POLICY TOPICS
1. Policy Amendments 2. Categories of Information Collected and The Purpose of Processing
3. Virtual Try On Tool
4. How we Collect your Information
5. Cookies and Tracking Technologies
6. Sharing Personal Information with third parties, and the categories of such third parties.
7. Data Retention
8. Information Security
9. Where Do We Store Your Information
10. Children
11. Your Rights
12. California Notice
13. Colorado Notice
14. Connecticut Notice
15. Virginia Notice
16. Utah Notice
17. Nevada Notice
18. General Information
1. POLICY AMENDMENTS:
We reserve the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent
version of this Privacy Policy will always be posted on the Website or App and the update date will be
reflected in the “Last Updated” heading. We will provide notice if these changes are material, and, where
required by applicable law, we will obtain your consent for such changes. Any amendments to the Privacy
Policy will become effective immediately, unless we notify otherwise.
2. CATEGORIES OF INFORMATION COLLECTED AND THE PURPOSE OF PROCESSING:
You are not required to provide us with any Personal Information. However, depending on the Service used,
certain features will require processing of Personal Information, or otherwise Sensitive Information.
“Personal Information”: is individually identifiable information, namely information that identifies an
individual or may, with reasonable efforts or together with additional information we have access to, enable
the identification of an individual, where identification of an individual also includes the association of such
individual with a persistent identifier such as a name, an identification number, persistent cookie identifier,
etc.
“Non-Personal Information”:: is information that does not personally identify an individual and includes
technical information such as the type of device, time stamp, or any Personal Information that has been
anonymized or aggregated, provided that such information can no longer be used to identify a specific
natural person. For the avoidance of doubt, any Non-Personal Information connected or linked to Personal
Information shall be deemed as Personal Information as long as such connection or linkage exists and
identifies a natural person.
“Personal Health Information” or PHI: means any information which relates to eyeglasses,
prescription, or
the provision of eye care services, identified with an individual who is the subject of such eye care services
and considered under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) as Personal
Health Information (“PHI”). The Properties are in essence, a consumer e-commerce platform, which are not
subject to HIPAA, however, we take the confidentiality of your PHI very seriously therefore we choose to
adopt the strict HIPAA Rules in maintaining the PHI as further detailed in the Notice of Privacy Practice.
We may also use or disclose to third parties, aggregated, or de-identified information (“De-identified Data”)
and we do not limit our third-party providers from using, selling, licensing, distributing, or disclosing de-
identified data.
The table below details the types of information we collect, access, share or use, and the purpose for
processing such information:
INFORMATION WE COLLECT - Contact Communications:
Where you contact us with any inquiries, through any means of communications we make available (e.g., an online form available on the Properties, email correspondence, chat, social media chats, toll free number, customer support, help center, etc.), you will be requested to provide us with your contact information such as your name, email address telephone number, and any other information needed to trace your order, or any information you choose to share with us through your correspondence or other communications with us. WHY DO WE COLLECT THIS INFORMATION
We use such contact communications for the purpose of responding to your inquiries and provide you with the support or information you have requested. Our correspondence with you, and its content, may be further processed and stored in order to improve our customer services as well as in the event we reasonably determine it is needed in order to comply with any regulatory requirement, or for handling and defending against any dispute you might have with us.
Further, calls may be recorded for the purpose of improving our customer support services or sales. INFORMATION WE COLLECT
- Payment Information:
When you conduct a transaction through the Properties we will process your payments by third party vendors. We do not collect your payment information, we may however, keep the last credentials of your credit card in case of recurring payments. Further, in certain cases, payment is made through your health insurance, which will require us to collect additional information as detailed in the Notice of Privacy Practice. WHY DO WE COLLECT THIS INFORMATION
We use any of this information to provide you with the Services and process the payments of the eye-products you have purchased. INFORMATION WE COLLECT
- Usage Data:
We perform such automatic collection through use of cookies, web beacons, unique identifiers, and similar technologies which allow us to collect information about the pages and screens you view, the links you click, and other actions you take when using our Properties. WHY DO WE COLLECT THIS INFORMATION
We use this information, as further detailed below, for analytic and marketing purposes, as well as, enhancing our Services, improving it, internal research, etc. We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. Our legitimate interests may span things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our services, protecting against harm to the rights, property or safety of our properties, users, or the public as required or permitted by law; enforcing legal claims, including investigation of potential violations of this Privacy Policy; o comply and/or fulfil our obligations under applicable laws, regulations, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request; and in accordance with our Terms of Service (“ Legitimate Interest”). INFORMATION WE COLLECT
- Advertising and Marketing:
