MO GLOBAL EYEWEAR, S.L. Data Protection Policy

1. Who is the Data Controller?

The data processing manager for the different processes with regard to the management of users, customers, potential customers, collaborators and suppliers is MO GLOBAL EYEWEAR, S.L., with registered office at Avda de los Reyes, s P.I. Mina 28770 de Colmenar (CIF), Madrid and the province of Mina Viejo (CIF). B-28465193

We inform you that, in accordance with current regulations, MO GLOBAL EYEWEAR, S.L.has appointed a Data Protection Officer (DPO) to whom you will contact to carry out any enquiry related to the processing of your personal data. To do this, you can send an email to: dpo@multiopticas.com

We also inform you that, in the processing of data on the management of Users, Customers and Suppliers, there are no entities that are responsible for the processing.

For the purposes of our data protection policy, the contact phone number is 918 357 302 and the email address of Contact It is dpo@multiopticas.com.

2. What type of data do we have about your person and how have we obtained them?

The categories of personal data that MO GLOBAL EYEWEAR, S.L. processes on its customers and suppliers are:

• Identification details.
• Postal or electronic addresses.
• Commercial information.
• Economic and transaction data.
• Image (Virtual website tests)
• Data collected by cookies or other data storage and recovery devices: IP address, date and time of visit of the page, data relating to the browser, operating system and visitor's device, data relating to consent, user preferences, customization, behaviour and monitoring.

We also inform you that, due to the nature of the data processing on our users, customers and/or suppliers, we process the following special category data: Health data (visual and auditory graduations).

All the above data have been obtained or directly from you by submitting a commercial offer, contractual proposal, etc. Or through your company, providing us with the identification details and other information necessary to carry out the purpose of the contractual relationship between the parties. Your company or your company will be required to provide us with the updated data in the event of modification. With regard to the data on candidates for employment, we have obtained your data by submitting a CV or obtaining your candidacy through the services of a job portal. In the latter case, you have authorized this transfer of your data to our company by inserting your CV details in the employment portal.

3. How long will we keep your data?

Personal data relating to individuals linked to potential customers, customers and suppliers that MO GLOBAL EYEWEAR, S.L. collects through the different contact and/or information collection forms will be kept until they are requested to be deleted by the data subject. The data provided by our customers and suppliers will be kept while the commercial relationship between the parties remains in line with the minimum legal storage periods in each case.

In any case MO GLOBAL EYEWEAR, S.L. will store your personal data for the period of time that is reasonably necessary, taking into account our needs to respond to issues that arise or resolve problems, make improvements, activate new services and meet the requirements required by applicable legislation. This means that we can keep your personal data for a reasonable period of time even after you have stopped using our products or have stopped using this website. After this period, your personal data will be deleted from all the systems of MO GLOBAL EYEWEAR, S.L..

4. For what purpose and on what legal basis do we process your data?

At MO GLOBAL EYEWEAR, S.L. we process the data provided by the interested parties in order to manage different activities derived from specific procedures carried out in the area of sales, post sale service, supplier management, candidate management, quality of services, etc. This way, we will use your data to carry out some of the following actions based on the respective legal basis:

