Privacy Notice

Allotex Italia S.p.A., with registered address in via Lorenzo Mascheroni 29, 20145 Milano (MI), Italy, and its subsidiaries and affiliated companies, including Allotex, Inc. (collectively, “Allotex”, “Company”, “We” or “Us”) respects the privacy of customers and visitors accessing Allotex’s websites (www.allotex.com) and Allotex’s social media pages (e.g., LinkedIn; Facebook, Instagram), and resources (the “Website”). Allotex has established this privacy notice (“Privacy Notice”) to inform you, a user of the Website, about how Allotex (acting as data controller) uses any information that may have been collected about you (“personal data”) as you were using this Website.

I. Personal data collected on the Website

The personal data that we may collect about you when you visit our Website includes:

1. Information that you provide voluntarily

We collect personal data that you provide voluntarily when you complete our online forms or survey. The information we collect about you may include some or all of the following:

• Name and surname;
• Contact details, such as your email address, phone number and home address;
• Any information needed to complete our survey (“Survey Information”), including:
  • Age;
  • Health information, including medical prescriptions, information relating to your use of visual aids, visual behavior and personal lifestyle; and
  • Any other personal information that you voluntarily choose to provide to us in the context of the survey.

2. Information that we collect automatically

When you visit our Website, we may collect certain personal data automatically from your device (e.g., your IP address, information about how your device has interacted with our Website, including the pages accessed and links clicked, and other technical information).

This information tells us about your usage of our Website, which helps us to improve our Website and to deliver a better and more personalized service to you. By enabling us to take into account your Website usage patterns and preferences, this information helps us to customize our Website according to your individual interests, to speed up your searches, and to recognize you when you return to our Website.

Some of this information may be collected using cookies and similar tracking technology, as explained further in our Cookie Notice.

II. How we use your personal data

The Company will use and otherwise process your personal data as described in the chart below:

Purpose	Categories of personal data	Legal basis of processing
To send you marketing and communications about our products and services.	Name and surname; Contact details.	Your consent (where required by law) OR Our legitimate interests to promote our products and services.
To assess your compatibility with our products and services.	Name and surname; Contact details; Survey Information.	Your consent.
To share your information with relevant clinics or health care professionals.	Name and surname; Contact details; Survey Information.	Your consent.
To communicate with you following your completion of our survey.	Name and surname; Contact details.	Your consent.
To improve our Website, social media and online media resources.	Survey; Online behavior; Visual behavior information.	Your consent.
To allow market research.	Survey Information.	Your consent.
To identify new patient and customer groups.	Survey Information.	Our legitimate interests.

You are not required to provide us with personal data for processing as described above. If you do not provide us with personal data, we will not be able to offer you our services through this Website.

III. Disclosure of personal data

Allotex takes its responsibility to keep your information private very seriously. Accordingly, we will only share your personal data under limited circumstances. Allotex may share your personal data with the following recipients:

• Authorized third-party vendors and service providers, as necessary in connection with the purposes described above (e.g., IT service providers).
• Corporate affiliates. Allotex may share your information with its corporate affiliates that are subject to this Privacy Policy for the purposes set out above.
• Business partners. Allotex may share your information in connection with a completed or proposed corporate transaction, such as the sale of all or part of the Allotex group of companies, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
• Authorized courts or authorities. Allotex may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, or as otherwise may be required or permitted by applicable law.
• With your consent or at your direction. Allotex may share information with third-party clinics or healthcare professionals where you have consented to it, as described above, or for any other purposes disclosed to you at the time Allotex collects the information or pursuant to your consent or direction.

Some of these third-parties are located outside of the EEA, including in countries that may not provide the same level of data protection as your home country. The Company takes appropriate steps to ensure that such third-parties are bound to duties of confidentiality and the Company implements measures such as standard contractual clauses to ensure that any transferred personal data remains protected and secure. A copy of these clauses can be obtained by contacting us at the address listed below in the “Contact Information” section.

IV. Automated decision making

We use automated decision-making technologies to support our data processing activities. Our automated decision-making capabilities include logic to identify you as a potential candidate for surgical vision correction. By using this logic, it helps us to assure that our products match with your personal needs. For you, this means a higher probability to be a qualified candidate for surgical vision correction.

V. Retention of personal data

The Company will only retain your personal data for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws. In any event, the Company will not keep your personal data for more than the end of the calendar year occurring 2 years anniversary after registration.

VI. Your data protection rights

You are entitled, in accordance with applicable law, to request access to, rectification, erasure and portability of their own personal data, as well as to object to or request restriction of processing of their personal data. Where we process your personal data on the basis of your consent, you may withdraw your consent at any time, without affecting the lawfulness of the processing prior to such withdrawal.

Requests should be submitted in writing to the address listed below in the “Contact Information” section.

You also have the right to lodge a complaint with a supervisory authority if you consider that Company’s processing of their personal data infringes applicable law.

VII. Contact Information

You can raise any issues regarding the processing of their personal data by contacting: [email protected].

In addition, Customers can contact our Data Protection Officer at any time: Michael Mrochen at [email protected].