Privacy Policy
This Privacy Policy explains how Zenova Optical Ltd. (“Zenova”, “we”, “us”, or “our”), together with its authorised distributor for the State of Kuwait, collects, uses, discloses, and protects personal data obtained through www.zenovalens.com (the “Site”). It is intended to align with the data protection principles applicable under the laws of the State of Kuwait, including Law No. 20 of 2014 Concerning Electronic Transactions and the data privacy principles issued by the Communication and Information Technology Regulatory Authority (“CITRA”).
By using the Site, submitting an enquiry, or otherwise providing personal data to us, you acknowledge that you have read and understood this Privacy Policy. Where consent is the basis for our processing of your personal data, we will seek that consent clearly before collecting it.
Personal Data We Collect
We collect personal data that you provide to us directly, and limited technical data collected automatically when you visit the Site.
- Contact and enquiry data: your name, email address, the category you identify as (e.g. lens wearer, general enquiry, press/media), and the content of any message you send through the Site's contact form.
- Newsletter data: your email address, where you choose to subscribe to updates from Zenova.
- Technical data: your IP address, browser type, device type, and general usage data collected through cookies and similar technologies, as described in our Cookie Policy.
How We Use Your Personal Data
We use personal data collected through the Site only for the following purposes:
- To respond to enquiries submitted through the contact form and to connect you with an authorised Zenova optician where relevant.
- To send newsletter communications to subscribers who have opted in, and to allow you to unsubscribe at any time.
- To maintain, secure, and improve the Site, including through aggregated and, where possible, anonymised analytics.
- To comply with our legal obligations under the laws of Kuwait.
What We Do Not Do
The Site does not process orders, payments, or health information; lenses are dispensed exclusively by authorised opticians following a professional eye examination. We do not use personal data for automated decision-making that produces legal or similarly significant effects on you, and we do not sell, rent, or trade personal data to third parties.
Legal Basis and Consent
Where required under applicable Kuwaiti data protection principles, we process personal data on the basis of your explicit consent, given when you submit a form or subscribe to communications on the Site. You may withdraw consent at any time by contacting us using the details in Section 12 (Contact Us); withdrawal does not affect the lawfulness of processing carried out before withdrawal.
Where you provide personal data on behalf of a minor, or where you are under the age of 18, processing requires the consent of a parent or legal guardian. We do not knowingly collect personal data directly from individuals under 18 without such consent.
Cookies
The Site uses cookies and similar technologies to operate correctly and, where enabled, to understand how visitors use the Site. Full details of the categories of cookies we use, their purposes, and how you can manage your preferences are set out in our Cookie Policy.
Disclosure of Personal Data
We do not share personal data with third parties except in the following limited circumstances:
- With service providers who process data on our behalf (for example, email delivery or analytics providers), strictly for the purposes described in this Policy and under contractual confidentiality obligations.
- Where disclosure is required by Kuwaiti law, regulation, court order, or a lawful request from a competent authority, including CITRA.
- To protect the rights, property, or safety of Zenova, our users, or the public, in accordance with applicable law.
International Transfers of Personal Data
Some service providers we use to operate the Site (for example, website hosting or email infrastructure) may process personal data outside the State of Kuwait. Where this occurs, we take reasonable steps to ensure the receiving jurisdiction or recipient provides a level of protection for personal data that is adequate and consistent with the principles applied under Kuwaiti law, including through contractual safeguards with our service providers.
Data Retention
We retain personal data only for as long as reasonably necessary to fulfil the purpose for which it was collected — including to respond to your enquiry or maintain a newsletter subscription until you unsubscribe — or to satisfy legal, accounting, or reporting obligations under Kuwaiti law. When personal data is no longer required, we delete or anonymise it.
Data Security
We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, loss, or destruction. No method of transmission or storage is completely secure; while we take reasonable steps to protect personal data, we cannot guarantee its absolute security.
Your Rights
Subject to applicable Kuwaiti law, you may have the right to:
- Request access to the personal data we hold about you;
- Request correction of inaccurate or incomplete personal data;
- Request deletion of your personal data, where it is no longer necessary for the purpose it was collected or where you withdraw consent;
- Object to, or request that we restrict, certain processing of your personal data;
- Withdraw consent to processing at any time, without affecting the lawfulness of processing carried out before withdrawal.
Children's Privacy
The Site, including product information relating to myopia-management lenses for children, is directed at parents, guardians, and eye care professionals, and not at children. We do not knowingly collect personal data directly from individuals under the age of 18 without the consent of a parent or legal guardian.
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or in applicable law. The effective date at the top of this page indicates when this Policy was last revised. Continued use of the Site after an update constitutes your acknowledgement of the revised Policy.
Governing Law
This Privacy Policy is governed by, and construed in accordance with, the laws of the State of Kuwait. Any dispute arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the competent courts of Kuwait.
Contact Us
Questions about this Privacy Policy, or requests to exercise any of the rights described above, may be directed to our authorised distributor in Kuwait:
- Address: Plot C-22, Free Trade Zone, Shuwaikh Port, Kuwait · P.O. Box 1139, Safat 13012
- Phone: +965 1806080
- Email: support@zenovalens.com