Purpose OF PROCESSING	Basis OF LEGITIMATION
Accounting, tax, administrative and commercial management of partners and collaborators	Execution (pre) contract; Regulatory obligation
Tax, accounting and administrative management with suppliers	Execution (pre) contract
Accounting, tax, administrative and commercial management of customers	Execution (pre) contract; Regulatory obligation
Process the return of products	Execution (pre) contract
Management and formalisation of the purchase of products through the MO website	Consent of the affected party; Execution (pre) contract; Regulatory obligation
Provision of the requested service (vision graduation, custom lens arrangement, product warranty management, etc.)	Consent of the affected party; Execution (pre) contract
Carry out virtual glasses tests through the MO website	Consent of the affected party
Management of model images for advertising campaigns	Execution (pre) contract
Carrying out an auditory test through the MO website.	Consent of the affected party
Ensure the security of facilities, goods and people.	Fulfilment of mission in the public interest or in the exercise of public powers of the interested party
Respond to requests from data protection stakeholders	Regulatory obligation
To exercise the right to effective judicial protection in the presence of judges and courts	Legitimate interest of the person responsible; Execution (pre) contract
Manage requests for information and channel incidents through the relevant department	Consent of the affected party
Management of requests for information that are sent via web and/or social media forms	Consent of the affected party
Processing of personal data to prevent the sending of commercial communications to those who have declared their refusal or objection to receive them.	Legitimate interest of the person responsible
Meet the requirements received from the Administration	Regulatory obligation
Register in the private area as a website user	Consent of the affected party
Managing user access requests to chat with website expert to resolve queries and queries	Consent of the affected party
Resolve issues, channel incidents through the relevant department, resolve queries and answer customers'questions, as well as attending the partner/collaborator	Consent of the affected party; Execution (pre) contract
Manage staff selection processes by collecting CV, studying and classifying them, managing work interviews and, where applicable, arranging the work contract with the chosen people	Execution (pre) contract
Operations in the segmentation of potential customers, carrying out capture campaigns, advertising exclusion	Consent of the affected party
Management of advertising and marketing operations for customer loyalty	Legitimate interest of the person responsible
Management and registration of MO gift card recipients	Execution (pre) contract
Management of cookies that store personal data, and monitoring it using analytical, remarketing and advertising tools	Consent of the affected party

As soon as you are obliged to provide the personal data to the legal basis referred to, in the event that you do not provide your personal data, you will not be able to execute your contract, comply with legal obligations or obligations derived from the public authorities.

We are not going to develop commercial profiles based on the information provided, and therefore we will not make automated decisions on you based on a commercial profile.

5. To which recipients will their data be communicated?

MO GLOBAL EYEWEAR, S.L. will never share your personal data with any third company that intends to use it in its direct marketing actions, except in the event that you have expressly authorised us to do so.

Your data may be communicated to you at the point of your choice for the management of the e-commerce service and/or for the conclusion of your online appointment.

We inform you that we may provide your personal data to public administration bodies and competent authorities in cases where MO GLOBAL EYEWEAR, S.L. receives a legal requirement from these authorities or in cases where, acting in good faith, we believe that such action is reasonably necessary to comply with a judicial process; To answer any legal claim or claim; Or to protect the rights of MO GLOBAL EYEWEAR, S.L. or its customers and the general public.

Please be informed that your data or data of third parties communicated by you or your company will not be transferred or communicated to third parties, unless legally required, the company being solely responsible for processing and safeguarding it.

MO GLOBAL EYEWEAR, S.L. may provide your personal data to third parties (e.g. Internet service providers that help us manage our website or carry out the contracted services, IT support and maintenance companies, logistics companies, management companies and tax and accounting advice, etc.). In any case, these third parties must at all times maintain the same security levels as MO GLOBAL EYEWEAR, S.L. in relation to your personal data and, where necessary, will be linked by legal commitments in order to keep your personal data private and secure, in order to use only the information following specific instructions from MO GLOBAL EYEWEAR, S.L.

We inform you that MO GLOBAL EYEWEAR, S.L. may communicate your data, according to the purpose of the service provided, to the following recipients located outside the EU, with this data flow being considered as an international data transfer in accordance with the current regulations:

List of International Transfer Recipients of MO GLOBAL EYEWEAR, S.L. in terms of user, customer and supplier management

Name of the Recipient	Destination country	Purpose of the data transfer	International transfer enable	Recipient profile ¹
SALESFORCE.COM EMEA LIMITED	USA	Mandatory for the provision of service	Data protection clauses adopted by the EU Commission	Data Processor
ORDERGROVE, INC	USA	Mandatory for service provision	Data protection clauses adopted by the EU Commission	Data Processor
Google INC	USA	Storage of Google Analytics information. Improved conversions.	EU-U.S Data Privacy Framework	Data sub-processor

