Data protection and Privacy policy


Data Privacy Statement


Phil Opticians respects your privacy and is committed to protecting your personal information (‘Personal Data’). Phil Opticians is the data collector, processor, and controller and is responsible for your Personal Data. To learn more, please read this Privacy Policy. This Privacy Policy aims to give you information on how Phil Opticians collects and processes your Personal Data through;

  • your use of our website [https://www.philopticians.com/] (for example, when you sign up for any of the Phil Opticians services, sign up as a customer through our website, or otherwise use our website);
  • any information you may provide to a member of the Phil Opticians team in our branches/stores when using any of the services provided by Phil Opticians as a customer;
  • information provided by suppliers, and other third parties engaged by Phil Opticians;
  • information provided to Phil Opticians when you purchase a product or service both online and, in our branches/stores; and
  • data provided to Phil Opticians when you take part in any of our marketing campaigns, promotions, loyalty programs, and competitions.

(altogether ‘the Phil Opticians Services’). Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from [https://www.philopticians.com/pages/terms-and-conditions].

This Privacy Policy also tells you about your privacy rights and how the law protects you, so please read this Privacy Policy carefully. Please note that this Policy does not apply to the employees, and a separate Internal Privacy Policy exists for the employees engaged by the Company.

This Policy has been prepared in accordance with the Data Protection and Privacy Act of Zambia.


Data Controller and Data Protection Officer

Phil Opticians, as identified at the top of this Data Protection and Privacy Policy, is the data collector, processor, and controller regarding all personal data processing carried out online or offline. In order to ensure maximum data protection, privacy, security, and integrity, Phil Opticians has appointed a Data Protection Officer (DPO).

Please contact them for any queries, complaints, or communications related to data protection and privacy.

To get in touch with Phil Opticians Data Protection Officer, please contact: gm@philgroupworld.com

This Privacy Policy explains how we collect, use, and (under certain conditions) disclose your personal information. This Privacy Policy also explains the steps we have taken to secure your personal information. Finally, this Privacy Policy explains your options regarding the collection, use, and disclosure of your personal information. By registering and accepting to use the Phil Opticians Services mentioned above, you accept the practices described in this Policy.

Data protection is a matter of trust, and your privacy is important to us. As such, we strive to maintain constant compliance with any privacy laws in Zambia as modified from time to time. We shall therefore only use your Personal Data in the manner set out in this Privacy Policy. We will only collect information where it is necessary for us to do so, and we will only collect information if it is relevant to our dealings with you or which otherwise relate to the Phil Opticians Services.

We will only keep your information for as long as we are either required to by law or as is relevant for the purposes for which it was collected.

You can visit our website and browse without having to provide personal details. During your visit to the website, you remain anonymous and at no time can we identify you unless you have an account on the website and log on with your username and password.

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you do not provide that Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or our Phil Opticians Services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.


Data that We Collect and How We Use It

We may collect various pieces of information if you seek to place an order for a product or service with us at our branches/stores and on the website so that we can provide the Phil Opticians Services.

We collect, store, and process your data for processing your purchase on the website and in-store and any possible later claims, and to provide you with our Phil Opticians Services. We may collect personal information including, but not limited to, the data groups set out below;

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.
  • Contact Data includes billing address, delivery address, email address, and telephone numbers.
  • Health Data includes data related to the state of physical or mental health of the customers and includes records regarding the past, present, or future state of the general health, optometrist tests and diagnoses, data collected in the course of registration for, or provision of the Phil Opticians Services specifically, optometrist services.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical and Location Data
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
  • Usage Data includes information about how you use our website, products, and Phil Opticians Services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We use different methods to collect data from and about you including through;

  • Direct interactions: You may give us your Personal Data with your express consent by filling in forms at our branches/stores or by corresponding with us by post, phone, email, or otherwise. This includes Personal Data you provide when you:
    • purchase or use our products or any of the Phil Opticians Services;
    • create an account on our website or at our stores/branches;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion, or survey; or
    • give us feedback or contact us.
  • Automated technologies or interactions: As you interact with our website, we will automatically collect technical data about your equipment, browsing actions, and patterns. We collect this Personal Data by using cookies, server logs, and other similar technologies – this information is anonymized. Please see our Cookie Policy for further details.

