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Privacy Notice for Candidates

JOB APPLICANTS’ PRIVACY NOTICE

At EssilorLuxottica, we are committed to protect Personal Data. Upholding this commitment is essential to our success and reputation,
and ultimately our ability to fulfil our mission of helping people see more, be more and live life to its fullest.

1. PURPOSE OF THIS NOTICE

As part of its recruitment process, EssilorLuxottica collects (directly or through recruitment agencies) job applicant’s Personal Data.
This Job Applicants’ Privacy Notice (“Privacy Notice”) aims to clarify and detail the main principles that EssilorLuxottica (“we,” “us,”
“our”) applies in the context of recruitment or career communication to Candidates who apply for jobs, internship or apprenticeship
opportunities within EssilorLuxottica directly or indirectly through external recruiters (“you,” “yours”) data that it collects and
processes.

EssilorLuxottica (and/or the Affiliate processing your Personal Data) is a "controller". This means that we are responsible for deciding
how we hold and use the Personal Data that you share with us. We are required under data privacy legislation to inform you on the
way we process your Personal Data.

In this Privacy Notice, capitalized terms shall have the following meaning:

EssilorLuxottica
Job Applicant / Candidate
Personal data
Processing of Personal Data
EssilorLuxottica, a French company having its registered office at 147, rue de
Paris 94227 Charenton-Le-Pont Cedex, France, or any of its Affiliates. For the
purposes of this privacy notice, "Affiliates" shall refer to any of the legal entities
owned and/or controlled by EssilorLuxottica. For the purposes of this Policy,
EssilorLuxottica shall be deemed to have "control" over an Affiliate where it
holds 50% or more of the shares or voting rights in that Affiliate and whose
financial statements are consolidated in the EssilorLuxottica consolidated
financial statements. [MD1]
Any person applying directly or indirectly for a job position or an internship or
apprenticeship opportunity in EssilorLuxottica or being contacted directly or
indirectly by EssilorLuxottica or any recruitment agency acting on its behalf as
a potential candidate for a job position.
Any information, about an individual from which that person can be identified
(name, contact details, identification number, etc.). The categories of Personal
Data that we may process are enumerated in this Employee Privacy Notice.
Any action conducted concerning your Personal Data such as, the collection,
recording, organization, storage, modification, transfer, deletion, access,
consultation, etc. of such data.

2. UNDERSTANDING WHO PROCESSES YOUR PERSONAL DATA

In the context of recruitment within EssilorLuxottica, recruitment management means and tools including websites and recruitment
platforms, (“Recruitment Websites”) may be mutualized and allow you to apply for jobs, internship or apprenticeship opportunities
everywhere EssilorLuxottica is present, allowing different Affiliates to access your data simultaneously in compliance with the
applicable laws and regulations. As a consequence,

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EssilorLuxottica refers to:

1.
1. EssilorLuxottica or any of its Affiliates in its capacity as publisher of the Recruitment Websites, or as a recruiter for jobs
offers; or
2. Any Affiliate of EssilorLuxottica likely to access to Candidates’ data, either as part of the management of a recruitment
process after having posted a job offer on the Website, or as part of a search on the EssilorLuxottica talent database.

Except in exceptional cases involving entities in certain countries, EssilorLuxottica and its Affiliates act as joint controllers, within the
meaning of the GDPR, for the processing of data for the purpose of administering recruitment within the Group. It means that they
jointly define the human, technical and material resources required for processing, as well as its purposes.

Therefore, EssilorLuxottica and its Affiliates have agreed, in a joint controllership agreement, their respective obligations to protect
your data and to respect your rights in relation to such data. This agreement provides in particular the allocation rules regarding the
definition of the characteristics of the processing implemented, providing the required information to data subjects, responding to their
requests to exercise their rights or implementing security and data protection measures.

For example, the harmonization of processing between the different entities of the Group falls within the competence of
EssilorLuxottica, such as the adoption of a uniform data retention policy for Candidates/talent data or the management of the visibility
of Candidate profiles with the HR departments within EssilorLuxottica Affiliates or the sending of similar job offers. The EssilorLuxottica
Affiliates to which You are likely to apply process Your data throughout the recruitment process, in particular by organizing job
interviews and the sending of Newsletters if You have chosen to subscribe to this service.