Information about your impressions of, and reactions to, advertisements that appear on the Properties as well as ad-campaigns which are displayed online. This information may include the following: Device ID or unique identifier, device type, ID for advertising, unique device token, operating system, information regarding your clicks, views and engagement with our advertisement and Services, information concerning your traffic to and from the Platform, your referral URL, ad data, your IP address, your web log information, and your location information, including location information from We perform such automatic collection through use of tools that measure the advertisement, the content viewed, the emails (if you opened it or not), in order to obtain insights on how or campaigns optimize and convert, measure the performance of our Services and ad campaigns, features, measure the performance of our marketing efforts, etc. Further, we use your online behavioral information in order to market our Properties and Services – send you an email to remined you that you have not completed your order of items you have added to your cart, build a profile on you in order to present you offers which are tailor made to your preference, provide you with offers your mobile device or as can be derived from your IP address. We further know whether the ad was clicked, viewed and when, if the emails sent were opened or not. We use third party tools that enrich the data we have and add profiling data, insights, including demographic data, contact information, and information made available to the public, such as information from credit bureaus, to the extent permitted by applicable law. WHY DO WE COLLECT THIS INFORMATION
We perform such automatic collection through use of tools that measure the advertisement, the content viewed, the emails (if you opened it or not), in order to obtain insights on how or campaigns optimize and convert, measure the performance of our Services and ad campaigns, features, measure the performance of our marketing efforts, etc. Further, we use your online behavioral information in order to market our Properties and Services – send you an email to remined you that you have not completed your order of items you have added to your cart, build a profile on you in order to present you offers which are tailor made to your preference, provide you with offers which we believe you might be interested according to an offer you have redeemed previously, etc. To the extent we’re permitted to do so under applicable law, to display or send to you marketing and advertising material and general and personalized content and to track and analyze the effectiveness and relevance of such material. We may ask for your consent to send you our marketing offers and communications. INFORMATION WE COLLECT
- Analytic Information and Tracking:
Our analytics tools use cookies and similar technologies to collect and analyze information related to user behavioral metrics on our Properties, such as mouse movements, clicks, user inputs, scrolling, access time, visit duration, pages viewed, IP address (including approximate location), operating system, and page reloading. These tools provide insights into what works and what does not work for users of our Properties. We use a website analytics tool that provides session replay, heatmaps, funnels, form analytics, feedback campaigns, and similar features and functionality. This session replay tools may record your clicks, mouse movements, scrolling, form fills (keystrokes) in non-excluded fields, pages visited and content, time on site, browser, operating system, device type (e.g., desktop/tablet/phone), screen resolution, visitor type (first time/returning), anonymized IP address, location (city/country), language, and similar metadata. This tool does not collect information on pages where it is not installed, nor does it track or collect information outside your web browser. In addition, pixel tags (also known as web beacons and clear GIFs and cookies) may be used to, among other things, track the actions of users of our Properties or action taken by email recipients. WHY DO WE COLLECT THIS INFORMATION
We use web analytics tools to enhance the experience by optimizing the efficiency, design, and quality of our Properties, fix errors and ensure security and for our Legitimate Interest. We use the information and the tools to, for example, identify and repair technical errors, such as broken links that hamper the Properties’ functionality, and help us reconstruct the user experience to better understand, for example, where users may be encountering frustration or impediments to using the or other Properties We use this web-based analytics software because it provides us with a tool to track the online behavior of visitors while on the Properties and lets us replay your actions. This tool gives us the opportunity to make the Properties better and, in turn, provide you with an enhanced online experience as well. We obtain insights on how you and other visitors use the Properties; for example, whether you can easily locate certain pages or whether it takes multiple clicks to get to those pages. More importantly, allow us to provide you with a more seamless, customer-centric e-shopping experience while on the Website and other Properties. For more information about this session replay software, see FullStory’s Privacy Policy at FullStory’s Privacy Policy. Measure the success of our marketing efforts, and compile statistics about usage of the services and response rates. INFORMATION WE COLLECT
- Review and Feedback:
Where you submit a review or survey regarding your satisfaction of our products (including through our third-party service providers such as Trustpilot), you may share information such as rating, free text and an image you actively share when submitting such review. WHY DO WE COLLECT THIS INFORMATION
We use such information in order to improve our Services and allow others to make an informed decision prior to purchase the specific product. You agree that we may collect, use and retain the contents of such review and you image, including for the purposes of publicly displaying such information within the Properties and our marketing assets. INFORMATION WE COLLECT
- Social Media Interaction:
We allow you to share certain information with social platforms. If you actively communicate about us, our products or our brands on social media, we may collect (i.e., either directly or indirectly) and use a copy of your communication for branding purposes. For example, if you post #GlassesUSA in connection with one or more of our products across social media, we reserve the right to track, retain and use a copy of the post/tweet. WHY DO WE COLLECT THIS INFORMATION
PLEASE NOTE THAT ANY INFORMATION YOU POST OR DISCLOSE USING HASHTAGS, WILL BECOME PUBLIC AND MAY BE AVAILABLE TO OTHER USERS AND THE GENERAL PUBLIC. INFORMATION WE COLLECT
