Legal

Privacy

Privacy

Preamble

JIMMY FAIRLY is committed to the privacy of its customers and users of its services and website.
This Personal Data Protection Policy (hereinafter the "Policy") aims to provide simple, clear, and complete information about the processing of your personal data implemented by JIMMY FAIRLY.
JIMMY FAIRLY hopes that this policy will help you understand our commitments to protect your privacy.


You can refer to the following sections:

  • General principles adhered to by JIMMY FAIRLY in the processing of personal data (1);

  • Processing of your personal data modalities (2);

  • Cookie management (3);

  • Your GDPR rights (4);

  • Contact information of our Data Protection Officer where you can exercise your rights (5).

        JIMMY FAIRLY may modify the data protection policy as needed. We will ensure that you are informed of these changes either through a special notice on our site or through a personalized warning, especially in the context of our newsletter mailings.

        1. General commitments

        Compliance with Personal Data Protection Regulation

        JIMMY FAIRLY is responsible for processing your personal data in accordance with the conditions detailed in the Policy and ensures that the collection and processing of this data are carried out in compliance with the current regulations (Law No. 78-17 of January 6, 1978, known as the Data Protection Act in its latest version, and Regulation No. 2016/679 of April 27, 2016, known as GDPR).

        A Data Protection Officer has been appointed by JIMMY FAIRLY to ensure the security of your data and answer any questions you may have about your data.

        General Measures for Protecting Personal Data Legality of Processing

        JIMMY FAIRLY ensures that all data processing it performs as a data controller serves lawful purposes within the meaning of Articles 6 and 9 of the GDPR.

        Minimization of Collected Data

        JIMMY FAIRLY undertakes to collect and process only data strictly necessary for the purposes pursued in the context of its activities of creating, manufacturing, and selling optical products. All individuals with access to your data are bound by professional secrecy.

        Moreover, each form on our website and platforms limits the collection of personal data to the strict minimum and indicates the objective(s) of collecting this data as well as the recipient(s) of the data.

        Data essential to the management of your requests, if applicable, are indicated by an asterisk on each form. If you do not fill in these mandatory fields, JIMMY FAIRLY will not be able to respond to your requests and/or provide you with the requested services. Other information is optional and allows us to better manage your requests and improve our communication and services to you.

        Accuracy of Collected Data

        JIMMY FAIRLY undertakes to keep only personal data that is accurate and to rectify or erase promptly any data that is inaccurate.

        Limitation of Data Retention

        JIMMY FAIRLY undertakes to limit the retention of your personal data to a duration not exceeding that necessary for the purposes for which they are processed. Your personal data is kept in active use for a strictly limited duration to achieve the objective that justified their collection/record. Subsequently, your personal data is deleted, except when longer retention as archives is required in accordance with applicable legal provisions. Archived data is only accessed occasionally, for the purpose justifying their archiving and by persons specifically authorized within JIMMY FAIRLY. If necessary, your data is deleted after the required archiving period.

        Security of Your Data

        JIMMY FAIRLY undertakes to protect your personal data against any loss, destruction, alteration, unauthorized access, or disclosure. For this purpose, JIMMY FAIRLY implements appropriate technical and organizational measures, considering the nature of the data and the risks associated with its processing, to preserve the security and confidentiality of your personal data and, in particular, to prevent them from being distorted, damaged, or accessed by unauthorized third parties. These measures may include practices such as limiting access to data to only personnel authorized to access it due to their functions, contractual guarantees when using an external provider, privacy impact assessments, regular reviews of our privacy practices and policies, and/or physical and/or logical security measures (data pseudonymization, secure access, authentication process, backup copies, antivirus software, firewall, etc.).

        Sharing Your Data with Third Parties and Transferring Your Data Outside the European Union

        Subject to your prior consent when required, your data may be transmitted to technical service providers chosen for their expertise and reliability who act on our behalf and according to our instructions (IT subcontractor, host of our servers, business partners, etc.).

        We only authorize these providers to use your personal data to the extent necessary to provide services on our behalf or to comply with legal requirements, and we strive to ensure that your personal data is continuously protected.

        JIMMY FAIRLY may also communicate your data to third parties when such communication is required by law, a regulatory provision, or a court decision, or if this communication is necessary to ensure the protection and defense of our rights.

        JIMMY FAIRLY may transfer your encrypted health data to other countries where privacy laws may not be as strict. These transfers are governed by binding corporate rules as well as standard contractual clauses and, depending on the recipient countries of your data, additional measures proposed by the European Data Protection Committee (EDPC) to ensure a level of protection equivalent to that provided in the European Economic Area.