Personal Data means any information relating to an identified or identifiable natural person; an identifiable natural person 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. For the avoidance of doubt, Personal Data has the meaning as set forth in the Applicable Data Protection Laws.

Processing (as well as “Process,” “Processed” and other variations) means any operation, or set of operations, which is performed on Personal Data, or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Data Controller means, in general, the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data;

Data Subject means any identified or identifiable natural person whose Personal Data is included within the Consignee Data shared with the Subcontractor;

Data Processor means, in general, a natural or legal person, public authority, agency, or other body which Processes Personal Data on behalf of a Data Controller.


Consent

The use of your personal data at Phil Opticians is only after you have clearly expressed the approval that establishes and confirms freely given, explicit, informed, and unambiguous expression of your consent to the collection/processing of your personal data (hereinafter “Consent”).

The Consent you give us freely, voluntarily, and in your interest is explicit, informed, and conscious.

Your consent to the processing of personal data may be given to us by you or your representative in any form that allows us to confirm that it was received, namely:

  • In writing: In this event, the consent should contain the following information: surname, first name, patronymic (if applicable), address of the subject of personal data, number of the main identification document, document issue date and the issuing authority, or surname, first name, patronymic, address of the representative of the personal data subject, the number, issue date, and issuing authority of their main identification document, the requisites of the notarized power of attorney or other document confirming the authority of that representative (upon receipt of the consent from the representative of the personal data subject).
  • BY WAY OF IMPLICATIVE ACTIONS: The personal data subject expresses their will to establish a legal relationship with Phil Opticians, not in the form of an oral or written expression of their will, but by their behavior, from which such intention can be concluded (for example, registration on the Phil Opticians website, registration to Phil Opticians services, execution of monetary transactions into their personal account obtained through registration on our website, etc.).

We do not require your Consent to process your personal data in the following cases:

  • where the processing of personal data is necessary to achieve the objectives provided for by international treaties or laws of local jurisdictions, for the performance and discharge of the functions, powers, and duties conferred by law;
  • where processing of personal data is necessary for the administration of justice, the execution of a court decision or a decision by another legal body or an official subject to execution in accordance with local laws;
  • where processing of personal data is necessary to protect the life, health, or other vital interests of the subject of personal data if obtaining their consent is not possible;
  • where processing of personal data is necessary for the purposes of exercising the rights and legitimate interests of Phil Opticians or third parties, or for the achievement of socially significant purposes, provided that this does not violate the rights and freedoms of your personal data.

The company shall only obtain, store, and process the data of individuals who are customers of the company. A customer of the company is an individual who has agreed to the company’s terms and conditions.

The procedures for the withdrawal of your consent to the processing of your personal data, obtaining information about the availability of your personal data, and clarifying, blocking, and destroying your personal data which we hold on request are governed by the Data Protection and Privacy Act, 2019 and are carried out by us in full.


How We Use Your Personal Data and the Lawful Bases for Processing

We will use your Personal Data in the following circumstances:

  • Performance of a contract: Where we need to perform the Phil Services (i.e., a contract) we are about to enter into or have already entered into with you.
  • Legitimate interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Compliance with a legal obligation: Where we need to comply with a legal obligation.

Below is a table outlining the ways we use your Personal Data and the legal grounds we rely on to process it. We have also identified our legitimate interests where applicable. If you need further clarification about the specific legal ground for processing your Personal Data, please get in touch.

Purpose/Activity

Type of Data

Lawful Basis for Processing

To register you as a new customer online and in-store

Health Data, Identity, Contact

Performance of a contract with you

To process and deliver your order (including payments, fees, and charges)

Identity, Contact, Financial, Transaction, Marketing and Communications

Performance of a contract with you, Legitimate interests (recover debts, comply with the Proceeds of Crime and Anti-Money Laundering Act, No. 9 of 2009)

To manage our relationship with you (including regular check-ups, follow-ups, notifications, reviews)

Identity, Health Data, Profile, Contact, Marketing and Communications

Performance of a contract with you, Compliance with legal obligation, Legitimate interests (to update records, study customer behavior)

To enable participation in promotions, loyalty programs, or surveys

Identity, Contact, Profile, Usage, Marketing and Communications

Performance of a contract with you, Legitimate interests (study customer behavior, improve products/services)

To administer and protect our business and website (troubleshooting, data analysis, hosting, etc.)