- Newsletter Registration:
If you register to receive our newsletter, updates, and other marketing materials and offers (i.e., discounts, coupons, etc.), you will be requested to provide us your email address. WHY DO WE COLLECT THIS INFORMATION
We use this information in order to send you the content or offer you have signed-up to receive. We will further store this information in order to include you in our marketing lists, as well as the "opt-out" list (solely the necessary information for such purpose), and to ensure we respect your choice and comply with applicable laws in this regard. INFORMATION WE COLLECT
- Mobile Marketing Services:
When you opt-in to receive text messages from us, including, but not limited to, through our re-order contact lenses feature or otherwise, or when you send us a text message (i.e., SMS and/or MMS messages), we will collect you phone number, and the date, time, content of any text messages that you send us. WHY DO WE COLLECT THIS INFORMATION
We will use your phone number in order to provide you with the services and send your reminders. In addition, we will use your phone number in order to send you recurring marketing messages and promotions. You are able to opt-out from such recurring text messages at any time by replying to the text message we sent you, click the link in the text message, or otherwise, whichever is available to you. Once you opted-out, you may receive one SMS confirming you have successfully opted-out. After that you will receive no further messages for this system unless you opt-in again. Please know that, even if you opted out of receiving text messages from us, we may still contact you for transactional or informational purposes (e.g., customer service, product information, etc.). INFORMATION WE COLLECT
- Device Information and Permissions :
We collect information from and about the computers, phones, and other web-connected devices you use that integrate with our Properties and Services, and we combine this information across different devices you use. For example, we use information collected about your use of our Services on your phone to better personalize the content or features you see when you visit or use our Properties on another device or to measure whether you took an action on your phone on a different device. Information we obtain from these devices includes: network connections, information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots), system, hardware and software versions, battery level, signal strength, available storage space, ISP, language, time zone, browser type, Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers, app and file names and types, and plugins. When you use our mobile App, we will request the following permissions: GPS, camera, photos, Bluetooth signals, and information about nearby Wi-Fi access (“ App Permissions ”). WHY DO WE COLLECT THIS INFORMATION
permission or the mobile settings, you can disable the App Permissions at any time, however note, depending on the App Permission you disable a feature or all features might not properly operate. Please note that the actual processing operation per each purpose of use detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. In addition, we may use certain Personal Information to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of our services and to enforce our terms of use and other policies, as well as to protect the security or integrity of our databases and Properties, and to take precautions against legal liability.
3. VIRTUAL TRY-ON TOOL:
Purposes:
In order to provide you and other visitors of GlassesUSA.com with the ability to “virtually” try-on certain frames
available on GlassesUSA.com, we may offer you to use a virtual try-on tool (the “VTO Tool”) that is owned and
operated by Perfect Corp. (“Perfect”), a third-party. GlassesUSA, independently or through Perfect, may collect
and/or use facial image data, which may potentially be considered of a biometric nature, even though not used for
identification purposes (“VTO Input Data”), for the purposes of facilitating your use of the VTO Tool, including
providing you with the virtual try-on experience and customized information, as well as for improving our
properties and services, including our eyewear prediction and recommendations model including, but not limited to,
the following:
- to address certain problems or concerns you may have with your glasses;
- to help better understand how our frames fit our customers and provide frame recommendations; and
- to provide, personalize, and improve our products and our services.
GlassesUSA and Perfect will not disclose, redisclose, or disseminate any VTO Input Data to any third party without/unless:
- first obtaining informed electronic/written consent from the customer/visitor to do so;
- the data completes a financial transaction requested/authorized by the customer/visitor;
- disclosure is required by law or ordinance; or
- disclosure is required pursuant to a valid warrant/subpoena issued by a court.
In the event GlassesUSA or Perfect, collects VTO Input Data from any customer or visitor, such data shall be permanently destroyed within one year after the date such VTO Input Data is collected. GlassesUSA and/or Perfect may store your photographs uploaded through use of the VTO Tool or Pairfect Match™ quiz for your convenience or your future use of the VTO Tool or Pairfect Match™ quiz if you created a GlassesUSA account or used associated email messages to transmit your photographs electronically. GlassesUSA and/or Perfect will permanently destroy all such photographs within one year after the date, such photographs are initially stored. You may also delete your uploaded photographs from your account at any time. GlassesUSA and Perfect does not collect any VTO Input Data or other data that may be considered of a biometric nature under applicable laws from your uploaded photographs and does not use your uploaded photographs for identification purposes. Security
GlassesUSA uses a reasonable standard of care to store, transmit, and protect from disclosure any VTO Input Data collected. Such storage, transmission, and protection from disclosure is performed in a manner that is the same as or more protective than the manner in which GlassesUSA stores transmits and protects from disclosure other forms of confidential and sensitive information, including personal information that can be used to uniquely identify an individual.