3. WHY DO WE PROCESS YOUR PERSONAL DATA?

In order to understand who you are and how interesting your career paths is we need to process your Personal Data. We use various
tools and applications to provide you with information on our organizations, career opportunities within EssilorLuxottica, and to
facilitate and personalize your recruitment and integration process within EssilorLuxottica, in accordance with applicable laws and
regulations. At each step, you may share Personal Data with us, or we may collect your Personal Data.

EssilorLuxottica may process your Personal Data for a number of purposes which include without limitation:

PURPOSES LEGAL BASIS DETAILS

Research and selection
of potential Candidates
Legitimate Browsing professional job seeking or professional networking websites or
interest
applications to identify and select potential Candidates, from open source
platforms
Obtaining communication of potential Candidates from a third party vendor /
recruitment agency
Receiving and processing including storage of spontaneous candidatures
Selecting potential Candidates by using scoring tools offered by job seeking
websites

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Selecting Candidates with regards to the particular skills or expertise

required by the job search (e.g. technical, language skills, professional
experience, etc.
Assessing Candidates using structured interviews, psychometric or
competency-based interviews (technical tests, business cases etc.) or other
methods decided by EssilorLuxottica and communicated to the Candidate
during the interview process
Recording and managing candidatures in our Recruitment Websites,

Recruitment and Consent/ Legal Entering in contact with potential Candidates

selection of employees
for filling open positions
obligation
Responding to job applications by Candidates
Collection and management of job applications
Evaluation of job applications
Decision whether to offer the job to the Candidate;
Check a Candidate’s eligibility to work in the country or in the specific
position
Reference checks and background checking, notably in order to ensure
compliance with applicable legal obligations

Creation of a pool of Legitimate Creating a database of CVs and profiles for future recruitment purposes,
potential Candidates for interest
which our internal talent team will be able to consult, update and maintain.
future positions

Equal opportunity Legal obligation Ensuring compliance with equal opportunity obligations and non-
monitoring
discrimination, where applicable

Managing recruitment of Legal obligation Complying with our legal obligations with respect to disabled persons
persons with disabilities
Making reasonable adjustments for Candidates who have a disability

Legal claims Legitimate Responding to and defending against legal claims.

interest
Temporary staff Legitimate Management of temporary / interim staff Personal Data received from interim
interest
/ work agencies for the purposes of their mission in EssilorLuxottica.

Job alert and Consent Presentation with relevant job offers or relevant job recommendations based
personalized job on resumes and profile of preferred place of work and career level.
recommendations

EssilorLuxottica has a legitimate interest in processing Personal Data during the recruitment process and for keeping records during a
certain period of time. Processing data from Job Applicants allows us to manage the recruitment process, assess and confirm a
Candidate's suitability for employment and decide to whom to offer a job.

You may request us to send you job alerts through the Recruiting Website, where possible, by completing your job search criteria and
preferences. You can stop receiving these job alerts at any time by clicking on the unsubscribe link contained in the job alert email.

Supplementing this Job Applicants’ Employee Privacy Notice, we may provide other privacy notice on specific occasions and/or in
specific countries.

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4. WHAT PERSONAL DATA MAY WE PROCESS ABOUT YOU?

4.1 Categories of Personal Data

For the purposes set out above, in the context of your application for recruitment in EssilorLuxottica, we may process Personal Data
relating to you, including the categories and types of data below.

We may collect this information in a variety of ways. For example, Personal Data may be contained in application forms, CVs or
resumes, or collected through interviews or other forms of assessment.

CATEGORY OF DATA TYPES OF DATA

Contact details First, middle and last names, date and place of birth, nationality, gender,
distinctions, email address, address of residence, phone number.

Personal life data Where legally allowed, or because it is necessary to process your
application, marital status, family members.