        Data Concerning Minors

        JIMMY FAIRLY undertakes to process personal data of minors only when strictly necessary for the exercise of its activity. If necessary, JIMMY FAIRLY undertakes to ensure respect for the rights of the minor regarding their personal data, in particular through adapted methods of informing the concerned persons, confidentiality, and security of data processing.

        2. Modalities of processing your personal data

        Why are your personal data collected?

        Your personal data may be collected and processed by JIMMY FAIRLY for the following purposes:

        • To enable you to use JIMMY FAIRLY services (including the creation and use of your JIMMY FAIRLY customer account).

        • To facilitate the ordering of JIMMY FAIRLY products, including their manufacturing, delivery, and billing. Additionally, this includes the transmission of invoices to your health insurance and social security organization if applicable.

        • To assist our opticians during in-store appointments (including vision tests) and help you choose frames, corrective lenses, and options if needed.

        • To offer you our current commercial offers tailored to your needs (e.g., sending advertising messages, contests, promotions).

        • To evaluate and improve our services and products, process your feedback, and make any improvements that could benefit you.

        • To provide after-sales services.

        • To implement your GDPR rights.

        • To ensure the tracking of our accounting and any disputes.


        All of these processes are based on various legal grounds (Article 6 of the GDPR):

        • Either based on the need for JIMMY FAIRLY to fulfill the order you have placed (execution of a contract).
        • Or based on a legal obligation (e.g., the obligation for JIMMY FAIRLY opticians to provide appropriate assistance for your vision test/correction needs; the obligation for JIMMY FAIRLY in the management of its accounting).
        • Or based on a legitimate interest of JIMMY FAIRLY for the needs of its commercial activities and improvement of its products and services.

        If you are not yet a JIMMY FAIRLY customer, your prior consent is requested before receiving our current commercial offers.

        What personal data is processed by JIMMY FAIRLY?

        JIMMY FAIRLY needs to collect and use various information about you, which may include:

        • Identification data: postal address, email, gender, phone number, date of birth, name, first name, etc.
        • Billing and/or payment data: bank details, payment method, transaction history. In the case of ordering corrective lenses: social security number, data related to your health insurance, etc.
        • Commercial and usage data: subscribed services, used products, promotion data, means and connection data, etc.
        • Health data (optical prescription, prescription for corrective lenses, data related to your visual correction, data related to your refraction tests, health questionnaires, optical equipment, etc.)
        • Data provided by filling out forms or questionnaires, downloading content.
        • Customer relationship tracking data: assistance requests, after-sales service, newsletter subscriptions; correspondence with the customer, etc.
        • Participation data in contests and surveys or other promoted activities that may require information about you.

        When we ask you to enter your personal data to enable your access to one of the features or services on our website, remember that some fields will be marked as mandatory as they are necessary for the service in question or to enable you to access that feature. Therefore, if you decide not to provide us with this data, your registration as a user may not be successfully completed, or you may not be able to benefit from these services or features.

        Who has access to your personal data?

        Your personal data is processed only by authorized personnel subject to professional secrecy. This includes:

        • JIMMY FAIRLY staff, including sellers, advisors, and opticians in-store, as well as those responsible for online stores, billing, accounting, commercial actions, customer reviews, after-sales services, and IT system management.

        All JIMMY FAIRLY personnel with access to your personal data are bound by professional secrecy.

        Our Partners

        Your personal data may be shared with our partners for order management, after-sales services, and sending messages, newsletters, advertising content, and ongoing promotions. These data will only be communicated to our commercial partners if you do not object (a non-opposition/consent checkbox will be offered beforehand). Please note that you can withdraw your consent or object at any time to the processing of your personal data for commercial promotion purposes.

        Organizations Taking Charge of Your Corrective Lenses

        For your corrective lenses to be covered by health insurance, your data must be communicated by JIMMY FAIRLY to your Health Insurance Fund and your health insurance company.

        Certified Health Data Host

        When we collect medical data for your vision tests and corrective lenses, this data is securely stored by a certified health data host, as required by regulations.

        How Long is Your Personal Data Retained by JIMMY FAIRLY?

        Your data is kept in JIMMY FAIRLY records for the duration necessary for the purpose of their processing. Please refer to the following table for these retention periods:

        Purpose

        Legal basis

        Duration of conservation

        Order management, delivery, service execution, or provision of goods, refraction tests, etc.

        Contract execution

        Duration of the contractual relationship

        Accounting, tax obligations, etc.