Identity, Contact, Technical

Legitimate interests (business administration, IT services, network security, fraud prevention, business restructuring), Compliance with legal obligations (consumer protection, cybersecurity laws)

To deliver relevant website content and advertisements, and measure the effectiveness of advertising

Identity, Contact, Profile, Usage, Marketing and Communications, Technical

Legitimate interests (study customer behavior, improve business and marketing strategy)

To use data analytics to improve website, products, services, and customer experiences

Technical, Usage

Legitimate interests (define customer types, keep website relevant, business development, marketing strategy)

To make suggestions and recommendations about products or services

Identity, Contact, Technical, Usage, Profile, Marketing and Communications

Legitimate interests (develop products/services, grow business)

We process your Personal Data under the lawful grounds as specified in the DPA, 2019, particularly under legitimate interests, provided that your rights and freedoms are not overridden. If you have agreed to receive marketing communications, we may use your Personal Data for this purpose as set out below.


Marketing

We strive to provide you with choices regarding how your Personal Data is used, especially regarding marketing and advertising. You can control your preferences through our One-Time Password (OTP) mechanism and signature box, which allows you to view and manage how your Personal Data is used.

Upon receiving your consent, we may send you information about our products and services. You can opt out of receiving marketing communications at any time. Here’s how we manage marketing:

  • Promotional offers: We may use your identity, contact, technical, usage, and profile data to assess what products and services may be of interest to you. If you consent, we may send you marketing materials about our offerings.
  • Third-party marketing: We will seek your express consent before sharing your data with any third party for marketing purposes.
  • Opt-out: You can opt out at any time through the opt-out links in any marketing email or by contacting us at gm@philgroupworld.com. After receiving your request, we will cease sending you marketing materials within 7 working days. Opting out will not affect personal data you provided for product purchases or service experiences.


Data Retention

We will retain your Personal Data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy. We delete session data promptly after use. We also retain Personal Data to comply with legal obligations, resolve disputes, and enforce agreements. Usage data is retained for a shorter period unless required for security or functionality improvements.


Data Transfer

Your Personal Data, including sensitive data, may be transferred to and maintained on servers located outside Uganda. The transfer will be conducted in compliance with the DPA, and only upon obtaining your consent, ensuring safeguards are in place to protect your data’s integrity.

Phil will take all reasonable steps to ensure your data is handled securely and in accordance with this Privacy Policy. By submitting your data, you agree to the transfer and processing of your Personal Data outside Uganda.


Other Uses of Your Personal Information

We may also use your information for opinion and market research, but your details will remain anonymous. You can opt out of this at any time by notifying us. Survey answers will be kept separate from your email address. Additionally, your email address will only be disclosed for competition purposes.

If you have any questions or wish to exercise your rights regarding your Personal Data, please contact us at gm@philgroupworld.com.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may anonymize data about users of the Phil Opticians services and website and use it for various purposes, such as determining general locations of users and usage patterns. This anonymized data will not be capable of identifying you personally and may be supplied to third parties, such as publishers. Additionally, we may collect information on how the website is accessed and used (“Usage Data”), which may also constitute Personal Data.


Security

We have implemented appropriate technical and security measures to prevent unauthorized or unlawful access to, or accidental loss, destruction, or damage of your personal data. Access to your personal data is limited to those employees, agents, contractors, and third parties who have a legitimate need to know. They will process your personal data on our instructions and are bound by confidentiality obligations.

When we collect data through our website, we do so on a secure server. Our security procedures may occasionally request proof of identity before disclosing personal information to you. You are responsible for protecting against unauthorized access to your password and computer. We have put in place procedures to deal with suspected data breaches and will notify you and applicable regulators where legally required.