Data about Candidates
professional experience
Education and skills including (at the final stage of recruitment) copy of
diplomas or certifications
Past or current employment: professional experience, employment
history and recommendation letters, references
Evidence of employment such as work certificate issued by the previous
employer
Current compensation: salary, bonus, long term incentives, awards,
benefits entitlement and (at the final stage of recruitment) related
justification
Potential obligations or restrictions from your current employment (e.g.
non-compete clause)
Other activities you may have that are relevant for the management of
conflict of interests: your interests or the interests of your family and/or
friends in third party businesses or activities;
any other information you provide (such as information included in your
resume or cover letter, or in any online application you may fill on our
websites or third party platform such as job search and career
networking websites or applications)
Information that you make publicly available such as contact information,
your education, and work experience information (e.g. when you share
information via job search and career networking sites as far as it is
relevant to consider you for career opportunities)

Candidates expectations Expected compensation and benefits of the Candidates

Preferred place of work
Willingness to relocate

Application documents Information about specific needs of trip or accommodation you may
generated by us
require during the recruitment process

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Test results, feedback and notes from interviews or other selection

processes

Contact with referees
We will seek information from third parties referred by you only once a
job offer has been made to you and will inform you that it is doing so.
The only exception to this is if you are selected for interview and have
provided EssilorLuxottica with your permission to contact your referees
prior to a job offer being made then we will go ahead and contact your
referees.

Background checks and
criminal records
We may collect background checks and criminal records, where allowed
or requested by applicable laws, in order to check your eligibility for the
job position, at the final stage of the recruitment process.
We may also collect information such as your education and work
experience, contact information, and demographics, to help ensure
additional control measures, from third-party data providers who have
the rights to provide us with your information. These partners collect your
information from publicly available sources, or through third parties they
work with.

Philosophical, political and Such data will never be Processed by us, unless for the purposes of
religious opinions, sexual
equal opportunity monitoring and where legally allowed or required. This
orientation, information
relating to racial or ethnic data should never be used to discriminate your candidature.
origin
Health Data Whether or not you have a disability for which the organization needs to
make reasonable adjustments during the recruitment process, where
legally allowed or required, or such data is necessary in order to comply
with legal requirements relating to employment of disabled persons;
Health information to monitor the spread of infectious diseases in the
workplace (where appropriate)

Immigration information Copies of passport, visa, work permit

Other permits Copies of the driver’s license or other professional license (e.g.
optomestrist license), if required for the job position to be filled.

Connection data When you connect to our Recruitment Websites, we collect Data such as
IP addresses, type and version of the browser, connexion time and
location, identification data (login, password), connection logs, activity
conducted on our Recruitment Websites.

4.2 Processing of Sensitive data

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We may process certain categories of Personal Data which may be qualified as “sensitive” Personal Data (e.g. social security
numbers or national identification numbers, philosophical, political and religious opinions, , sexual orientation, information relating to
EssilorLuxottica and your personal health data, racial or ethnic origin, criminal records).

However, we will only process such sensitive data:

where it is required or allowed under local applicable legislation

while implementing adequate safeguards to ensure the protection of such “sensitive” Personal Data;
where it is strictly necessary to meet legal obligations and/or
where it is relevant as per local practices, meets a clearly defined and legitimate purpose and respects the rights and
individual freedoms of the individuals whose “sensitive” Personal Data will be processed.

4.3 Information about criminal convictions

We may only use information relating to criminal convictions on an exceptional basis at the final stage of the recruitment, where it is
mandatory or relevant for the considering position and that the law allows us to do so. This will usually be where such processing is
necessary to carry out our obligations and provided we do so in line with our Personal Data protection policy.

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able
to do so.

4.4 Cookies

Cookies improve the user experience on our services because they allow, e.g., the system to recognize returning visitors. Cookies are
small, usually randomly coded text files that are sent to your computer and stored there. These cookies allow your browser to track
certain information that may be retrieved and used by internet servers at a later stage. Our Recruitment Websites use cookies and
similar technologies for several reasons (e.g. faster loading, saving or your settings, facilitating your log-in, etc.). You can refer to our
privacy statement. Most browsers allow you to turn off cookies. If you want to know how to do this, please look at the help menu on
your browser. However, switching off cookies will restrict your use of our Recruitment Websites.