¹ Data Processor: Third party providing services to our bank, data processing is carried out under our instructions and responsibility.
Data Processor: Third party that provides us with services indirectly through the provision of services to our data processor. The data sub-processor is responsible for the instructions given by the data processor and is therefore under the control of our entity as the Data Controller.
Assignee: Third party that obtains the data on the basis of a legal authorisation, the need to facilitate the provision of a service or the consent of the interested party. Once the data has been communicated, the transferee becomes the Data Controller with respect to the transferred data.

6. What are your rights as affected or interested parties?

Any person has the right to obtain confirmation as to whether MO GLOBAL EYEWEAR, S.L. is processing personal data that concern him or her or not.

Specifically, interested parties may request the right to access their personal data, as well as receive them in a common format and machine reading if the processing is carried out by electronic means (right of portability).

Similarly, interested parties may request the right to rectify inaccurate data or, if applicable, request its deletion when, among other reasons, the data is no longer necessary for the purposes that were collected.

Additionally, in certain circumstances, interested parties may request the limitation of processing their data, or in certain circumstances and for reasons related to their particular situation, interested parties may exercise their right to object to the processing of their data. MO GLOBAL EYEWEAR, S.L. will cease to process the data, except for compelling legitimate reasons, or to exercise or defend possible claims or exceptions established in the applicable regulations.

We also inform you that you have the right to withdraw your consent at any time, without this affecting the legality of the processing based on your consent prior to your withdrawal.

Likewise, the User is informed that at any time they can exercise the aforementioned rights by writing to us using the contact details that appear in Section 1, "Data Controller" of this Data Protection and Privacy Policy of MO GLOBAL EYEWEAR, S.L.. In any case, the bank reserves the right to request a document proving the applicant in order to verify the identity of the applicant and only in cases where such verification cannot be carried out by other means.

You will also have the right to file a claim with the Spanish Data Protection Agency, especially when you have not obtained satisfaction in exercising your rights.

7. Exercising rights by being a customer of one of our opticians associated with the MO network.

Each optical element associated with the MO GLOBAL EYEWEAR, S.L. network acts as the data controller of its customers, so to exercise any right in data protection, it must contact the establishment of which you are or have been a customer or user.

Additionally, you can contact MO GLOBAL EYEWEAR, S.L. by email at dpo@multiopticas.com, indicating the right you wish to exercise and the establishment to which your request is addressed. the Customer Service Department will contact the indicated optician and will send your request to you as soon as possible.

MO GLOBAL EYEWEAR, S.L. acts as the data controller for customers and users of the website https://en.multiopticas.com /

8. Data protection for website users.

In accordance with current Regulation (EU) 2016/679, MO GLOBAL EYEWEAR, S.L. informs that the personal data of the Users of the website (such as the data provided through the completed forms and the metadata associated with these forms: Date, time of delivery, IP of delivery, etc.) will be processed for the processing activity indicated in each data collection form on our website by MO GLOBAL EYEWEAR, S.L. This data processing will be covered by your own consent. By clicking on the “SEND” button, the User consents to the processing of his/her data by MO GLOBAL EYEWEAR, S.L..

When visiting our page, your browser sends information to our web server temporarily relating to the IP Address of the requesting computer, date and time of access, browsing information, browser used, operating system and name of your ISP to ensure a smooth, proper use and appropriate security, and administrative purposes.

MO GLOBAL EYEWEAR, S.L., has its own consent management platform, to obtain its consent regarding the configuration of cookies and their revocation.

The following Google services are also used: Google Tag Manager, Google Analytics, Google AdWords, Conversion Tracking, Google Ads Remarketing and Google Analytics Functions.

