Privacy Notice
Last updated September 20, 2022
Respecting your Right to Privacy and Retaining your Trust is Important to Alcon
Alcon is committed to be a trusted steward of your personal information (please see the “personal information” section below for an explanation of what is considered your personal information). We collect and use this personal information to meet your expectations when you engage with us and continue to improve our business as the global leader in eye care, dedicated to helping people see brilliantly. Today, we rely on personal information to incorporate state-of-the-art technology into our products and services, improve quality and safety, and align with the interests of healthcare community, our consumers, and other stakeholders.
Our Commitment to You:
We are committed to being transparent about our management of your personal information and we take all reasonable steps to ensure our practices, procedures and activities comply with any applicable requirements, including all applicable privacy laws, and with this Privacy Notice.
What this Privacy Notice Covers
This Privacy Notice describes how Alcon Vision LLC and its affiliates (collectively, “Alcon”) use and disclose the personal information collected through our websites, social media forums, applications (including mobile applications), and other online services that link to, incorporate, or for which you are provided a copy of this Privacy Notice (collectively, the “Sites”), and the rights you may have about how we use your personal information.
Table of Contents
Click on one of the links below to directly access a section:
What Personal Information Do We Collect and How do We Use It?
Who Is the Controller of Your Personal Information?
When and to Whom Do We Disclose Your Personal Information?
For How Long Do We Keep Your Personal Information?
When and How Do We Transfer Your Personal Information Between Countries?
How Do We Protect Your Personal Information?
Children's Personal information
Changes to This Privacy Notice
Contact details of Alcon as Controller and of our Data Protection Officer
Personal information is any information relating to an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
What Personal Information Do We Collect and How do We Use It?
Purpose and Categories of Personal Information | Legal Basis | Our Legitimate Interests |
We collect and use your personal information for various purposes, as described below: | The lawful grounds on which we may collect, process, and/or disclose your personal information. | What is the important benefit or requirement to process personal information? |
Responding to Requests or Inquiries. Depending on your request, we may collect your contact personal information (such as your name, mailing address, telephone number, job title), your interests and preferences (such as products or areas of interest), and any other personal information you voluntarily provide to us. | We collect and process your personal information for these purposes based on a legitimate interest to respond to your request. If you submitted any sensitive personal information as part of your inquiry, we will also base such processing of that sensitive personal information on your explicit consent. If reporting is required, we may process your personal information to comply with our legal obligations. |
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Completing Transactions. | We use your personal information to perform our obligations under our agreement with you or to fulfill services you have requested. |
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Personalizing Your Experience. This may include personal information about your contact and product preferences, languages, marketing preferences, and demographic data. | We will seek your consent if you reside in a country that requires consent for collection of personal information for this purpose. |
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Cookies, Website Analytics and Tracking. | We will seek your consent if you reside in a country that requires consent for collection of personal information for this purpose. |
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Tracking and Monitoring Adverse Events and Pharmacovigilance. | We collect and process your personal information for these purposes to comply with our legal obligations including in certain cases being required to report the gathered information to regulatory authorities. |
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To Run and Maintain our Sites. | We collect this personal information automatically, for our legitimate business interests to run, maintain, and secure our Sites. | Ensuring our Sites are secure and functionproperly. |
Contacting You and Conducting Advertising on Third-Party Social Networks: We use your personal information when you interact with third-party social networking features, such as “Like” functions, to serve you with advertisements and engage with you on third-party social networks. You can learn more about how these features work, the profile information that we obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third-party social networks. | In cases where we collect this personal information automatically, we collect and process this personal information for our legitimate business interests. In other cases, we will collect and process this personal information pursuant to your consent. |
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Legal Reasons or Merger/Acquisition. We will use your personal information to comply with our legal obligations (e.g., tax law and product safety obligations). This includes personal information such as full name and title, postal address, email address, financial personal information, bank account number, name of your authorized representative (if any). We will disclose your personal information to third-parties (a) when required by applicable laws, 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. Further, if Alcon or its assets are acquired by, or merged with, another company including through bankruptcy, we will share your personal information with any of our legal successors. | We collect and process your personal information for these purposes to comply with our legal obligations. In other instances, we collect and process this personal information for our legitimate business interests. |
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Who Is the Controller of Your Personal Information?
a) Identity of the Controller
Alcon is responsible for the processing of your personal information as it decides why and how it is processed, thereby acting as the “Controller”.
For Alcon organizations or affiliates located outside of the EU, Alcon has elected Alcon Laboratories BVBA as its legal representative in the EU.
For Alcon organizations or affiliates located outside of the UK, Alcon has elected Alcon Eye Care UK Limited as its legal representative in the UK.
For all other Alcon organizations or affiliates globally (outside of the EU and UK), Alcon’s relevant local entity is the legal representative.
b) Contact details of the Controller and its Data Protection Officer
If you have any questions about our Privacy Notice or want to contact our Data Protection Officer, please contact us via email at [email protected] or by using our Data Subject Request form available here: https://privacyportal-ch.onetrust.com/webform/2eb916c9-1b88-4c4a-b85d-495cf9e48d32/f5345017-e0ca-4d14-b779-70fc65e13c9c.
When and to Whom Do We Disclose Your Personal Information?
