Privacy Policy

This privacy notice is to let you know how we manage your personal information at Imperial Optical Jamaica Limited. We collect your personal data when you establish and maintain a relationship with us. This notice also tells you about your privacy rights and how the law protects you.

 

OUR AGREEMENT WITH YOU

As a customer, you agree to us collecting, using and appropriately disclosing your personal information in accordance with our contract with you. We may change our products and services at any time without notice, and consequently, our Privacy Notice may be updated at any time in the future. Continued use of our products and services implies ongoing acknowledgement and consent to same.

 

OUR PRIVACY PROMISE TO YOU

We will:

1. Secure and protect your personal information;
2. Not disclose your personal information outside of Imperial Optical Jamaica Limited without your consent unless we need to do so to fulfill our obligations to you;
3. Where possible and practical, enable you to express your preferences so that you can manage how we use your personal information.

 

WHO WE ARE

Imperial Optical Jamaica has proudly served customers for over 90 years, operating branches throughout the island, including Kingston, Spanish Town, May Pen, Mandeville, and Montego Bay. We are committed to providing world-class ophthalmology, optometry, and optician services and products, ensuring complete customer satisfaction.

The Data Protection Act of Jamaica (DPA) is applicable to Imperial Optical and our related companies that operate in Jamaica. Where the DPA does not provide sufficient guidance, we will be guided by the principles and requirements of the General Data Protection Regulation of the UK/EU (GDPR), adjusted, if necessary, to the local environment. The GDPR is recognised as the de-facto international standard of data protection. Where necessary, we will also be guided by the principles and requirements of the data protection legislation and by any other relevant legislation in other legislative jurisdictions within which Imperial Optical operates.

 

WHAT INFORMATION DO WE COLLECT?

We gather various types of information that may identify you as an individual (“personal information”). The information collected depends on the service you request.

 

Customers or Prospective Customers

We collect your information in the following circumstances:

• When you request information about our products and services;
• When you access our products and services;
• When you talk to us on the phone or in a branch, including recorded calls and notes we make;
• When you use our websites, web chats and mobile device apps;
• When you send emails and letters;
• When you submit documents;
• When you participate in customer surveys;
• When you take part in our competitions or promotions.

We may also collect data when you use our services. This data collection covers several areas:

1. Details about what services are provided to you.
2. Information about how and where you access our services.
3. Activity that results from your business with us, including:

• Services, Payments and Transactions: This includes the amount, frequency, type, location, origin. If you receive payment credit, it also includes details of repayment and whether they are made on time and in full.
• Profile and Usage of Information: This includes any security details you create and use to connect to our services. It also includes your settings and marketing choices. Additionally, we gather statistical data about your browsing actions and patterns, from the devices you use (such as computers and mobile phones) to connect to any internet, mobile and telephone services we may provide. We may collect information about your computer including, where available, your IP address, operating system and browser type, for system administration and to report aggregate information (not your personal information) to our advertisers.

 

Employees or Contractors

We collect the personal data required to fulfill our contractual, legal and administrative obligations as an employer. 

 

HOW DO WE USE YOUR PERSONAL INFORMATION

Customers or Prospective Customers

We may use the information we collect from our customers in connection with the services we provide for a range of reasons, including to:

• provide, operate and maintain the services;
• manage our customers’ use of the services, respond to enquiries and comments, and provide customer service and support;
• send customers technical alerts, updates, security notifications, and administrative communications; verify the identity of customers;
• investigate and prevent fraudulent activities, unauthorized access to the services, and other illegal activities; and
• perform any other functions about which we notify customers.

 

Below we detail the main ways in which Imperial Optical may use your personal information and the reasons for collecting your information.

What we collect your data for	How we use your data that we collect	Our reasons for collecting your data
Establishing and maintaining a relationship	To provide our Products and/or Services/ Update customer personal data. Update contractual agreement terms and conditions. Offers related to our existing contract with you	Keeping our records up to date, working out which of our products and services may interest you and telling you about them Seeking your consent when we need it to contact you
Marketing and Product Development	To test new products. To manage how we work with other companies that provide services to us and our customers. To develop new ways to meet our customers’ needs. To communicate to you, information related to our products and services.	Defining types of customers for new products or services Developing products and services, and what we charge for them Being efficient about how we fulfill our legal and contractual duties
Transaction Processing/ Business Operations	To execute business in accordance with industry best practice. To deliver our products and services. To facilitate and manage customer transactions.	Being efficient about how we fulfill our legal and contractual duties Complying with rules and guidance from regulators

 

Employees or Contractors

We use the personal data of employees or contractors for the purposes of payroll, employee benefits, statutory reporting, and other legal or administrative purposes necessary as a responsible employer.