4. HOW WE COLLECT YOUR INFORMATION:
Depending on the nature of your interaction with us and our Properties, we may collect Personal Information as
follows:
- Automatically - we may use cookies and SDKs or similar tracking technologies to gather some information automatically when you interact with our Properties.
- Provided by you voluntarily - we will collect information if and when you choose to provide us with the information, such as where you create an Account, place and order, contact us, provide a proscription, etc.
- From publicly available sources - such as through social media platforms where you open an Account through such platforms, credit bureaus, all to the extent permitted under applicable law.
- From third parties who assist us in the performance of our Services - for example, when you purchase contact lenses through the Properties, we may request information from you about your medical records, vision conditions, information for data enhancer vendors, etc.
5. COOKIES AND TRACKING TECHNOLOGIES:
We use “cookies” and similar tracking technologies such as Software Developer Kits ('SDKs) when you access to,
interact with, or use our Properties. The use of cookies is a standard industry-wide practice. A “cookie” is a
small piece of information that a website assigns and stores on your computer while you are viewing a website.
Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, enable
automatic activation of certain features (e.g., shopping cart), for statistical purposes, as well as for
advertising purposes. You can find more information about cookies here: www.allaboutcookies.org.
Our Cookie Policy, available here , details the tracking technologies we use on our Website. Currently, we use the following SDK in our App: AppsFlyer, Firebase, Sentry, Luna and Cloudbees Rollout.
6. SHARING PERSONAL INFORMATION WITH THIRD PARTIES, AND THE CATEGORIES OF SUCH
THIRD PARTIES:
We may share your personal information with third parties (or otherwise allow them access to it) only in the
following manners and circumstances:
- Third Party Service Providers: We partner with a number of selected service providers or business associates, whose services and solutions complement, facilitate and enhance our own. These include hosting, data and cyber security services, fraud detection and prevention services, merchant processing, shipping, postal and delivery services, website and mobile app functionality, manufacturing services, e-mail and text message distribution and monitoring services, advertising, data optimization and marketing services, affiliation and related analytics services, customer support and call center services, as well as our business, legal and financial advisors, and others. Any disclosure or access to Personal Information is strictly subject to such third party’s confidentiality undertakings and the application of appropriate safeguards. These third-parties have limited access to your Personal Information solely as needed to perform their services.
- Third parties with whom you choose to share your Personal Information with: We may disclose to a family member, other relative, close personal friend, or any other person you identify, PHI directly relevant to that person's involvement in your health care, health care treatment (such as pharmacists, doctors, nurses, optometrists, etc.), or payment related to your care. If a person has the authority by law to make health care decisions for you, we will generally regard that person as your "personal representative" and treat him or her the same way we would treat you with respect to your PHI. Further, we may share your Personal Information with social media platform when you choose to share information with the social platform about your activities on the Services.
- Enforcement: We may disclose Personal Information and PHI to enforce our policies and agreements, as well as defend our rights, including the investigation of potential violations thereof, alleged illegal activity or any other activity that may expose us, you, or other users to legal liability, and solely to the extent required. In addition, we may disclose Personal Information to detect, prevent, or otherwise address fraud, security, or technical issues, solely to the extent required.
- Protecting Rights and Safety: We may share your Personal Information with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of our Company, of any of our customers, or any members of the general public.
- Our Affiliated Companies: We may share Personal Information internally within our affiliates for the purposes described in this Privacy Policy. In addition, should we or any of our affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of our assets, your personal information may be shared with the parties involved in such event. If we believe that such change in control might materially affect your personal information then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Platform.
7. DATA RETENTION:
Except as specifically detailed above, we retain the Personal Information we collect as long as it remains
necessary for the purposes set forth above, all in accordance with applicable laws, or until the individual
expresses a preference to opt-out.
In certain circumstances, we will retain your Personal Information for longer periods of time and mainly:
- Where we are required to retain Personal Information in accordance with legal, regulatory, tax, or accounting requirements;
- Where we deem retention is necessary to obtain an accurate record of your dealings with us in the event of any complaints or challenges (e.g., adverse event); or
- If we reasonably believe there is a prospect of litigation relating to your Personal Information.
8. INFORMATION SECURITY:
Securing your Personal Information including your PHI is of high priority. We design our systems with your
security and privacy in mind. We have implemented physical, technical, and administrative security measures that
comply with applicable laws and industry standards, such as encryption, access restrictions and permissions, etc.
Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no
warranty, express, implied, or otherwise, that we will always be able to prevent such access.
Please contact us at: privacy@glassesusa.com , if you feel that your
privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of
a third party's attempt to gain unauthorized access to any of your Personal Information. We will make a reasonable
effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover
a security incident related to your Personal Information.
9. WHERE DO WE STORE YOUR INFORMATION
We maintain Personal Information that we collect from you in secured cloud storage environments provisioned by
third party cloud providers in the United States. Nevertheless, any such information will be maintained and
processed by us and our authorized affiliates and service providers which are located in various locations around
the world, including, without limitation, the United States and in our facilities in Israel.
Data obtained from you in connection with our mobile marketing programs
may include your cell phone number, your carrier’s name and the
date/time/content of any text messages that you send us. We reserve the
right to use this data in the same manner and for the same purpose(s) as
other data that we may collect in accordance with this Privacy Policy,
including without limitation, in order to provide the services you
request of us, and to otherwise operate, develop and improve the
service.
10. PROTECTING CHILDREN:
In order to access to, interact with or use our Services, you must be over the age of eighteen (18). Therefore, we
do not knowingly collect Personal Information from minors under the age of eighteen (18) and do not wish to do so.
Any purchase of products through our Properties that is intended for a child under eighteen (18) years of age,
must be carried out by his/her legal guardian within such legal guardian’s account, and without providing us any
personal information of such child. We reserve the right to request proof of age at any stage so that we can
verify that minors under the age of eighteen (18) are not using the Services. If we learn that we have collected
personal information from a child under eighteen (18) years, we will delete that information as quickly as
possible. If you believe that we might have any such information, please contact us at service@glassesusa.com.
11. YOUR RIGHTS:
| RIGHT TO KNOW (ACCESS) | You have the right to confirm whether we collect Personal Information, or Personal Data, and to know the information specifically collected on you. You can exercise your right by reviewing this Privacy Policy, and in case you would like to receive a copy of your information please submit a request here: https://privacy.saymine.io/GlassesUSA. |
| RIGHT TO CORRECTION | You have the right to correct inaccuracies in your Personal Information, or Personal Data, taking into account the nature of the processing and the purposes. At any time, you may correct any of the Account information through your account or app settings, or otherwise you may contact us at: privacy@glassesusa.com |
| RIGHT TO DELETION |
You have the right to delete the Personal Data, or Personal Information we collected from you, you can
exercise your right for deletion through the App settings, and through this form:
https://privacy.saymine.io/GlassesUSA. You do not need to create an account with us to submit a
request to know or delete. The deletion right is not absolute and in certain circumstances we may deny such request. We may deny your deletion request, in full or in part, if retaining the information is necessary for us or our service provider(s) for any of the following reasons: (1) Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you; (2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (3) Debug products to identify and repair errors that impair existing intended functionality; (4) Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (5) Comply with the law or legal obligation; (6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; (7) Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (8) Make other internal and lawful uses of that information that are compatible with the context in which you provided it. We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our processors to take similar action. |
| RIGHT TO PORTABILITY | You have the right to obtain the personal data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We will select the format in which we provide your copy. Please fill in this form to receive a copy of your data: https://privacy.saymine.io/GlassesUSA . |
| RIGHT TO OPT OUT FROM:
(I) SELLING PERSONAL DATA; (II) RIGHT TO OPT OUT FROM TARGETED ADVERTISING; AND (III) RIGHT TO OPT OUT FROM PROFILING |
You have the right to opt out of the sale of your Personal Data, or Personal Information, for the purposes
of targeted advertising, sale to a third party for monetary gain, or for profiling in furtherance of
decisions that produce legal or similarly significant effects concerning you or any other consumer.
You may authorize another person acting on your behalf to opt out (including by technical tools and opt
out signals).
Optimax does not profile you in a manner that has significant effect of you or and other
consumer, therefore there isn’t an opt-out option.
We do not “sell” or “share” information as most people would commonly understand that term, we do
not, and will not, disclose your Personal Information
or Personal Data in direct exchange for money or some other form of payment, however, we do share Personal
Information or Data for analytic and marketing purposes, including targeted advertising, when we promote
our Properties or products. In most cases we obtain Personal Data, or Personal Information collected
automatically from our Properties and your actions therein, and do not combine it with your actions on
other websites or apps, however, our third-party partners might do so, when providing analytic or
advertising services to us.