Google Tag Manager is used to manage website tags working without the use of cookies and does not collect any personal data. Google can directly obtain personal data from you through this procedure. For more information, visit the Google Terms of Service https://policies.google.com/terms and the privacy policy https://policies.google.com/privacy

Google Analytics uses cookies to customize and optimize the website, collecting data on the type and version of the browser, the operating system used, page visited previously, name of the device that accesses, its IP address and time of request of the server, user ID and advertising ID.

Google AdWords Conversion Tracking is used to obtain statistics on the use of our website for its assessment and optimization. Cookies are installed that collect data relating to the requesting computer's IP Address, date and time of access, browsing information, browser used, operating system and name of your ISP, generating user conversion or monitoring statistics after interacting with an ad. More information: Https://business.safety.google/adsprocessorterms / and https://support.google.com/google-ads/answer/9888656?hl=es#null.

Google Ads Remarketing is used to present to users of our website ads based on their interests on other websites within Google's advertising network, using Google Pixel and storing conversion cookies for monitoring.

Google analytics advertising functions is used to analyze user behavior to optimize our website and our advertising based on demographic and interest characteristics by using Google Pixel and storing user behavior through analytical cookies.

We also inform you that, unless legally required or expressly consented by MO GLOBAL EYEWEAR, S.L., you will not transfer your data to third parties.

Similarly, the User is informed that they may exercise their rights of access, rectification or deletion of data at any time, as well as have other rights recognised in this document and regulated in Regulation (EU) 2016/679, by writing to us using the Data Controller that appear in the section " 1

In addition, in accordance with the provisions of Law 34/2002 of 11 July, on Information Society and E-Commerce Services, MO GLOBAL EYEWEAR, S.L. undertakes not to send advertising via email without having obtained the express authorisation of the recipient. The User may object to the sending of advertising by checking the corresponding box.

9. Other useful information on our privacy policy

9,1 Security Measures

MO GLOBAL EYEWEAR, S.L. adopts the security levels required by European and Spanish regulations in force in data protection taking into account the state of the technique, the costs of application and the nature, scope, context and purposes of the processing described, as well as the risks of probability and severity of the variables for your rights and freedoms as a person.

9,2 Processing of minor data

Under EU Regulation 2016/679 and LOPDGDD 3/2018, minors over 14 years old can give their consent to the contracting of information society services, such as the registration in a forum, the completion of a contact form, etc. However, it will be the responsibility of MO GLOBAL EYEWEAR, S.L. to check the veracity of the age indicated by the child.

For the processing of data for children under 14 years of age, this data collection will always be carried out under the express consent of parents or legal guardians.

9,3 Modifications to our Data Protection and Privacy Policy

Occasionally, MO GLOBAL EYEWEAR, S.L. may make modifications and corrections in this section of Data Protection Policy for Customers, Suppliers and Users. Please check this section regularly to see any changes that may have occurred and how they may affect you.

Why is it necessary to accept this Data Protection and Privacy Policy?

This section provides you with all the information you need so that you can find out the type of data that MO GLOBAL EYEWEAR, S.L. maintains on its users, potential customers, customers and/or suppliers, the purposes pursued, the rights recognised by data protection regulations you as an affected person and how to exercise these rights. Therefore, by deliberately sending your personal data through our means of contact and/or the start of the business relationship with our company, we consider that you acknowledge and accept the processing of your personal data as described in this policy. This personal information will only be used for the purposes for which you have provided it to us or certain national or regional regulations enable us to do so.

In any case, we must warn you that a refusal by you to provide us with certain requested data could hinder the development of the contractual relationship between the parties with possible serious consequences when providing the various benefits contemplated within the commercial contract concluded with the contracting party.

If you have any questions in relation to this section of Data Protection Policy for Users, Potential Clients, Customers and Suppliers of MO GLOBAL EYEWEAR, S.L., please contact the company using the address provided in Section 1, "Data Controller" and we will be happy to help you and answer any additional questions you may have.

10. Applicable legislation

This Data Protection Policy shall be governed at all times by Spanish and European law on personal and privacy data protection.