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California Employee Privacy Policy

Effective Date: October 23, 2023
Luxottica of America, Inc. (“Luxottica,” “we,” “our,” or “us”) respects the privacy of our
employee’s personal information.
Pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights
Act of 2020 (“CCPA”), we are required to provide California employees with a privacy policy
that contains a comprehensive description of our online and offline practices regarding our
collection, use, sale, sharing, andretention of their personal information as well as a description
of the rights they have regarding their personal information. This Privacy Policy provides the
information the CCPA requires as well as other useful information regarding our collection and
use of personal information.
Please review this Privacy Policy carefully. From time to time, we may change this Privacy
Policy. If we do, we will post an amended version on this webpage and on our intranet policy
page. You also may receive a copy by contacting us as described in the “How to Contact Us”
section below.
This Privacy Policy covers the following topics:

  1. Scope of Privacy Policy
  2. Notice at Collection of Personal Information
  3. Disclosure of Personal Information
  4. Retention of Personal Information
  5. Your Rights
  6. How to Submit a Request to Know, Delete, and/or Correct
  7. Our Process for Verifying a Request to Know, Delete, and/or Correct
  8. Other Relevant Policies, Including Monitoring
  9. Accessibility
  10. How to Contact Us
    2
  11. Scope of Privacy Policy
    When This Policy Applies
    This Privacy Policy is intended solely for, and is applicable only to, current and former
    California employees. Where relevant, it also applies to job applicants, interns, agency workers,
    contractors, consultants, directors, and other individuals whose information we collect in
    connection with providing employment. For ease of reference, this Privacy Policy generally
    refers to employee data, but this does not indicate in any way that an individual is our employee.
    When This Policy Does Not Apply
    This Privacy Policy does not apply to individuals who are not California residents.
    This Privacy Policy also does not apply to our collection and use of your personalinformation in
    a consumer or business-to-business capacity. For more information on our collection and use of
    your personal information in that capacity, includinghow we process opt-out preference signals,
    please see our online privacy policy available on our individual brand website s.
  12. Notice at Collection of Personal Information
    Personal Information We Collect
    The CCPA defines “personal information” to mean information that identifies, relates to,
    describes, is reasonably capable of being associatedwith, or could reasonably be linked, directly
    or indirectly, with a particular California resident or household. Personal information does not
    include publicly available, deidentified, or aggregated information or lawfully obtained, truthful
    information that is a matter of public concern. For purposes of this Privacy Policy, we will refer
    to this information as “Personal Information.”
    We currently collect and, in the 12 months prior to the Effective Date of this Privacy Policy,
    have collected the following categories of Personal Information from employees:
  • Identifiers (name, alias, dateof birth,account name, personal email address, postal
    address, Social Security number, driver’s license number, other types of state
    identification card numbers suchas California ID Cards, passport number, Internet
    Protocol address, online identifiers, other similar identifiers);
  • Unique personal identifiers (cookies, beacons, pixel tags, mobile ad identifiers, or other
    similar technology; employee number, work email address, unique pseudonym, or user
    alias; telephone numbers or other forms of persistent or probabilistic identifiers that can
    be used to identify a particular employee or device);
  • Signature;
  • Telephone numbers;
  • Physical characteristics or description;
  • Bank account number;
  • Debit and corporate card number;
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  • Account log-in, financial account, debit card, or credit card number for corporate account
    in combination with any required security or access code, password, or credentials
    allowing access to an account;
  • Other financial information including wage garnishment, child support and other
    creditors; stock purchase eligibility; retirement selections; unemployment benefits; short
    and long-term disability benefit selection;
  • Internet or other electronic network activity information (browsing history; search
    history; and information regarding an individual’s interaction with a website, application
    or advertisement);
  • Medical/health information; dependent information (including domestic partner);
  • Insurance policy number or subscriber identification number;
  • Any unique identifier used by health insurer to identify employee;
  • Any information in an individual’s application and claims history, including appeals
    records, if informationis linked or reasonably linkable to an individual or household,
    including via device, by business or service provider;
  • California meal waivers;
  • Education information;
  • Professional or employment-related information (including employment history)