You have the right to opt-out of the “sharing” of your personal information for “cross-contextual
behavioral advertising”, or “targeted advertising”, often referred to as “interest-based advertising” as
well. You may opt out through the “do not sell or share my personal information” button available within
the Properties’ footer or within the App settings. You may further opt out through device settings
(opt-out from tracking AAID, ADID, please see the following for information applicable to all devices: https://thenai.org/opt-out/mobile-opt-out/ ) , or
by using Self-Regulatory Program for Online Behavioral Advertising such as:
• Digital Advertising Alliance’s (“ DAA ”):
https://www.aboutads.info/choices • Network Advertising Initiative (“ NAI ”): https://www.networkadvertising.org/choices. Last, you are able to install privacy-controls in the browser's settings to automatically signal the opt-out preference to all websites you visit (like the “ Global Privacy Control ”). We honor the Global Privacy Control as a valid request to opt-out of the sharing of information linked to your browser. In any event, please keep in mind, opt-out tools are limited to the browser or device you use because they work off your browser ID and device ID. If you’re not signed-in to your customer account or don’t have a customer account, you will need to opt-out on each browser and device you use. Your browser may save some information in its cookies and cache to maintain your privacy preferences. Clearing these may remove opt-out preferences, requiring you to opt-out again. If you opt-out, you will still see ads online, but these ads will not be based on your inferred interests. Some automated means may still be used to collect information about your interactions with our online services for the other purposes such as to remember user preferences or enable specific functionality. We use necessary cookies to make our Properties work. Necessary cookies enable core functionality such as security, network management, and accessibility. You cannot disable those. You can read more about targeted adverting and take additional steps to control targeted advertising from many ad networks and exchanges by visiting the Digital Advertising Alliance ( www.optout.aboutads.info ). As online environments continue to evolve, additional opt-out mechanisms or privacy settings may become available to you. We encourage you to review the information on opt-outs and settings that browser owners, device manufacturers, technology companies, and industry associations make available to you. You can opt-out from receiving our marketing emails by clicking “unsubscribe” link. |
| RIGHT TO APPEAL | If we decline to take action on your request, we shall so inform you without undue delay, within 45 days of receipt of your request. The notification will include a justification for declining to take action and instructions on how you may appeal, if applicable. |
| NON-DISCRIMINATION | Such discrimination may include denying a good or service, providing a different level or quality of service, or charging different prices. We do not discriminate our users. |
12. CALIFORNIA NOTICE
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“
CCPA ”) effective November 2020, and as amended by the CPRA, effective January 1, 2023.
Please see the CCPA Privacy Notice available here which discloses
the categories of personal information collected, purpose of processing, source, categories of recipients with
whom the personal information is shared for a business purpose, whether the personal information is sole or
shared, the retention period, and how to exercise your rights as a California resident.
Information we collect in relation to our Virtual Try-On tool may constitute biometric information under the CCPA.
For more information on our collection and processing of information that may constitute biometric information,
data in relation to our Virtual Try-On tool, please click here.
13. COLORADO NOTICE
This section applies to Colorado residents acting only as an individual or household context (and not
in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an
employment context). Pursuant to the Colorado Privacy Act (“ CPA ”) please see below the disclosure of the
categories of personal data that are collected or processed, the purposes, how consumers can exercise their
rights, and appeal such decision, categories of third-parties the controller shares or sells the personal data, or
sells the personal data for advertising and how to opt-out.
“Personal Data” as defined in the CPA means information that is linked or reasonably linkable to an
identified or identifiable individual and does not include publicly available information that is lawfully made
available from government records, or that a consumer has otherwise made available to the public; de-identified or
aggregated consumer information; or information excluded from the CPA scope, such as: Health or medical
information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) or 42 CFR Part 2-
“Confidentiality Of Substance Use Disorder Patient Records”, Personal information covered by certain
sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or
and the Driver’s Privacy Protection Act of 1994, Children’s Online Policy Protection Act of 1998 (COPPA), Family
Educational Rights and Privacy Act of 1974, national Security Exchange Act of 1934, higher education data and
employment data.
Sensitive Data includes (i) racial or ethnic origin, religious beliefs, mental or physical health
condition or diagnosis, sex life or sexual orientation; (ii) Genetic or biometric data that can be
processed to uniquely identify an individual; or (iii) child data. Information we collect in relation to
our Virtual Try-On tool may constitute biometric information under the CPA. For more information on our collection
and processing of information that may constitute biometric information, data in relation to our Virtual Try-On
tool, please click here .
Under CPA, Optimax needs to provide a privacy notice that identifies the categories of personal data that are
collected or processed, the purposes, how consumers can exercise their rights, and appeal such decision,
categories of third-parties the controller shares or sells the personal data, or sells the personal data for
advertising and how to opt-out.