Your Rights as a Data Subject

You have the following rights:

  • Request access to your Personal Data: You can request a copy of the personal data we hold about you and verify whether we are processing it lawfully.
  • Request correction of your Personal Data: You can ask us to correct any incomplete or inaccurate data.
  • Request erasure of your Personal Data: You can ask us to delete or remove your data if there’s no valid reason for us to continue processing it.
  • Object to processing of your Personal Data: You can object to the processing of your personal data based on our legitimate interest or for direct marketing purposes.
  • Request restriction of processing: You can ask us to suspend processing of your personal data in certain situations.
  • Request transfer of your Personal Data: We can transfer your personal data to you or another third party in a structured, commonly used, machine-readable format.
  • Withdraw consent: You can withdraw consent at any time where we rely on consent to process your personal data, but this does not affect the lawfulness of processing carried out before your withdrawal.

Additionally, you have the right to request that we stop using your personal data for marketing purposes.

Section 1 – What Do We Do with Your Information?

When you purchase from Phil Opticians, we collect personal information such as your name, address, and email address. We also collect your IP address to better understand your browser and operating system.

  • Email marketing (if applicable): With your consent, we may send you emails about our store, promotions, new products, and updates.

Section 2 – Consent

We lawfully process your Personal Data after obtaining your express consent, in accordance with the provisions of relevant privacy regulations.

When registering at any of our stores or online, we will ask for your express consent to use your personal data. You will receive an OTP code containing a link redirecting you to this privacy policy. Once you accept, you consent to us using your personal data for contacting you and fulfilling our business purposes.

You can withdraw your consent at any time by contacting our Data Protection Officer at gm@philgroupworld.com.

 

Minors as Data Subjects

We may collect personally identifiable information from individuals under the age of 18. Before collecting personal data of minors, we will seek parental or guardian consent. If we learn that we have collected such data without consent, we will take steps to remove it.

How Do I Withdraw My Consent?

You can withdraw your consent by contacting us at gm@philgroupworld.com or through the contact numbers provided.

Section 3 – Disclosure

We may disclose your personal information if required by law, for security purposes, or if you violate our Terms of Service.

Section 4 – Hosting and Payment Processing

Our store is hosted (_____) provides us with the e-commerce platform that enables us to sell our products and services.

  • Payment: If you choose to complete a purchase using a direct payment gateway, your credit card information is encrypted using PCI-DSS standards.

Section 5 – Third-Party Services

We may use third-party service providers to help us operate our services. These third parties may have access to your personal data only for the purposes of providing the service and are obligated to maintain confidentiality.

Some third-party service providers, such as payment gateways, have their own privacy policies. Please review their policies to understand how they handle your information.

Section 6 – Links

When you click on links on our website, they may direct you away from our site. We are not responsible for the privacy practices of other websites, and we encourage you to review their privacy policies.

Section 7 – Security

We take reasonable precautions to protect your personal data. All credit card information is encrypted using SSL and stored with AES-256 encryption. While no method of transmission over the Internet is 100% secure, we comply with all PCI-DSS requirements.

Section 8 – Age of Consent

By using this website, you confirm that you are at least the age of majority in your jurisdiction or that you have consent from a parent or guardian to use this website.

Section 9 – Governing Law

This Privacy Policy is governed by the laws of the jurisdiction where Phil Opticians operates.

Section 10 – Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Changes will take effect immediately upon posting. If any material changes are made, we will notify you at least 30 days in advance.

If Phil Opticians is acquired or merged with another entity, your data may be transferred to the new owners.

Section 11 – Cookies

We use cookies to improve your experience on our website. You can learn more in our cookies policy.

Section 12 – Legal Disclaimer

We are not responsible for any events beyond our control. Please be aware that external websites may have different security practices than we do.

Section 13 – Consent to Data Protection and Privacy Policy

By using our services, you consent to the collection, processing, and storage of your personal data in accordance with this Privacy Policy.


Questions and Contact Information

If you have questions or would like to access, correct, or delete any personal information we have about you, please contact our Data Protection Officer at gm@philgroupworld.com.

Phil Opticians
Data Protection Officer
Email: gm@philgroupworld.com