  • Biometric information (imageryof iris; imagery of retina; fingerprint; imagery of face;
    imagery of hand; imagery of palm; vein patterns; voice recordings from which an
    identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be
    extracted; keystrokepatterns or rhythms; gait patterns or rhythms; and sleep, health, or
    exercise data that contain identifying information);
  • Characteristics of protected classifications under California or federal law (race; color;
    sex/gender (including pregnancy, childbirth, breastfeeding and/or related medical
    conditions); sexual orientation or sex life; gender identity/expression; age (40 and older);
    religion (including religious dress and grooming practices); national or ethnic origin;
    ancestry; union membership; disability (mental and physical, including HIV/AIDS,
    cancer, and genetic characteristics); citizenship or immigration status; genetic
    information; marital status; medical condition (genetic characteristics, cancer or a record
    or history of cancer); military or veteran status; political affiliations or activities; status as
    a victim of domestic violence, assault, or stalking; requests for family care leave, for
    leave for an employee’s own serious health condition, or for pregnancy disability leave;
    and retaliation for reporting patient abuse in tax-supported institutions);
  • Video information (CCTV video footage);
  • Contents of an employee’s mail, email, and text messages unless we are the intended
    recipient of the communication;
  • Inferencesdrawn from above information to create a profile about an employee reflecting
    their preferences, characteristics, psychological trends, predispositions, behavior,
    attitudes, intelligence, abilities, and aptitudes;
    Sources of Personal Information
    We collect Personal Information directly from California residents and from recruiters; staffing
    companies; references; former employers; educational institutions; online providers (such as
    through LinkedIn and similar providers); government entities; other employees; business
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    partners; payroll providers; benefits providers; medical providers; background checks; company
    bankers; claims handlers; authentication and single sign-on providers; advertising networks;
    internet service providers; data analytics providers; operating systems, platforms, or software;
    social networks; and data brokers. We do not collect all categories of Personal Information from
    each source.
    Purposes for Collection
    We currently collect and have collected the above categories of Personal Information for all
    purposes of providing employment, including to:
  • Process payroll;
  • Enable recruiting services;
  • Request you complete applications and forms associated with your employment or
    prospective employment;
  • Consider you for potential employment;
  • Perform background checks and drug testing;
  • Verify your ability to work in this country;
  • Identify you as a veteran;
  • Process security clearances;
  • Investigate and report, as required under applicable law, security incidents and data
    breaches;
  • Perform diversity and inclusion initiatives, including data analysis, development, and
    deployment;
  • Perform company, client and regulator audits;
  • Facilitate access to company systems, applications and assets;
  • Request you acknowledge your agreement to certain company policies;
  • Administer our wellness program;
  • Administer and maintain benefits, including group health insurance, retirement accounts,
    employee compensation, and employee leave;
  • Contact individuals for emergency purposes;
  • Track time and attendance at work;
  • Manage workers’ compensation claims;
  • Manage your job-related performance;
  • Arrange business travel;
  • Investigate and handle disciplinary actions or termination;
  • Establish training and/or development requirements;
  • Detect lost/stolen equipment, fraud, or other types of wrongdoing;
  • Grant and monitor your access to secure company facilities and files;
  • Engage in corporate transactions requiringreview of employee records and information,
    such as for evaluating potential mergers and acquisitions;
  • Review web traffic and events, monitor for virus attacks and web content, and determine
    bandwidth consumption;
  • Maintain commercial insurance policies and coverages, including for workers’
    compensation and other liability insurance;
  • Maintain commercial licenses for enterprise applications and platforms;
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  • Prevent the spread of illness and administer programs duringa pandemic (e.g., COVID19);
  • Perform call monitoring and surveillance (e.g., CCTV);
  • Comply with federal and state law;
  • Enforce our legal rights; and
  • Engage in other legitimate business purposesreasonably required for our day-to-day
    operations such as accounting, financial reporting, and business planning.
    We also use your PersonalInformation for the purposes described in our Acceptable Use Policy,
    Workplace Monitoring Policy, Employee Handbook, etc.
  1. Disclosure of Personal Information
    The following table identifies the categories of Personal Information that we disclosed for a
    business purpose in the 12 months precedingthe Effective Date of this Privacy Policy and, for
    each category, categories of recipients to whom we disclosed Personal Information.