 

WHAT IS OUR LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA 

In accordance with the law, our internal procedures for processing (collecting, storing and securing) your personal information are governed by controls, which ensure the protection and security of your personal information. The law allows us to use personal information based on lawful bases for legitimate purposes. The following are the lawful bases upon which we process data:

• Processing is necessary for fulfilment and performance of a contract to which you are a party. We process your personal information to open accounts, maintain account details, perform administrative tasks and provide services.
• Processing is necessary for compliance with a legal obligation or duty. When you access a product or service, we are required by law to collect and process certain personal information about you. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to provide services to you.
• Processing is necessary for the purposes of our legitimate interests or that of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms. Our use of your personal information may also be based on our legitimate interest to ensure network and information security if you use any of our systems’ and make available reports (risk, financial, accounting, etc.) to internal management and supervisory bodies.

 

WHAT IS OUR LAWFUL BASIS FOR PROCESSING YOUR SENSITIVE PERSONAL DATA?

• Processing the sensitive personal data of our customers is necessary for providing the services they request (contract) and for health purposes.
• Our use of the sensitive personal data of our employees is based on our legitimate interest to identify our employees, ensure the security of our facilities, make available reports to internal management, and the consent of our employees.

 

WHEN DO WE SHARE PERSONAL DATA

We do not rent or sell your personal information to anyone. We may share your information, including how we manage

your account or visits to our website, with other companies and/or with relevant third parties to support the services we provide, and as permitted by law, including, but not limited to the following:

1. People who provide a service to us or act as our agents, on the understanding that they will keep your information strictly confidential and, otherwise, process it in accordance with data protection rules.
2. Related companies from which our customers may seamlessly receive the same services that we provide, should theychoose to do so at their convenience.
3. Anyone to whom we transfer or may transfer all or any part of our business or assets; from whom we acquire any business or assets; or who acquires substantially all of the assets of Imperial Optical.
4. We may also provide information about you if we have a duty to do so to comply with any legal obligation, or to enforce or apply our terms of use, or if the law allows us so to do.

 

If Imperial Optical receives your personal information and subsequently transfers that information to a third-party agent or service provider for processing, Imperial Optical remains committed to ensuring that such third-party agent or service provider processes your personal information to the standard required to comply with the DPA and/or other applicable privacy laws.

 

INTERNATIONAL DATA TRANSFERS

We will only send your data outside of Jamaica or outside of any other geographic area within which we operate in the following circumstances:

1. to follow your instructions,
2. to comply with a legal duty or
3. to work with our service providers who help us to provide you with services.

 

These countries may not have similar data protection laws to those in your country of residence. However, we will always protect your information on the basis that anyone to whom we pass the information protects it in the same way we would, and in accordance with this privacy notice and applicable laws.

 

FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA

Retention periods for our records are determined based on the type of record, the nature of the activity, product or service, and the applicable legal or regulatory requirements. We normally keep customer account records for at least seven years after your relationship with Imperial Optical ends, then the information is securely destroyed. We determine any additional retention period beyond seven years based on our experience and estimates of how long we may need the data (e.g. for legal proceedings or to access important historical information).

We may maintain CCTV facilities in various locations. CCTV recordings are kept until the storage is full and then they are overwritten. We have some cameras that take constant images and some that are activated by motion, consequently causing our retention policy to vary by premises. Our retention policy for CCTV footage varies between 14-90 days depending on the location and nature of recording. We will supply footage if we have it and if it is needed for a legally valid purpose. However, we do not commit to supplying any footage beyond 14 days after the CCTV recording.

Job applicant’s data is kept only for the duration of the application process, and then it is destroyed if the applicant is unsuccessful. Any exceptions are with the consent of the job applicant.

We may also keep your data for longer than seven years if we cannot delete it for legal, regulatory or technical reasons, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. For example, we may have to hold pension information indefinitely (i.e. as important historical information).

 

YOUR RIGHTS IN RELATION TO PERSONAL DATA

(Note: These rights are not absolute and are subject to the laws of Jamaica or any other legislative environment in which we may operate) 

Your Rights	Meaning
The right to access your personal data.	You have the right to be informed whether, and to what extent, we process your data. Subject to certain exceptions, you have the right to obtain a confirmation as to whether we process your personal data, and if we do, request access to your data.
The right to consent to processing	You have the right to consent to the processing of your personal data. If your personal data is processed on basis of your consent, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal
The right to prevent processing	You have the right to object to the processing of your personal data in certain situations.
Rights in relation to automated decision making	You have the right to object to decisions based exclusively on the automated processing of your personal data.
The right to rectification	If the personal data that we process is incomplete or incorrect, you have the right to request, at any time, their completion or correction.

