or share data based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
  
  
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  
  
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
  
  
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  
  
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
  
  

More specifically, we may need to process your data or share your personal information in the following situations or where we are expressly authorized by applicable law to do so:

• Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology in connection with the Digital Services, which will enable them to collect data about how you interact with the Digital Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Privacy Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.  
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Digital Services. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

See “Online Identifiers” under Section 1. WHAT INFORMATION DO WE COLLECT? abovefor additional information about cookies and other tracking technologies.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law. 

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE? 

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, the transmission of personal information to and from the Digital Services is at your own risk. You should only access the Digital Services within a secure environment.  

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Digital Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Digital Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at dpo@walman.com.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details HERE.

If you have questions or comments about your privacy rights, you may email us at dpo@walman.com.  

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log into your account settings and update your user account. 

• Contact us using the contact information provided. 

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.    

Cookies and similar technologies:Most Web browsers are set to accept cookies by default.  See “Online Identifiers” under Section 1. WHAT INFORMATION DO WE COLLECT? above for additional information.       

Opting out of email marketing:You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you Service-related emails that are necessary for the administration and use of your account.

 9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.  

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information. 

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Digital Services, you have the right to request the removal of unwanted data that you publicly post on the Digital Services. To request the removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Digital Services, but please be aware that the data may not be completely or comprehensively removed from our systems.

11. DO NEVADA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information.  Subject to a number of exceptions, Nevada law defines "sale" to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons.  We do not currently sell personal information as defined in the Nevada law.  However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes.  Opt-out requests may be sent in writing to us using the contact information provided below.

12. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

In Short: Yes, we will update this Privacy Policy as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.  

13. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?

If you have questions or comments about this Privacy Policy, you may contact our Data Protection Officer (DPO),  by email at dpo@walman.com, or by mail to:

The Walman Optical Company    

Data Protection Officer

801 North 12th Avenue

Minneapolis, MN 55411  

United States    

14. DO I CONSENT TO DATA TRANSFER IF I AM A NON-US RESIDENT?

If you reside in a country other than the United States, upon providing your personal information to us, you will be indicating your explicit consent that the personal information you have provided may be transferred, processed and stored in the United States.

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. Requests to review, update, or delete your personal information, may be sent in writing to us using the contact information provided above. We will respond to your request within 30 days.