In Section 2 “ CATEGORIES OF INFORMATION COLLECTED AND THE PURPOSE OF PROCESSING
” of the Privacy Policy, we describe our collection and processing of Personal Data, the categories of
Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or
used. We will not collect additional categories of Personal Data or use the Personal Data we collected for a
materially different, unrelated, or incompatible purpose without obtaining your consent. Additionally, in Section 6 “ SHARING PERSONAL INFORMATION WITH THIRD PARTIES, AND THE CATEGORIES OF
SUCH THIRD PARTIES ” details and discloses the categories of third-parties we share for business purposes.
Section 11 “ YOUR RIGHTS ” details and discloses your rights and Personal Data
shared or sold for targeted advertising.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete
your Personal Data. If the request is submitted by someone other than you, proof of authorization (such as
power of attorney or probate documents) will be required.
We will respond to your request within 45 days after receipt of a verifiable Consumer Request (no more than twice
in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when
reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we
refuse to take action on a request, you may appeal our decision within a reasonable period time by
contacting us at privacy@glassesusa.com and specifying you wish to
appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not
taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal
is denied, you may submit a complaint as follows: Colorado AG at
https://coag.gov/file-complaint/
If you have an account with us, we may deliver our written response to that account or via email at our sole
discretion. If you do not have an account with us, we will deliver our written response by mail or electronically,
at your option. You do not need to create an account for submitting a request.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response
we provide will also explain the reasons we cannot comply with a request, if applicable.
14. CONNECTICUT NOTICE
Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (the “ CDPA ”) if you are a resident of
Connecticut, acting in an individual or household context (and not in a commercial or employment context
or as a representative of business, non-profit or governmental entity), your rights with respect to your personal
data are described below.
"Personal Data" means any information that is linked or reasonably linkable to an identified or
identifiable individual and does not include publicly available information that is lawfully made
available from government records, or that a consumer has otherwise made available to the public; de-identified or
aggregated consumer information; or information excluded from the CDPA scope, such as: HIPAA, GBPA, non-profit
entities, higher education, employment data and FCRA, Driver's Privacy Protection Act of 1994, Family Educational
Rights and Privacy Act, Farm Credit Act.
"Sensitive Data" under the CDPA means data revealing racial or ethnic origin, religious beliefs, mental or
physical health condition or diagnosis, sex life, sexual orientation, citizenship, or immigration status; The
processing of genetic or biometric data for the purpose of uniquely identifying an individual; Personal data
collected from a known child; Precise geolocation data. In certain cases, we will process precise geolocations
data if you explicitly enable the GPS permission within our App. Further, information we collect in relation to
our Virtual Try-On tool may constitute biometric information under the CDPA. For more information on our
collection and processing of information that may constitute biometric information, data in relation to our
Virtual Try-On tool, please click here .
Under CDPA, Optimax is required to provide you with a clear and accessible privacy notice that includes:
categories of personal data processed, purpose of processing, instructions for exercising consumer rights and
appealing decisions, categories of personal data shared with third parties, categories of third parties with whom
data is shared, and any sale of data or targeted advertising.
In Section 2 “CATEGORIES OF INFORMATION COLLECTED AND THE PURPOSE OF PROCESSING”
of the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data
that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will
not collect additional categories of Personal Data or use the Personal Data we collected for a materially
different, unrelated, or incompatible purpose without obtaining your consent. Additionally, in Section 6 “ SHARING PERSONAL INFORMATION WITH THIRD PARTIES, AND THE CATEGORIES OF
SUCH THIRD PARTIES ” details and discloses the categories of third-parties we share for business purposes.
Section 11 “ YOUR RIGHTS ” details and discloses your rights and Personal Data
shared or sold for targeted advertising. Note, under CDPA consent can be withdrawn within 15-days of notice at any
time.
We shall respond to your request within 45 days of receipt. The response period may be extended once by 45
additional days when reasonably necessary, taking into account the complexity and number of requests and we inform
you of such extension within the initial 45 day response period, together with the reason for the extension.
If we decline to take action on your request, we shall so inform you without undue delay, within 45 days of
receipt of your request. The notification will include a justification for declining to take action
and instructions on how you may appeal. Within 60 days of our receipt of your appeal, we will inform you in
writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons
for the decisions. If the appeal is denied, you may submit a complaint to the Connecticut Attorney General at
link: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.
We shall provide information in response to your request free of charge, up to twice annually, unless requests are
manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially
reasonable efforts, we may request additional information reasonably necessary to authenticate you and your
request. If we cannot authenticate you and your request, we will not be able to grant your request.
15. VIRGINIA NOTICE
Under the Virginia Consumer Data Protection Act, as amended (“ VCDPA ”) if you are a resident of Virginia
acting in an individual or household context (and not in an employment or commercial context), you have
the following rights with respect to your Personal Data.