 

HOW MAY I EXERCISE MY DATA SUBJECT RIGHTS?

If you would like to access, review, update, rectify, and delete any personal information we hold about you, or exercise any other data subject right available to you under the DPA, or any other applicable data protection law, you may obtain contact information from the “How to Contact Us” section of this privacy notice. We will examine your request and respond to you as quickly as possible and in accordance with the relevant law. You may be required to submit your request using a specific form prescribed by the DPA or related regulations.

Please note that we may still use any aggregated and anonymised personal information. Such information does not identify any individual and so is not personal data. We may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

USE OF AUTOMATED DECISION-MAKING AND PROFILING

We may use systems to make automated decisions about you or your business. This would help us to make sure our decisions are quick, fair, efficient and correct based on what we know. Automated decisions can affect the products, services or features we may offer you now or in the future. They are based on personal information that we have or that we are allowed to collect from others. Here are the types of automated decision we may make:

 

Pricing

We may decide what products and services to offer and the price of those products and services based on our understanding of the available information.

 

Tailoring Products, Services, Offers and Marketing

We may place you in groups with similar customers. These are called customer segments. We may use these to study and learn about our customers’ needs and behaviours, and to make decisions based on what we learn. This would help us to design products, services and offers for different customer segments, and to manage our relationships with them. It would also help us tailor the information that individuals receive or see on our own and other websites and mobile apps, including social media.

 

Establishing Customer Relationships

When you establish a customer relationship with us, we check that the product or service is relevant to you, based on what we know.

 

HOW TO CONTACT US

We are committed to the protection of your privacy rights and of your personal information. If you have any questions or require more details about how we use your personal information, please see below:

 

Customer Relations Officer

16 West Kings House Road, Kingston 10, Jamaica W.I.

876-754-0051-5 info@imperialja.com

 

You may also contact our Data Protection Officer:

16 West Kings House Road, Kingston 10, Jamaica W.I.

876-754-0051-5

dpa@imperialja.com

 

You also have the right to make a complaint to the Office of The Information Commissioners (OIC). Details of this may be found on their website.

 

Changes to this privacy statement occur from time to time as the business develops and grows and adds more processing. You are encouraged to check back regularly to see any changes that may have occurred.

 

USE OF COOKIES AND OTHER TECHNOLOGIES

We use cookies and other internet tracking software to collect data while you are using our websites or mobile apps. Cookies allow us to store information about the computer device you use to access our website so that you can conduct business with us easily. They allow us to recognise when you revisit our websites and to evaluate our websites’ advertising and promotional effectiveness. We use both our own (first party) and partner companies’ (third party) cookies to support this activity.

 

We do not use Cookies to:

• track your internet usage after leaving the website
• store personal information others may read and understand.

 

Processing of personal data associated with the use of these cookies occurs based on our legitimate Interests to administer the website.

Our cookies are listed below.

Cookie Name	Retention Time	Description
_ga	2 years	Used to distinguish users.
_ga_XPD1Z55NZG	2 years	Used to persist session state.

You can deactivate the non-technical cookies by not consenting to non-essential cookies when you first visit the site. When you first visit the site, it gives you an opportunity to opt-in or opt-out of cookies.

 

You may also set your browser’s setting to deactivate cookies. If you use that option, some functions of this website (e.g. login, memory of preferences, etc.) may not be available. Detailed guidance on how to control cookies preferences for the most common browsers can be found at:

• Google Chrome
• Mozilla Firefox
• MacOS Safari
• Microsoft Edge
• For other browsers please see org

 

You also have the option to install the Google Analytics opt-out browser add-on and thereby deactivate the use of Google analytics cookies and the associated data processing. You can find the Opt-out browser add-on here.

https://tools.google.com/dlpage/gaoptout You can find the Google privacy notice here.

Google Analytics privacy notice.

 

LINKING TO OTHER WEBSITES / THIRD PARTY CONTENT

For your convenience, hyperlinks may be posted on our websites that link to other websites. We are not responsible for these sites, and this privacy notice does not apply to the privacy practices of any linked sites or of any companies that we do not own or control. Linked sites may collect information in addition to that which we collect on our website. We encourage you to seek out and read the privacy notice of each linked site that you visit to understand how the information that is collected about you is used and protected.