The personal information we collect from and about you may be disclosed to third parties for the purposes described in this Privacy Notice:
- to the subsidiaries and affiliates within the Alcon group of companies,
- to third-parties that provide services to us, such as those that fulfill requests for personal information, answer calls, administer programs or projects, assist in research and development, deliver advertisements or other communications or host databases or servers,
- 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,
- by you, on message boards, chat, profile pages, blogs, and other services to which you post personal information and materials. Because any personal information you post may become public, we urge you to be careful when deciding to disclose any personal information on or through the Services,
- 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).
For How Long Do We Keep Your Personal Information?
Unless indicated otherwise in this Privacy Notice, the criteria we use to decide how long we retain personal information include: (i) whether we need your personal information to perform a contract to which you are subject, to respond to your questions or provide to you with the required service or support, (ii) whether there is a legal obligation to which we are subject, or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).
We delete personal information when it is no longer necessary to retain it for the purposes described in this Privacy Notice, or when required to do so by applicable law.
When and How Do We Transfer Your Personal Information Between Countries?
Due to the global nature of our business, your personal information may be transferred to or accessed by Alcon subsidiaries or affiliates or Alcon’s third-parties around the world. Of course, when we do so, we comply with applicable laws on the transfer of personal information between countries.
For example, when we transfer personal information from the European Economic Area (EEA), the United Kingdom (UK), and Switzerland to Alcon-affiliated companies in other countries or Alcon third-parties in other countries which may have different standards of data protection to the EEA, UK and Switzerland, such transfers are governed by Standard Contractual Clauses, where appropriate, or other legally recognized measures that adequately protect the personal information.
You may have the following rights in relation to your personal information, in accordance with the applicable data protection laws:
- To withdraw your consent at any time, if we are processing your personal information on the basis of consent,
- To access and/or update the personal information that Alcon holds about you,
- To request that Alcon rectify or erase your personal information,
- To request that Alcon restrict the way it processes your personal information,
- To object to the way Alcon processes your personal information,
- Where you request us to do so, to transfer your personal information either back to you or to another individual or entity, and
- The right to express your point of view in the event of any individual decision having a significant impact on you being made by automated means about you and to request that such automated decision be reviewed by a human.
If you wish to exercise one of these rights, please complete our “Data Subject Request Form” at https://privacyportal-ch.onetrust.com/webform/2eb916c9-1b88-4c4a-b85d-495cf9e48d32/f5345017-e0ca-4d14-b779-70fc65e13c9c or email us at [email protected]. You also have the right to lodge a complaint with a data protection authority in your country of residence (all EU/EEA Data Protection Authorities’ contact details may be found here).
We will require appropriate evidence of your identity or to be provided with additional relevant personal information based on your relationship with us before we are able to act on your request in circumstances where the personal information we have in our systems is insufficient detail to identify you or reply to your request.
If you would like, you can enable someone else to exercise your rights under this Privacy Notice on your behalf. We would call this person your Personal Representative. If your Personal Representative sends us a request to exercise your rights under this Privacy Notice, we may ask them to provide evidence that you gave them permission to make the request on your behalf. In that scenario, we may also seek to verify your identity directly and/or ask you to confirm the Personal Representative’s ability to act on your behalf.
How Do We Protect Your Personal Information?
We have appropriate technical and organizational measures designed to provide an adequate level of security and confidentiality for your personal information.
These measures take into account:
(i) State of the art technology, (ii) The costs of implementation of such technical and organizational measures, (iii) the nature of the personal information, and (iv) the risks involved in the processing of that personal information.
The purpose of these measures is to protect your personal information against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing.
Moreover, when handling your personal information, we:
(i) Only collect and process personal information which is adequate, relevant and not excessive, as required to meet the above purposes, and
(ii) Ensure that your personal information remains up to date and accurate.
For the latter, we may request you to confirm the details of the personal information we retain about you. You are also invited to inform us whenever there is a change in your personal circumstances so we can ensure your personal information is kept up-to-date.
Children's Personal information
We are committed to protecting the privacy of children and that is why we do not knowingly collect personal information from children under the age of 18 , unless permitted to do so by applicable law. If we learn that we have collected personal information directly from children through our Sites without being permitted to do so by applicable law, we will delete this information.
This Privacy Notice applies only to the Sites that display or refer to this Privacy Notice. The Sites may contain links to third-party websites that are not under our control. We are not responsible for the collection, use, or disclosure of your personal information by such websites. We encourage you to review the privacy policies of all third-party websites to learn about how those third parties collect, use, and disclose your personal information.
Changes to This Privacy Notice
We may update this Privacy Notice from time to time by posting a new Privacy Notice on our Sites. When we update this Privacy Notice, we will indicate when it was most recently updated by changing the “last updated” date. Unless otherwise indicated, updates to this Privacy Notice are effective immediately upon posting. If we make a material change to our Privacy Notice, we may take reasonable steps to notify you, for example, by posting a banner or pop-up notice on our Sites.
Contact details of Alcon as Controller and of our Data Protection Officer
If you have any questions about our Privacy Notice or want to contact our Data Protection Officer, please contact us via email at [email protected] or by using our Data Subject Request form available here: https://privacyportal-ch.onetrust.com/webform/2eb916c9-1b88-4c4a-b85d-495cf9e48d32/f5345017-e0ca-4d14-b779-70fc65e13c9c