"Personal Data" means any information that is linked or reasonably linkable to an identified or
identifiable natural person, and does not include publicly available information that is lawfully made available
from government records, that a consumer has otherwise made available to the public; de-identified or aggregated
consumer information; Information excluded from the VCDPA scope, such as: HIPAA, GBPA, non-profit entities, higher
education, employment data and FCRA, Driver's Privacy Protection Act of 1994, Family Educational Rights and
Privacy Act, Farm Credit Act.
“ Sensitive Data ” under the VCDPA means data revealing racial or ethnic origin, religious beliefs, mental
or physical health diagnosis, sexual orientation, or citizenship or immigration status; the processing of genetic
or biometric data for the purpose of uniquely identifying a natural person; the personal data collected from a
known child; and precise geolocation data. In certain cases, we will process precise geolocations data if you
explicitly enable the GPS permission within our App. Further, information we collect in relation to our Virtual
Try-On tool may constitute biometric information under the VCDPA. For more information on our collection and
processing of information that may constitute biometric information, data in relation to our Virtual Try-On tool,
please click here .
The VCDPA requires Optimax discloses the categories of personal data processed, purpose of processing, how you can
exercise your rights, including how a you may appeal our decision with regard to the consumer request, the
categories of personal data shared with third parties and with whom, and Optimax sells personal data to third
parties or processes personal data for targeted advertising.
In Section 2 “CATEGORIES OF INFORMATION COLLECTED AND THE PURPOSE OF PROCESSING”
of the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data
that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will
not collect additional categories of Personal Data or use the Personal Data we collected for a materially
different, unrelated, or incompatible purpose without obtaining your consent. Additionally, in Section 6 “ SHARING PERSONAL INFORMATION WITH THIRD PARTIES, AND THE CATEGORIES OF
SUCH THIRD PARTIES ” details and discloses the categories of third-parties we share for business purposes.
Section 11 “ YOUR RIGHTS ” details and discloses your rights and Personal Data
shared or sold for targeted advertising.
We will respond to your request within 45 days after receipt of a verifiable Consumer Request (no more than twice
in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when
reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we
refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us
at privacy@glassesusa.com and specifying you wish to appeal. Within
60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response
to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may
submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform
.
If you have an account with us, we may deliver our written response to that account or via email at our sole
discretion. If you do not have an account with us, we will deliver our written response by mail or electronically,
at your option. You do not need to create an account for submitting a request.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The
response we provide will also explain the reasons we cannot comply with a request, if applicable.
We shall provide information in response to your request free of charge, up to twice annually, unless requests are
manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially
reasonable efforts, we may request additional information reasonably necessary to authenticate you and your
request. If we cannot authenticate you and your request we will not be able to grant your request.
16. UTAH NOTICE (effective January 2024)
Under the Utah Consumer Privacy Act (“ UCPA ”) if you are a resident of Utah, acting in an individual or
household context (and not in a commercial or employment context) your rights with respect to your
personal data are described below. “ Personal Data " refers that is linked or reasonably linkable to an
identifiable individual, and does not include de-identified data and publicly available data or data that is
processed not within the scope of UCPA.
In Section 2 “CATEGORIES OF INFORMATION COLLECTED AND THE PURPOSE OF PROCESSING”
of the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data
that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will
not collect additional categories of Personal Data or use the Personal Data we collected for a materially
different, unrelated, or incompatible purpose without obtaining your consent. Additionally, in Section 6 “ SHARING PERSONAL INFORMATION WITH THIRD PARTIES, AND THE CATEGORIES OF
SUCH THIRD PARTIES ” details and discloses the categories of third-parties we share for business purposes.
Section 11 “ YOUR RIGHTS ” details and discloses your rights. Note, under UCPA,
our sharing practices with third-party analytic and advertising tools are not considered a “sale”.
17. NOTICE TO NEVADA RESIDENTS
Nevada law allows Nevada residents to opt out of the sale of certain types of personal information. Subject to
several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for
monetary consideration to another person. We currently do not sell personal information as defined in the Nevada
law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and will
record your instructions and incorporate them in the future if our policy changes. You may send opt-out requests
to privacy@glassesusa.com .
18. GENERAL INFORMATION
This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws
of the State of Israel. Any and all such claims and disputes shall be brought in, and you hereby consent to them
being litigated in and decided exclusively by a court situated in Israel.
Our Properties may, from time to time, contain links to and from the websites of our partner networks, advertisers
and affiliates. If you follow a link to any of these websites, please note that these websites may have their own
privacy policies and that we do not accept any responsibility or liability for these policies. Please check these
policies before you submit any personal information to these websites
For any question, inquiry or concern related to this Privacy Policy or the processing of your Personal
Information, you may contact our privacy team at privacy@glassesusa.com
.