    Categories of Personal Information Categories of Recipients
    Personal identifiers (name; alias; date of
    birth; account name; personal email
    address; postal address; Social Security
    number; driver’s license number; other
    types of state identification card numbers;
    passport number; Internet Protocol
    address; online identifiers; cookies,
    beacons, pixel tags, mobile ad identifiers,
    or other similar technology; employee
    number, work email address, unique
    pseudonym, or user alias; telephone
    numbers or other forms of persistent or
    probabilistic identifiersthat can be used to
    identify a particular employee or device;
    signature; physical characteristics or
    description; bank account number; debit
    and corporate card number; account login, financial account, debit card, or credit
    card number for corporate account in
    combination with any required security or
    access code, password, or credentials
    allowing access to an account; wage
    garnishment (child support, other
    creditors); stock purchase eligibility;
    retirement selections; unemployment
    benefits; short and long-term disability
    selections; browsing history; search
    history; information regarding an
    Human resource information systems; operating
    systems and platforms; customer relationship
    management systems; background check service
    providers; government or law enforcement
    entities; applicant and recruiter software;
    payroll/tax providers; expense management
    service providers; enterprise travel providers; data
    analytics providers; company bankers;
    authentication and single sign-on providers;
    security providers; mobile device management
    providers; accountants; lawyers; benefits
    providers; social networks; clients; auditors;
    vendors, regulators; company insurers;
    consultants and other professional advisors
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    individual’s interaction with a website,
    application or advertisement)
    Medical and insurance information
    (medical/health information; insurance
    policy number or subscriber identification
    number; any unique identifier used by
    health insurer to identify employee; any
    information in an individual’s application
    and claims history, including appeals
    records, if information is linked or
    reasonably linkable to an individual or
    household, including via device, by
    business or service provider, dependent
    information (including domestic partner,
    California meal waivers)
    Benefits providers; company insurers; payroll/tax
    providers
    Education, employment history, and
    related information
    Applicant and recruiter software; background
    check service providers; benefits providers;
    lawyers
    Characteristics of protected classifications
    under California or federal law (race;
    color; sex/gender (including pregnancy,
    childbirth, breastfeeding and/or related
    medical conditions); sexual orientation or
    sex life; gender identity/expression; age;
    religion (including religious dress and
    grooming practices); national or ethnic
    origin; ancestry; union membership;
    disability (mental and physical, including
    HIV/AIDS, cancer, and genetic
    characteristics); citizenship or
    immigration status; genetic information;
    marital status; medical condition (genetic
    characteristics, cancer or a record or
    history of cancer); military or veteran
    status; political affiliations or activities;
    status as a victim of domestic violence,
    assault, or stalking; requests for family
    care leave, for leave for an employee’s
    own serious health condition, or for
    pregnancy disability leave; retaliation for
    reporting patient abuse in tax-supported
    institutions)
    Applicant and recruiter software; human resource
    information systems; benefits providers; company
    insurers; background check service providers;
    lawyers
    7
    We disclosed Personal Information to the above categories of recipients for the following
    business or commercial purposes:
  • Process payroll;
  • Enable recruiting services;
  • Request you complete applications and forms associated with your employment or
    prospective employment;
  • Consider you for potential employment;
  • Perform background checks and drug testing;
  • Verify your ability to work in this country;
  • Identify you as a veteran;
  • Process security clearances;
  • Investigate and report security incidents and data breaches;
  • Perform diversity and inclusion initiatives, includingdata analysis, development, and
    deployment;
  • Perform company, client and regulator audits;
  • Facilitate access to company systems, applications and assets;
  • Request you acknowledge your agreement to certain company policies;
  • Administer our wellness program;
  • Administer and maintain benefits, including group health insurance, retirement accounts,
    employee compensation, and employee leave;
  • Contact individuals for emergency purposes;
  • Track time and attendance at work;
  • Manage workers’ compensation claims;
  • Manage your job-related performance;
  • Arrange business travel;
  • Investigate and handle disciplinary actions or termination;
  • Establish training and/or development requirements;
  • Detect lost/stolen equipment, fraud, or other types of wrongdoing;
  • Grant and monitor your access to secure company facilities and files;
  • Engage in corporate transactions requiringreview of employee records and information,
    such as for evaluating potential mergers and acquisitions;
  • Review web traffic andevents, monitor for virus attacks and web content, and determine
    bandwidth consumption;
  • Maintain commercial insurance policies and coverages, includingf or workers’
    compensation and other liability insurance;
  • Maintain commercial licenses for enterprise applications and platforms;
  • Prevent the spread of illness and administer programs duringa pandemic (e.g., COVID19);
  • Perform call monitoring and surveillance (e.g., CCTV);
  • Comply with federal and state law;
  • Enforce our legal rights; and
  • Engage in other legitimate business purposesreasonably required for our day-to-day
    operations such as accounting, financial reporting, and business planning.