4.5 What happens if you do not provide the personal information we request?

If you do not provide the information we request, we may not be able to properly process your application or to take your application
further.

In the event your candidature would be successful, we will ask for additional information and relevant evidence that are necessary to
finalise your recruitment. The finalisation of your recruitment will be subject to the communication of such information and documents.
If you do not provide the information we request, we may not be able to finalise your recruitment and the conclusion of an employment
contract with you.

5. HOW DO WE PROCESS YOUR PERSONAL DATA?

5.1 How do we collect your Personal Data

1.
1. We may collect Personal Data directly from you:

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i. You provide us with it, for example when filling in a contact form, participate in a job interview or answer the
questions of a recruitment test that we may implement; or
ii. We collect it through the implementation of technologies such as cookies.

1.
1. We may also collect Personal Data indirectly when we collect it from service providers or partners, as is the case when
We collect data resulting from your answers when using the tools provided by our providers or publicly available media
such as for example LinkedIn, Twitter or Facebook as part of the analysis of your application;
2. We may collect Personal Data from third parties such as referents (when we issue a job offer to you), former employer
(to confirm previous employment dates) or education institutions (in order to confirm your diplomas).

5.2 We share your Personal Data with the persons directly linked to the recruitment

We keep your Personal Data and share it internally with:

The members of our internal talent recruitment team within EssilorLuxottica and its Affiliates;
The Human Resource business partners supporting the recruiting manager;
The recruiting manager and potentially his/her hierarchical superiors;
Other managers involved in the recruitment process (e.g. other departments’ managers that may interview you) and
As the case may be, third party consultants supporting the recruitment process or the individual assessment of candidatures,
for the sole purpose of this recruitment process.

5.3 We may share your Personal Data with other Affiliates of the Group

EssilorLuxottica is a global organization with offices and operations throughout the world and your Personal Data may be shared with
Affiliates of EssilorLuxottica.

As a result of the above, your Personal Data may be accessed and/or transferred to countries which do not have equivalent data
protection laws to those required within the European Economic Area (EEA).

In such cases, EssilorLuxottica ensures that, at all times, appropriate safeguards are implemented to ensure that your Personal Data is
processed in accordance with applicable legislation. In this respect, where your Personal Data is processed by another
EssilorLuxottica entity, the safeguards are based on the commitments taken on the basis of a dedicated transfer agreement binding
upon the EssilorLuxottica entity involved in the processing.

5.4 Where is your Personal Data processed?

Your Personal Data is hosted in data centers located in the European Union but that may be connected, exchange and have links with
applications based in different geographies that may, when relevant, be specified in additional privacy notices. It may be transferred to,
accessed and stored in a country outside the European Economic Area ("EEA") and in particular may be processed by staff operating
outside the EEA who work for us or for one of our service providers.

EssilorLuxottica l will only transfer Data outside the EEA in a secure manner and in accordance with applicable laws. As some
countries may not have laws governing the use and transfer of Personal Data, We will take all reasonable steps to ensure that third
parties comply with the terms of this Policy. These measures may include the control of the standards applied by such third parties

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regarding Data protection and security and/or the execution of appropriate contracts (e.g. the standard contractual clauses adopted by
the Commission of the European Union).

5.5 Is your Personal Data transferred to third parties?

We keep your Personal Data confidential. However, we may disclose your Personal Data where it is necessary to meet our own legal
obligations or to liaise with third parties who are related to the recruitment process or the assessment of candidatures, notably for the
following purposes:

verification of employment references and/or education;

verification of criminal records (where mandatory or necessary and relevant for the considering position and allowed by the
law);
performing tests and other assessment of the human capital, leadership or other kinds of assessment services connected to
the job application;
hosting of our Recruitment Websites;
professional advice on the recruitment;

such third parties being subject to confidentiality and Personal Data protection requirements;

We may also transfer your Personal Data in the following cases:

Based on your consent and if permitted by law;