        Legal obligations

        Legal conservation duration of 10 years

        Customer relationship monitoring

        Surveys / customer reviews / commercial messages

        Legitimate interest

        Duration necessary to achieve the objective of the survey or until the exercise of the right to object

        Handling complaints

        Contract execution

        Duration of the contractual relationship

        After-sales service

        Contract execution

        Duration of the contractual relationship

        Studies on the quality of products and services,
        Sales statistics

        Legitimate interest

        Duration necessary to achieve the objective of the study or until the exercise of the right to object

        Management of prospecting activities for individuals who are not customers of JIMMY FAIRLY

        Automated sending of electronic messages (email, SMS, automated calling system, etc.)

        Consent

        3 years from the last contact with the person or until the withdrawal of consent

        Management of online forms

        Legitimate interest

        Duration necessary to manage the online request

        Management of your GDPR rights

        Legitimate interest

        Up to 3 years after the exercise of your right

        Dispute resolution

        Legitimate interest

        Throughout the duration of the relevant prescription

        Your data is stored in the active database of JIMMY FAIRLY for the durations specified in the table above, and afterward, they are archived for a period in accordance with the applicable legal provisions based on the purpose of the respective processing.

        In all cases, your data is retained using methods that ensure their security and confidentiality.

        3. Cookie Policy

        JIMMY FAIRLY's policy regarding cookie management is accessible online upon arriving on the site and is managed through CookieFirst.

        4. What are your rights?

        You have the right, at any time, to request access, rectification, erasure, and, in certain cases, portability of your personal data, or to request to restrict or object to its processing. You can also request the withdrawal of your given consent, if any, for a specific processing.

        To exercise these rights, you can directly contact JIMMY FAIRLY as specified in the section 'How and who to contact to exercise your rights?' below.

        Please note that if you exercise any of the rights mentioned above, you will be asked to let us know which right you wish to exercise and to provide certain information (copy of an ID card, passport, or other legally recognized identification) for identification purposes to process your request and protect against fraudulent requests from third parties.

        You also have the right to lodge a complaint with the National Commission for Information Technology and Civil Liberties ('CNIL') in case of a presumed violation of the current personal data protection rules.

        Below are explanations regarding the nature of your rights:

        • You want to access your personal data: The right of access allows you to know if personal data concerning you is processed by JIMMY FAIRLY and, if so, to obtain communication of it.


          • You want to rectify your personal data: The right of rectification allows you to request the correction or completion of your inaccurate personal data.


            • You want to delete your personal data: The right to erasure ('right to be forgotten') allows you to request JIMMY FAIRLY to erase your data for which JIMMY FAIRLY is the data controller, particularly for one of the following reasons:
              Your data is no longer necessary for the purposes for which it was initially collected or used by JIMMY FAIRLY, You have objected to the processing of your data by JIMMY FAIRLY for legitimate reasons, Your data is being processed unlawfully, Your data must be erased to comply with a legal obligation.Please note that personal data archived by JIMMY FAIRLY to comply with a legal obligation cannot be deleted.


              • You want to object to the processing of your personal data: The right to object allows you to object to the processing of your personal data for reasons related to your particular situation.


                • You want to limit the processing of your personal data: The right to limit processing allows you to request JIMMY FAIRLY to limit the use of your data when you dispute the accuracy of your personal data, in case of unlawful processing, when we no longer need your personal data, or if you have objected to the processing.


                  • You want to exercise your rights to the portability of your personal data: The right to data portability allows you to request to receive or have us transmit to a third party, in a structured, commonly used, and machine-readable format, the personal data you provided to us directly and that we process via an automated process for the execution of your contract or based on your consent.


                    • You want to withdraw your consent for a specific processing: When the processing of your personal data is based on your consent, you can decide to withdraw it at any time. In accordance with current regulations, the withdrawal of your consent will not affect the processing of personal data already carried out or those based on other legal grounds, such as the execution of your contract or compliance with a legal obligation.

                    5. How and who to contact to exercise your rights?

                    For any information or exercise of your rights regarding the processing of personal data managed by JIMMY FAIRLY, you can contact us by enclosing your request with a copy of an identity document bearing your signature (ID card, passport):


                    • By mail at the following address:

                      JIMMY FAIRLY Data Protection Officer

                      23, rue du Mail

                      75002 - Paris

                    JIMMY FAIRLY undertakes to provide you with a response within one month following the receipt of your request to exercise one or more of your rights.

                    You also have the right to file a complaint with the National Commission for Information Technology and Civil Liberties (CNIL), 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07, for any complaint relating to how JIMMY FAIRLY collects and processes your data.

                    When you exercise your rights, JIMMY FAIRLY processes your personal data for the purpose of managing your request (title, name, first name, copy of the identity document, nature of the request, response provided). This data is kept for a maximum period of 3 years, except for the copy of your identity document, which is kept for 1 year.