    8
    We have not sold or shared Personal Information in the twelve (12) months preceding the
    Effective Date of this Privacy Policy.
    We do not knowingly collect, sell, or share the Personal Information of individuals under 16
    years of age. We do not use Sensitive PersonalInformation for purposes other thanthose allowed
    by the CCPA and its regulations.
  1. Retention of Personal Information
    We retain your Personal Informationfor as longas necessary to fulfill the purposes for which we
    collectit, such asto provide you with services you haverequested, and forthe purposeof satisfying
    any legal, accounting, contractual, or reportingrequirements that apply to us. Please contact us as
    described in the “How to Contact Us” section below for more informationon our employee data
    retention schedule.
  2. Your Rights
    If you are a California employee, you have the following rights with respect to your Personal
    Information:
    (1) The right to know whatPersonalInformation we have collected about you, including the
    categories of Personal Information, the categories of sources from which we collected
    Personal Information, the business or commercial purpose for collecting, selling, or
    sharing Personal Information (if applicable), the categories of third parties to whom we
    disclose Personal Information (if applicable), and the specific pieces of Personal
    Information we collected about you;
    (2) The right to delete Personal Informationthat we collected from you,subject to certain
    exceptions;
    (3) The right to correct inaccurate Personal Information that we maintain about you;
    (4) If we sell or share Personal Information, the right to opt-out of the sale or sharing;
    (5) If we use or disclose sensitive PersonalInformation for purposes other than those allowed
    by the CCPA and its regulations, the right to limit our use or disclosure; and
    (6) The right not to receive discriminatory treatment by us for the exercise of privacy rights
    conferred by the CCPA.
  3. How to Submit a Request to Know, Delete, and/or Correct
    You may submit a request to know, delete, and/or correct through our interactive webform
    available here or by emailing us at privacyoffice@luxotticaretail.com or via U.S. mail:
    Privacy Office
    Luxottica of America, Inc.
    4000 Luxottica Place
    9
    Mason, Ohio 45040
    If you are submitting a request on behalf of a California employee, please submit the request
    through one of the designated methods discussed above. After submitting the request, we will
    require additional information to verify your authority to act on behalf of the California
    employee.
    In addition to the CCPA rights discussed above, California law provides current and former
    employees with the right to request certain information relatingto their employment, such as the
    right to access their personnel file and payroll records. Because these requests are governed by
    laws that contain differentrequirements than the CCPA, we handle such requests separately from
    CCPA requests. If you would like to make such a request, please
    privacyoffice@luxotticaretail.com.
    If you would like to update your personalinformation, suchas to notifyus of a change of name
    or address, or if you have questions about your employment, please contact Human Resources.
  4. Our Process for Verifying a Request to Know, Delete, and/or Correct
    We will comply with your request upon verification of your identity and, to the extent
    applicable, the identity of the California employee on whose behalf you are makingsuch request.
    In certain circumstances, we may need to verify your identity either to a “reasonable degree of
    certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal
    Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as
    applicable.
    For requests to access categories of Personal Information and for requests to delete or correct
    Personal Information that is not sensitive and does not pose a risk of harm by unauthorized
    deletion or correction, we will verify your identity to a “reasonable degree of certainty” by
    verifying at least two data points that you previously provided to us and which we have
    determined to be reliable for the purpose of verifying identities.
    For requests to access specific pieces of Personal Information or for requests to delete or correct
    Personal Information that is sensitive and poses a risk of harm by unauthorized deletion or
    correction, we will verify your identity to a “reasonably high degree of certainty” by verifying at
    least three pieces of Personal Information previously provided to us and which we have
    determined to be reliable for the purpose of verifyingidentities. In addition, you will be required
    to submit a signed declaration under penalty of perjury stating that you are the individual whose
    Personal Information is being requested.
  5. Other Relevant Policies, Including Monitoring
    When we hire you, we provide you with other policies and procedures that govern your use of
    our offices, networks, computers, and other devices. We have the right to monitor your use of
    our offices and electronic resources in accordance with those policies and procedures.
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    For more information, please read the Employee Handbook, and policy addressing “
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