If we have to disclose or share your Personal Data to comply with a legal obligation or a judicial or administrative decision, or
for any other circumstances that you have agreed to;
For the defense of EssilorLuxottica’s rights in the context of litigation or to protect the rights, property or safety of
EssilorLuxottica, its customers or employees;
If we sell or intend to sell a business or assets (by any means, including by sale of the business carrying on that business or
owning those assets), we may disclose your Personal Data to the purchaser of that business or assets and/or to potential
purchasers for the purposes of a discovery process, an audit, of for the purpose of getting advice; or
If Luxottica or any part of its assets is acquired by a third party, the Personal Data held in relation to the Candidates and linked
to those assets will be one of the transferred assets. In this case, your Personal Data will be processed by the purchaser which
will act as the new data controller and its data protection policy will then govern the processing of your Personal Data.

We do not disclose your Personal Data under any other circumstances and do not sell it.

5.6 For how long do we retain your Personal Data?

EssilorLuxottica has set up an internal specialized talent team as its own internal recruitment agency, and we retain your CV Personal
Data (name and surname, employment history and contact details, mainly) for the purposes of future prospection. We will retain your
CV Personal Data on file for a period of up to 36 months after we have communicated to you our decision about whether to appoint
you to the role. for any suitable employment opportunities. After this period, we will seek your consent to continue to retain your CV
Personal Data, in order to contact you for potential suitable employment opportunities. You are free to withdraw your consent at any
time by notifying us in writing.

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In some circumstances we may anonymize your personal information so that it can no longer be associated with you, in which case
we may use such information without further notice to you.

If your application is successful, your Personal Data gathered during the recruitment process will be transferred to your personnel file
(in hard copy or electronic format, or both), and on HR and payroll systems and retained for the duration of your employment.

Wherever practicable we will not retain original documents or print-outs and instead will make a note on our central HR and Payroll
system that the relevant check or procedure has been completed.

6. AUTOMATED DECISION-MAKING

Recruitment processes are not based solely on automated decision-making. When we set up recruitment questionnaires and other
skills validation tests for job offers for specific business sectors or when we ask recruitment agency to process them on our behalf, we
guarantee not to carry out a fully automated individual decision-making: the analysis of the answers and results to these
questionnaires and tests always involves a human being who analyses the results in order to finalize the Candidate selection process.

7. HOW DO WE PROTECT YOUR PERSONAL DATA?

EssilorLuxottica regards the protection of Personal Data as an essential priority.

In this respect, EssilorLuxottica has implemented appropriate measures and safeguards to protect the Personal Data it processes.

This is reflected in EssilorLuxottica’s procedures described in the EssilorLuxottica Group Data Protection Policy, and in the actual
measures implemented throughout the Group.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or
accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees,
agents, contractors and other third parties who have a business need to know. They will only process your personal information on our
instructions and they are subject to a duty of confidentiality. These measures range from technical security measures that protect IT
systems to the physical security measures employed at EssilorLuxottica sites. EssilorLuxottica also requires its staff to participate in
information security trainings. Details of these measures may be obtained from the Group Information Security Department.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a
breach where we are legally required to do so.

8. YOUR RIGHTS

You have the right to:

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1.
1. access your Personal Data;
2. request information about what data is processed about you, for what purposes and who such data may be disclosed
to;
3. request that EssilorLuxottica ceases processing your Personal Data provided that such request is based upon
legitimate grounds as duly evaluated by EssilorLuxottica.
4. request rectification, blocking or erasure of your data when they are inaccurate or if the purpose for processing is no
longer lawful or appropriate.
5. to the extent [or in the limited circumstances where] our processing of your Personal Data is based upon your consent,
withdraw your consent, without affecting the lawfulness of our processing based on your consent before its withdrawal;
6. request, where applicable by local laws, your Personal Data portability, i.e. that the Personal Data you have provided to
us be returned to you or transferred to the person of your choice, in a structured, commonly used and machine-
readable format without hindrance from us and subject to your confidentiality obligations

In order to exercise your rights, please contact:

privacy@essilorluxottica.com

Please note, however, that depending on local data privacy laws or other laws and regulations, certain Personal Data may be
exempt from the above-mentioned rights.

[MD1]Subsidiaries can replace this definition with their own corporate name and address

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