1. Introduction

Welcome to (“we,” “our,” or “us”). We operate the website [Your Website URL] (the “Site”) and specialize in [Choose or combine from: the sale of blue-light filtering computer glasses and gaming eyewear / direct-to-consumer prescription-ready sunglasses / an e-commerce marketplace for vintage and collectible designer sunglasses / custom-fit sunglasses using facial scanning technology / sustainable sunglasses made from recycled materials / sunglass repair and refurbishment services / a sunglass subscription box service / a B2B platform for promotional sunglasses / a peer-to-peer marketplace for limited-edition sunglasses / AI-powered sunglass recommendations / children’s UV-protection sunglasses / smart sunglasses with audio and connectivity, etc.].

We are committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our Site, use our services, interact with our mobile app, or engage with our facial scanning, AI analysis, or other technologies.

2. Data Controller

The data controller for your personal data is:

409 Lai Chi Kok Road, Tsim Sha Tsui, Yau Tsim Mong District, Hong Kong
Email: [email protected]
Phone: 00852-6376035

3. Information We Collect

We collect several types of information, including:

• Personal Identifiers: Name, email address, shipping/billing address, phone number.
• Commercial Information: Purchase history, products viewed, cart contents, warranty details, rental agreements, subscription preferences.
• Payment Information: Credit/debit card details (processed securely by our payment processors), billing address.
• Technical Data: IP address, browser type, device information, operating system, browsing behavior on our Site, cookies and similar tracking technologies.
• Biometric & Health Data (where applicable): For custom-fit or prescription services, we may collect facial scan data, pupillary distance (PD), optical prescription details, and face shape analysis. For smart glasses, we may collect usage data. For health-related apps, we may collect UV exposure data.
• Preferences & Lifestyle Data: Information you provide about your activities (e.g., sports, driving), style preferences, lens technology interests, and feedback from customer research.
• User-Generated Content: Photos for virtual try-on, reviews, marketplace listings, authentication requests.
• Inferred Data: Recommendations generated by our AI-powered facial analysis or based on your activity data.

4. How We Use Your Information

We use your information to:

• Process and fulfill your orders, rentals, subscriptions, or repair requests.
• Provide, personalize, and improve our services, including AI recommendations, virtual try-on, and custom fittings.
• Communicate with you about orders, accounts, services, promotions, and research.
• Operate and secure our Site, app, and marketplace platforms.
• Conduct customer research and develop new products and lens technologies.
• Facilitate peer-to-peer transactions, authentication services, and recycling programs.
• Send marketing communications (with your consent where required).
• Comply with legal obligations (e.g., tax, consumer law) and prevent fraud.

5. Legal Basis for Processing (GDPR)

For users in the European Union and UK, our processing is based on:

• Contract: To fulfill your order or service agreement.
• Consent: For marketing emails, biometric data processing (facial scans), health-related data (UV exposure), and certain cookies. You may withdraw consent at any time.
• Legitimate Interests: For site security, fraud prevention, personalized recommendations (non-sensitive), and improving our services.
• Legal Obligation: To comply with accounting and tax laws.

6. Sharing Your Information

We share data with:

• Service Providers: Payment processors, shipping carriers, IT and cloud hosting providers, facial scanning/AI technology partners, marketing platforms, and customer service tools.
• Business Partners: For affiliate marketing, B2B clients (corporate gifting), or partner brands in our marketplace.
• Legal Authorities: When required by law or to protect our rights.
• Other Users: In peer-to-peer marketplaces, necessary information to facilitate transactions.
• Corporate Transactions: In connection with a merger, sale, or acquisition.

We require all third parties to respect your privacy and process data only for specified purposes.

7. International Data Transfers

Your data may be transferred to and processed in countries outside your country of residence (e.g., to our headquarters at 409 Lai Chi Kok Road, Tsim Sha Tsui, Yau Tsim Mong District, Hong Kong or to service providers). We ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or adequacy decisions.

8. Data Retention

We retain personal data only as long as necessary for the purposes outlined, including to fulfill orders, warranties, and legal obligations. For example:

• Transaction data is kept for tax and warranty periods.
• Facial scan data is deleted after the custom fitting is complete, unless you consent to longer storage.
• Marketplace account data is retained while your account is active.
• Inactive accounts may be archived after a reasonable period.

9. Your Rights & Choices

Depending on your location, you may have rights under GDPR, CCPA/CPRA, and other laws:

• Access & Portability: Request a copy of your data.
• Deletion: Request we delete your personal data.
• Correction: Request correction of inaccurate data.
• Opt-Out of Sale/Sharing (CCPA): We do not “sell” data in the traditional sense, but you can opt-out of sharing for cross-context behavioral advertising via our “Do Not Sell or Share My Personal Information” link or by contacting us.
• Marketing: Unsubscribe from marketing emails at any time.
• Cookies: Manage your cookie preferences via our cookie banner or browser settings.
• Biometric Data (Specific): You may request deletion of your facial scan data at any time.

To exercise these rights, please contact us at [email protected].

10. Special Provisions

• Children’s Privacy: Our services are not directed at children under 16 (or other age as per local law). For children’s products, we collect data only with verifiable parental consent.
• Sensitive Data: We process biometric, health, or prescription data only with your explicit consent or as necessary to provide a service you requested.
• Automated Decision-Making: Our AI recommendation tools involve profiling but do not produce legal or similarly significant effects. You can request human intervention.

11. Payment Processing

We use PayPal as our payment gateway to handle credit card, debit card, and other online transactions. All payment information you enter at checkout is processed and stored through PayPal’s secure, encrypted services to safeguard your data privacy and security.

For detailed information on how PayPal collects, uses, and protects your personal data, please see the PayPal Privacy Statement.

12. Third-Party Links

Our Site may contain links to third-party sites (e.g., affiliate links, partner brands). This Privacy Policy does not govern those sites.

13. Changes to This Policy

We may update this policy periodically. The updated version will be posted on our Site with a new “Last Updated” date.

14. Contact Us

For privacy-related questions, to exercise your rights, or for our Data Protection Officer (DPO), contact:

409 Lai Chi Kok Road, Tsim Sha Tsui, Yau Tsim Mong District, Hong Kong
Email: [email protected]
Phone: 00852-6376035